This Personal Information Collection Statement and Privacy Notice sets out how McCabe associated entities1 (herein referred to as "McCabe”, "us", "we" or "our") is data controller and/or data processer (or data user) responsible for processing the personal data you provide to us.
We are committed to managing personal data securely and effectively. We will only keep the personal data required to undertake our business processes and will only share or transfer the data you provide to us for the purposes outlined below.
Our data protection policy and procedures have been developed in line with the requirements of Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) and with reference to the General Data Protection Regulation (Regulation (EU) 2016/679).
We collect and process personal data about you when you interact with us, use our website, sign up to our newsletters or attend seminars and events, when you enter into an employment contract with us, submit an online job application and when you purchase services from us or agree to provide services to us. We may also collect personal data about you in the course of managing our relationship with our clients. The personal data we process includes:
your name
your Hong Kong Identity Card number, passport number, and/or any other information that may help us ascertain your identity
your home or work address, email address and/or phone number
your job title
your payment details, including billing addresses
information about you relevant to our provision of services, which could include information about your conduct, your beliefs, your previous and existing employments, and/or your previous and existing business activities, etc.
your IP address and information related to the browser or device you use to access our website and other analytics data
your username and password when accessing restricted website content
any other information you may provide, whether directly or indirectly.
We will store data that we receive from you or your related third parties, data that is publicly available and data from third parties such as conflict checking agencies.
The provision of personal data is generally voluntary unless otherwise specified. A failure to provide the requested personal data, or the provision of inaccurate or incomplete information, may result in us not being able to accept your instruction, request or enquiry (as the case may be).
We process personal data listed in paragraph 2 above for the following purposes:
as required to establish and fulfill a contract with you, for example, if you enter into an agreement to provide or receive services, or if you seek to be employed or engaged by us. This may include verifying your identity, undertaking credit and due diligence checks, billing and payments, communicating with you and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
to comply with applicable law and regulation;
in accordance with our legitimate interests in managing and protecting McCabe's business interests and legal rights including but not limited to use in connection with legal claims, compliance, regulatory, credit & due diligence checks and investigative purposes (including disclosure of such information in connection with legal process or litigation);
to meet our obligations to comply with applicable anti-money laundering/counter-terrorist financing laws or regulatory requirements or guidance of professional bodies;
for the provision of services to our clients in accordance with the legitimate interests of our clients and us;
to manage our relationship with you, in accordance with our legitimate interests;
to manage our risk;
to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our services;
we may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
to monitor use of our websites and online services and we may use your information to help us check, improve, promote and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests; we may also use third parties to assist us in carrying out customer credit and due diligence checks in accordance with our requirements under relevant anti-money laundering/counter-terrorist financing regulations;
in circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
we may use your information to invite you to take part in market research or surveys, where you have consented to us doing so.
We will not use your personal data to carry out or facilitate direct marketing activities without your prior consent.
We may share the personal data you provide to us with the third parties below (whether within or outside the HKSAR) where this is necessary for legal or regulatory reasons, or in order to provide our services to you or our clients and undertake our business processes:
our professional advisors such as our auditors and external legal and financial advisors
our suppliers, business partners and sub-contractors
government authorities and/or law enforcement authorities if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws
to entities providing feedback and ranking services.
Personal data may also be shared with third party service providers (whether within or outside the HKSAR) who will process it on behalf of McCabe for the purposes above.
In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
We will not keep your personal data for any purpose(s) for longer than is necessary and we will only retain the relevant personal data that is necessary in relation to the purpose. We are also required to retain certain information by law or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
In the case of any contact you may have with our complaints team, we will retain those details for as long as is necessary to resolve your query and for up to 6 months after the query is closed.
We may retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any disposal to take place.
The personal data that we collect from you may be stored on a mix of McCabe and various cloud provider platforms and may be transferred and stored both within and outside the HKSAR. It may also be processed by staff operating within or outside the HKSAR who work for us, or for one of our suppliers.
Where such transfers occur, we ensure the confidentiality and protection of all data is preserved through compliance with legal requirements and the current local data protection legislation. Data encryption, integrity and confidentiality are enforced by following best practice. We also ensure that cryptographic controls are implemented following industry best practice, through the use of VPN tunnels, TLS and by conducting regular testing.
