Last update: May 13, 2020

JEI Hong Kong Limited (“JEI”) is a private company limited by shares with its principal place of business at 401, 4th Floor, Cheuk Nang Centre, No 9 Hillwood Road, Tsim Sha Tsui, Hong Kong Special Administrative Region. It is the owner and operator of hk.jei.com and other websites, mobile applications and other distribution channels JEI designates from time to time (“Site”). This privacy policy (”Privacy Policy”) states how we try to protect the privacy of your personal information that we may obtain from your use of this Site. We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Personal Data (Privacy) Ordinance with respect to the management of personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations. If there is any part of this privacy policy you do not agree with, or if you do not think this Privacy Policy provides you enough protection, you should not visit this Site or use our services. By proceeding and providing your personal information, you are consenting to its collection, use and disclosure according to this Privacy Policy.

1. Information We Collect and How We May Use It

• A. Personal Information – At various locations on the Site, such as areas where you may request information and/or sign up for newsletters, events and promotions, you may provide us personally identifiable information such as name, mailing address, telephone number and email address; and other demographic information such as age, gender, income, education, profession, area code and zip code. The provision of personal information is voluntary. If you give us your personal information, we will collect and retain that personal information to deliver the services you request. If you do not supply the relevant information, we may not be able to deliver the services you request. We will not use your personal information for direct marketing without your voluntary consent.
• B. Non-Personal Information – When you use the Site, we may also collect non-personal information, which we define as information that cannot be used by itself to identify you personally. Non-personal information includes, but is not limited to, technical information such as your IP address, the type of browser you are using, and the websites you visit immediately before and immediately after you visit the Site. Non-personal information also includes, without limitation, other anonymous data involving your use of the Site, such as the Sites you visit and the terms you enter into the search or select functions of the Sites. We or our service providers may collect this information by automated means, using technologies such as cookies, Web server logs, and Web beacons.
• C. Cookies – We use cookies to store information and enhance your visits to the Site. A cookie is a small data file that is sent to your browser from a web server and stored on your computer’s hard drive for record-keeping, administration or to customise your experience. Cookies do not store personal information about you, unless you knowingly provide it. Cookies can store non-personal information, such as what websites, pages, or advertisements your browser has accessed. You generally can refuse and/or delete cookies. See your Internet browser “Help” file for instructions. Please note that some of our Site functionalities utilise cookies and might not work for you if you refuse or delete cookies.
• D. Log File Information – Log file information is automatically reported by your browser each time you make a request to access or visit a web page. When you use this Site, our servers automatically record certain log file information, including the name of the domain and host from which you access the Internet, the Internet Protocol (“IP”) address of the computer you are using, the browser and software you use, your computer operating system, the type and name of your Internet Service Provider, which pages of this Site you visit, the order of those pages, and the amount of time you spend on each page. The information could be used to provide general statistics on this Site and improve our services.
• E. Web Beacons – we also may use “web beacons” (also often called “clear GIFs”, “clear pixels”, “1x1 GIFs”, or “1x1 pixels”) which are tiny graphic image files, embedded in a web page in GIF, jpeg or HTML format, that provide a presence on the web page and send back to its home server information from your browser, such as the IP address, the URL of the page on which the web beacon Is located, the type of browser that is accessing the site and the ID number of any cookies on your computer previously placed by that server. We may use web beacons to collect non-personal information about your use of the Site and the website of selected sponsors and advertisers, and your use of special promotions or content. This information allows us to statistically monitor how many people are using the Site and selected sponsors’ and advertisers’ sites.
• F. Mobile Device Information – we collect information about the mobile device you use to access or use the Site, including the hardware model, operating system and version, unique device identifiers, mobile network information and information about your use of our mobile applications, which may be utilised to provide general statistics on this Site. With your voluntary consent, we may also collect information about the location of your device and access and collect information from certain native applications on your device (such as your device’s camera, photo album and phonebook applications) to facilitate your use of certain features of the Site. We act under rigid guidelines when processing and handling sensitive personal data such as location information. Please refer to Section 5 of this Privacy Policy to learn more about our data security measures. You have the choice to have such personal data held by us erased or not to have the data shared or transferred. Please refer to Section 4 of this Privacy Policy to learn more about your rights to make data access and correction requests.
• G. “Do Not Track” – We currently do not process or comply with any web browser’s “do not track” signal or similar mechanism that indicates a request to disable online tracking of individual users who visit the Site or use our services, unless otherwise stated in a service-specific privacy statement.
• We do not use your personal information or share it with others except as described in this Policy. We will provide specific notice at the time of collection if we are going to use personally identifiable information in ways not set forth in this Privacy Policy. We reserve the right to use, disclose, license, assign or otherwise transfer information which is non- personal information as we find appropriate to evaluate and decide how to customize the content you see on this Site, improve our services, conduct research, and provide anonymous aggregated reporting for analytical or statistical purposes.