You have the right to request access, with some exceptions, to the personal data that we hold about you, update or correct your details, opt out of receiving other information from us or request that your personal details are deleted from our systems at any time by e-mailing privacy@mccabe.com.hk. We will treat all such requests in accordance with applicable local law and where it is practical and commercially feasible. We may charge a fee for your request to access your information, if permitted by applicable law.
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data. If you withdraw your consent, it is no longer necessary for us to use your personal data, you object to the use of your personal data and we don't have a good reason to continue to use it, or we haven't handled your personal data in accordance with our obligations.
If you have any queries please email us at privacy@mccabe.com.hk.or write to us at the following address:
Compliance
McCabe International Limited
16/F, Wing On Centre,
111 Connaught Road Central,
Hong Kong
This Personal Information Collection Statement and Privacy Notice may be amended from time to time. You may access and obtain a copy of this Notice at https://www.mccabe.com.hk/en/content.php?wid=148 at any time so that you are always informed of the way we collect, use, store and handle personal data.
This Website (the "Website") and its contents are owned (unless indicated otherwise) by McCabe International Limited, incorporated in the British Virgin Islands with limited liabilities and having a place of business in the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"). Reference to "McCabe", "we", "our", "us" in these terms and conditions and elsewhere in this Website is to the associated McCabe companies, being McCabe International Limited, McCabe Secretarial Services Limited, McCabe International Trustee Limited and other businesses they are connected with which include the acronym “McCabe” in their title.
By using our Website, you are deemed to have accepted the following terms and conditions. If you do not want to be legally bound by these terms and conditions, please do not access or use the Website. We reserve the right to change these terms and conditions at any time and you are advised to review these terms regularly to ensure you are aware of any changes. Your continued use of the Website after such changes are posted will be deemed agreement on your part to these terms and conditions as amended.
2.1 Copyright and all intellectual property rights in the content of the Website are vested in McCabe International Limited and reserved, unless indicated otherwise. The content of the Website belongs to McCabe International Limited, unless indicated otherwise. You may use the content of the Website subject to the following conditions: (a) it is used for information purposes only; (b) it is used only for your own personal, non-commercial use; and (c) any copies or downloads of any content from the Website must include a notice that copyright in the relevant material is owned by McCabe International Limited.
2.2 Except as expressly provided above, nothing contained on this Website should be construed as conferring any licence or right to use any trademark or copyright of McCabe or any third party.
3.1 You may submit comments to McCabe, including without limitation for publication on our Website.
3.2 Any comments submitted in connection with our Website are submitted on the basis that we will review and may edit such comments prior to publication on the Website, and that not all submissions will be published. Publication is entirely at the discretion of McCabe. We accept no responsibility or liability in relation to the content of any material posted or published on this Website by third parties or in relation to contributions by third parties which we publish on the Website. You are entirely liable for all activities conducted by you or by others authorised by you or otherwise on your behalf.
3.3 If and to the extent that you submit any personal data (such as your name and email address) to McCabe through the Website, McCabe confirms that it will only use any such personal data for the purposes for which you have provided it and in accordance with our "Website Privacy Statement" (which can be found here: https://www.mccabe.com.hk/en/content.php?wid=148).
3.4 Any communications and material that you transmit or post or submit via this Website will be deemed non-confidential and non-proprietary and we reserve the right to use the content of such communications for any purpose whatsoever. In relation to such contributions you grant us a perpetual, royalty-free, non- exclusive, sub-licensable right and license to use, reproduce, modify, adapt, edit, publish and exercise all copyright and publicity rights with respect to such work world-wide and/or to incorporate it in other works in any media now known or later developed for the full term of any rights that may exist in such content, consistent with the privacy restrictions set forth in the Website Privacy Statement. If you do not wish to grant such rights to McCabe please do not submit your contribution to this Website. By submitting your contribution to this Website, you also:
3.5 You must not intentionally violate any laws, rules or regulations.
3.6 No user must post nor recommend any other Website nor refer to specific URLs (website addresses) where those linked websites would infringe any of the above provisions. No user must post any advertisement on the Website.
3.7 In using this Website, you agree not to impersonate another person or use a false name or a name you are unauthorised to use or create a false email address or try to mislead others as to the identity or origin of any communication.