2. Disclosure of Personal Information

We engage and may share your information with our affiliated companies, including, but are not limited to, JEI Holdings Corporation, JEI Corporation and JEI e-Academy. These are companies that are fully or partly owned by, or have common ownership or similar kinds of ownership affiliation with JEI. We do not transfer your personal information to third parties or engage other service providers (such as IT contractors and agencies for clearing payments) to handle or process your personal information without your voluntary consent.

3. Retention

We will retain your personal data collected for as long as it is necessary to fulfill the purpose for which it is collected. We take all practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose for which the data is or is to be used.

4. Access and Correction

You have the right to inquire whether we retain your personal information and access the information you provided. You can also request that we update, correct, delete or stop using or transferring your information. For any such request, please write to the address in Section 10 of this Privacy Policy. We will review your request, take appropriate action to comply with the relevant Ordinance, and inform you about the result. We have the right to charge you a reasonable fee for processing your data.

5. Data Security

We take the security and protection of your personal data very seriously. As such, we store your personal data on secure servers and have put in place appropriate security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal of your personal data. We restrict access of personal data to relevant employees on a “need-to-know” basis, provide relevant training to the employees to handle personal data properly, and apply encryption to personal data when necessary.

6. Children Privacy

JEI does not knowingly collect, solicit or maintain information from children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible.

7. Other Websites and Services

JEI is not responsible for the practices employed by any websites or services linked to or from this Site, including the information or content contained within them. When you use a link to go from this Site to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on this Site, are subject to that third party’s own rules and policies.

8. International Users

If you access the Site from outside Hong Kong, your connection may be through and to servers located in your country or Hong Kong. Any personal information you provide may be processed and maintained in Hong Kong on servers and/or other network systems operated by us or for our benefit. Regardless of where you live, you consent to have your personal information transferred, processed and stored in Hong Kong, and allow us to use and collect your personal information in accordance with this Privacy Policy. IF YOU ACCESS THE SITES FROM AND/OR RESIDE OUTSIDE OF HONG KONG, YOUR INFORMATION MAY BE STORED, TRANSMITTED AND SHARED IN ACCORDANCE WITH HONG KONG DATA PRIVACY LAWS WHICH MAY NOT BE EQUIVALENT TO THOSE IN EFFECT IN YOUR COUNTRY. YOU EXPRESSLY AGREE THAT YOU WILL NOT USE THE SITES WITH ANY EXPECTATION OF GREATER PRIVACY RIGHTS THAN THOSE TO WHICH YOU HAVE EXPRESSLY AGREED AS STATED IN THIS PRIVACY POLICY.

9. Changes to Our Privacy Policy

We reserve the right to change this Policy at any time, so please review it frequently. If we change our Policy, we will post those changes to this Policy statement and to other places we deem appropriate so that you aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

10. Contact Us

If you have any questions or concerns regarding our Privacy Policy, please contact us by email at enquiry@jei.com or by letter to the following address.

Franchise Operations Manager
JEI Hong Kong Limited
401, 4th Floor, Cheuk Nang Centre, No. 9 Hillwood Road
Tsim Sha Tsui, Hong Kong Special Administrative Region