3.8 You must not corrupt the site, flood the site with information so as to cause the site not to function or use anything which may affect the function of the site for example viruses, worms, logic bombs or similar. You must not interfere or tamper with, remove, delete or otherwise alter in any way, any information which is included on the Website.
3.9 McCabe reserves the right to fail any messages and/or remove any material whatsoever submitted to the Website for any reason. McCabe will not notify the contributor of the material of such failure or removal.
3.10 McCabe reserves the right to take any action against any account or user, at any time, for any reason. We may at our discretion terminate your access to the Website or to the registration areas of the Website, or prevent you from submitting comments via the Website immediately and without giving you advance notice. If you engage in behaviour which breaches these terms and conditions, and we consider such behaviour to be serious and/or repeated, we may use whatever information is available to us to prevent further breaches. If your access to the Website or to registration areas of the Website is terminated, you may not open another account with us or register again and we reserve the right to terminate any such account or cancel any such registration.
3.11 Should you have any complaint regarding any material published on the Website, you can notify us of the nature and details of your complaint by emailing privacy@mccabe.com.hk.
When you register, you are registering as a personal user of the Website and you must use your own identity. You are obliged to provide accurate and complete registration information. Registration is for a single user only. Your username and password are personal to you and may not be used by anyone else to gain access to areas restricted to registered users.
5.1 This information on the Website has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The information cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact McCabe International Limited at privacy@mccabe.com.hk to discuss these matters in the context of your particular circumstances. McCabe, its directors, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information on the Website or for any decision based on it.
5.2 The content of this Website is intended to provide general guidance on matters of interest and about the services provided by McCabe. The content of this Website does not constitute, nor should it be relied upon as, professional advice. Please contact McCabe International Limited for advice on any particular area of interest.
5.3 In preparing and maintaining this Website every effort has been made to ensure the content is up to date and accurate. However, law and regulations change continually and unintentional errors can occur and the information may be neither up to date nor accurate. McCabe makes no representation or warranty (including liability towards third parties), express or implied, as to the accuracy, reliability or completeness of the information published on this Website.
5.4 We cannot guarantee that the Website is free from viruses or malicious codes. You agree that it is your responsibility to satisfy yourself that your own information technology/equipment used to access the Website is protected against such viruses and/or codes.
5.5 Except for death or personal injury caused by negligent acts or omissions, McCabe accepts no liability for any loss or damage whatsoever (including but not limited to any indirect, consequential, special, exemplary or similar damages) arising as a result of any decision or action taken or refrained from as a result of information contained on the Website or other websites to which it may be linked, or as a result of your use or misuse of the Website.
5.6 Without prejudice to the generality of clause 3.4.4, you agree to indemnify, defend and hold harmless McCabe against any claim, liability, cost, damage, or loss we may incur (including without limitation legal fees) as a result of any violation by you of your obligations under these terms and conditions.
This Website contains links to websites maintained by parties other than McCabe. These links are provided simply to increase the information available to you and we accept no responsibility or liability in respect of the accuracy, timeliness, suitability or lawfulness of the information contained on third party Websites. The inclusion of a link to a third party website does not constitute an endorsement or an indication of a joint venture, partnership or other legal arrangement not expressly stated between us and that third party.
Please refer to the Website Privacy Statement (which can be found here: https://www.mccabe.com.hk/en/content.php?wid=148 ) if you require information in regards to McCabe's policies governing the collection and use of your personal information.
If any of these terms are determined to be illegal, invalid or otherwise unenforceable by reason of the laws of any state or country in which these terms are intended to be effective, then to the extent and within the jurisdiction in which that term is illegal, it shall be severed and deleted from these terms and the remaining terms shall survive, remain in full force and effect and continue to be binding and enforceable.
These terms and conditions shall be governed by and construed in accordance with the laws of Hong Kong. As this Website can be visited from locations around the world with different laws from those of Hong Kong, when you access the Website you agree that the laws of Hong Kong will apply to all matters relating to your use of the Website. You and we also agree to submit to the exclusive jurisdiction of the Hong Kong courts with respect to such matters. Notwithstanding this, we reserve the right to bring enforcement proceedings in any court or courts including, if appropriate, in the courts of your country of residence.
This privacy statement (“Privacy Statement”) contains the information gathering and use policies adopted by "McCabe"1 in connection with this https://www.mccabe.com.hk website (or the “Website”), as our commitment to maintaining the privacy of personal information collected in accordance with Hong Kong's Personal Data (Privacy) Ordinance and other applicable laws.
This Privacy Statement applies only to the https://www.mccabe.com.hk Website which is provided by McCabe (also referred to below as “we”, “us” or “our”).
By using https://www.mccabe.com.hk and submitting any personal information to us, you agree to the use by us of your personal information in accordance with the terms of this Privacy Statement. If you have any questions about this Privacy Statement, please email us at privacy@mccabe.com.hk.
By providing any personal information, you fully understand and unambiguously consent to the transfer of such personal information to, and the collection and processing of such personal information provided, to the extent permitted in this Privacy Statement.
Please note that the other country or specific websites contained within https://www.mccabe.com.hk are provided by related entities managing them and are not the responsibility of McCabe. Such websites, as well as other websites that may be linked to this Website, are not governed by this Privacy Statement. We encourage visitors to review each of these other Website's privacy statements before disclosing any personal information.
We do not require registration for access to https://www.mccabe.com.hk, but if you participate in any of the activities or services offered by https://www.mccabe.com.hk, we will collect the personal information that we need in order to provide you with those services, such as (but not limited to) your name, job title, email address, employer's name, telephone number and IP (Internet Protocol) address (see further details regarding IP addresses below).
We do not collect sensitive personal information from you from https://www.mccabe.com.hk, except where legally required as part of a recruitment process. Sensitive information includes data relating to: race or ethnic origin; political opinions; trade union membership; religious or other similar beliefs; physical or mental health; sexual orientation or criminal record. Where you provide sensitive personal information to us voluntarily we will assume that we have your explicit consent to use that information in connection with the purpose for which it has been provided.
When you visit this Website, we may collect technical information such as your IP address, details of the pages you visit on https://www.mccabe.com.hk, other pages you visit on the Web, and which browser you used to view https://www.mccabe.com.hk.
https://www.mccabe.com.hk collects standard internet log and technical data to measure and improve the effectiveness of this Website, to help diagnose problems with our server, to administer this Website, to see where web site traffic is coming from and to identify our users. We may also collect other information via https://www.mccabe.com.hk, such as web site usage activity and preferences, also known as demographic or profile data. In connection with this we may use "cookies" to collect this information. For more information see our Cookies Policy here.
We collect personal information from you in the following circumstances:
when you subscribe to any of our publications or newsletters
when you register to attend an event
when you enter a discussion forum
when you contact us to request further information
when you submit an online job application
when you access this website
We collect the minimum amount of information to enable us to deal with your request. We will indicate where the provision of information is voluntary or compulsory. We would normally only request additional information to enable us to provide the most appropriate response to your request.
The personal data provided by you will only be used for the specific purpose or purposes for which it was provided or for a directly related purpose, as well as to manage https://www.mccabe.com.hk and the services that we offer to you via https://www.mccabe.com.hk (as described in this Privacy Statement). Where we have obtained your consent, we may send you communications from time to time, for example to advise you of updates or upcoming events which may be of interest to you. We will not use your personal data to carry out or facilitate direct marketing activities without your prior consent. When requesting material or asking someone to contact you, there will be the option to receive other information that may be of interest.
McCabe assumes responsibility for keeping an accurate record of personal data once you have submitted the information. However, McCabe does not assume responsibility for confirming the ongoing accuracy of your personal information.
If you believe that any of your personal data that we retain is out-of-date or inaccurate, you can request correction of the data by emailing us at privacy@mccabe.com.hk. Where practically possible, appropriate corrections will be made.
You have the right to request access to the personal information that you have submitted through https://www.mccabe.com.hk, update or correct your details, opt out of receiving other information from McCabe or request that your personal details are deleted from our systems at any time by e-mailing privacy@mccabe.com.hk. We will treat all such requests in accordance with applicable local law.
If you would like to opt not to receive promotional or marketing e-mail from us in the future, you may let us know by sending us an e-mail to privacy@mccabe.com.hk stating the e-mail address you wish to be removed from our mailing list. However, your option not to receive promotional and marketing e-mail shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your existing relationship with us.
Your personal data will not be disclosed to a third party except when required by law or regulation, where you have provided your consent or where it is necessary in order for us to deal with your enquiry or to otherwise operate this Website or our business activities.
From time to time, we may disclose personal information in response to a court order, subpoena, government investigation, or as otherwise required or permitted by law.
We do not provide information to third parties for their own marketing purposes and we do not undertake mailings for third parties.
We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganisation or liquidation of our company (a "Reorganisation Event"), transfer, sell or assign your personal information to third parties involved in the Reorganisation Event.
We only keep your Information for the period required for fulfilling your request and will delete it in accordance with our data retention policies.
If you wish to request the deletion of your personal data submitted through our website, please email us at privacy@mccabe.com.hk.
We have implemented generally accepted standards of technology and operational security to protect your personal data from loss, misuse, alteration or destruction. We will keep your personal data confidential and only authorised personnel have access to the personal data.
You acknowledge that in order to provide services to you via https://www.mccabe.com.hk we may need to transfer your personal information to countries that may not provide a level of protection of personal information that may be regarded as equivalent to that afforded under Hong Kong's Personal Data (Privacy) Ordinance. Whenever your personal information is transferred internationally, we will take appropriate steps to ensure its security and confidentiality in accordance with applicable data protection law.
We may modify or update this Privacy Statement from time to time. You will be able to see when we last updated the Privacy Statement because we will include a revision date. Changes and additions to this Privacy Statement are effective from the date on which they are posted. Please review this Privacy Statement from time to time to check whether we have made any changes to the way in which we use your personal information.
If you have any questions about this Privacy Statement you can contact us via email at privacy@mccabe.com.hk.
This Website is intended to provide general information on McCabe1 and the professional services and solutions provided by McCabe.
We gather information from users of this Website automatically and when you decide to provide us with information, for example, when you complete a form on https://www.mccabe.com.hk. This information is treated with confidence, and is only used by McCabe as per the terms of the Privacy Statement (https://www.mccabe.com.hk/en/content.php?wid=148).
We may use "cookies" to keep, and sometimes track, information about you.
Cookies are small text files which are downloaded to your computer or mobile device when you visit a web site or application. Your web browser (such as Internet Explorer, Mozilla Firefox or Google Chrome) then sends these cookies back to the web site or application on each subsequent visit so that they can recognise you and remember things like personalised details or user preferences. Cookies do not damage your system. You can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent.
To improve your experience and to make our service to you better we use cookies for the purposes of system administration and analytics of our web site. This gives us information about the number of visitors to different parts of our Website.
McCabe does not share this data with third parties. Our cookies do not store sensitive information such as your name or address, they simply just enable us to see behaviour on the Website to help us improve your experience. However, if you’d prefer to restrict, block or delete cookies from https://www.mccabe.com.hk, or any other web site, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.
There are various ways that you can control and manage your cookies which are discussed in more detail below. Please remember that any settings you change will not just affect https://www.mccabe.com.hk cookies. These changes will apply to all web sites that you visit (unless you choose to block cookies from particular web sites).
Managing cookies in my browser
Most modern browsers may allow you to:
See what cookies you have and delete them on an individual basis
Block third party cookies
Block cookies from particular web sites
Block all cookies from being set
Delete all cookies when you close your browser
You should be aware that any preferences will be lost if you delete cookies. This includes where you have opted out from cookies, as this requires an opt-out cookie to be set. Also, if you block cookies completely many web sites will not work properly and some functionality on these web sites will not work at all.
Managing analytics cookies
It is possible to opt out of having your anonymised browsing activity within web sites recorded by analytics cookies. https://www.mccabe.com.hk uses Google Analytics and you can opt out of their cookies by visiting the Google Analytics opt-out page. Please note that this will take you to Google Analytics' web site and generate a ‘no thanks’ cookie, which will stop any further cookies being set by those third parties.
1 "McCabe" is the collective name used to refer to the following legal entities within the Hong Kong business of McCabe: McCabe International Limited, McCabe Secretarial Services Limited, McCabe International Trustee Limited and other businesses they are connected with which include the acronym “McCabe” in their title.
Last modified: 30 June 2024
McCabe International Limited (incorporated in the BVI with limited liability)
McCabe Secretarial Services Limited
16/F, Wing On Centre
111 Connaught Road Central
Hong Kong
Email: info@mccabe.com.hk
Tel: +852 2541 5041
Fax: +852 2815 0002
