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  1. 私隱政策
  2. 私隱政策
  3. 私隱政策

Privacy and Data Protection Policy

  1. Introduction

    1. Osome Limited ("OSOME" or "we" or "our" or "us") acts under the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR. We recognize the importance of the personal data you have provided to us and believe that it is our responsibility to properly manage, protect and process your personal data. Please read this policy to understand what personal data is collected or processed by us, and for what purposes it is used.

    2. Personal data is defined in the Personal Data (Privacy) Ordinance as "personal data” means any data—

      • relating directly or indirectly to a living individual;
      • from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
      • in a form in which access to or processing of the data is practicable;
    3. The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process your personal data. Any changes to this Privacy Policy are effective after posting to this website. We recommend you to check this page from time to time to be aware.

    4. By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and consent to the collection, use, processing and disclosure of your personal data as described in this policy.

    5. Your Rights. Osome does not claim ownership of the information you submit via the Osome Application or through other means of data collection. You have the necessary rights to such information that you submit on the Osome Application.

    6. Osome’s Rights. We own all copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights associated with our Osome Application. You may not use our copyrights, trademarks, domains, logos, trade dress, patents, and other intellectual property rights unless you have our express permission and in accordance with our Terms and Conditions.

  2. Collection of Personal Data

    1. Automatically Collected Information

      • Usage And Log Information. We collect information about your activity on our Osome Application, such as service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Osome Application, how you interact with our staff and authorized people in our Osome Application, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Osome Application, your profile photo, whether you are online and when you last used the Osome Application.

      • Device And Connection Information. We collect device and connection-specific information when you install, access, or use our Osome Application. This includes information such as the hardware model, operating system information, the app version, browser information, language and time zone, IP, device operations information, and identifiers, for example, the device identifier.

      • Cookies. Our website and Osome Application are set up to automatically collect anonymous information about visitors to help us understand our website visitors and their traffic patterns. This information is used for statistical purposes and to improve our service. Below is a list of cookies that we use on our websites and services. The types of cookies we use are always changing. If you think we’ve missed a cookie, please let us know.

      Cookie name Purpose
      Facebook Ads Tells us how our ads on Facebook are working and what kinds of users are interested in Osome.
      Google Ads A cookie that shows us how effective our Osome ad campaigns are by tracking how many users click through to our website from a particular ad, and the demographic of those users.
      Google Analytics Allows us to see how many users are on the Osome website, which pages they are visiting and track how many visitors joined Osome.
      Google Optimise Part of our testing platform to help us understand whether any changes we've made to Osome website pages have been well received.
      Google Tag Manager This cookie controls other cookies on the website.
      HubSpot HubSpot sets a number of tracking cookies when a visitor lands on our website to understand their behavior better. To learn more about the different cookies we're using, check out HubSpot Cookie Policy. Types of cookies you can see here.
      Intercom Intercom is a tool that allows users to chat to Support through our website. It uses a script with a visitor cookie associated with it.
      Leadinfo We use the lead generation service provided by Leadinfo B.V., Rotterdam, The Netherlands, which recognizes visits of companies to our website based on IP-addresses and shows us related publicly available information, such as company names or addresses. In addition, Leadinfo places two first-party cookies for providing transparency on how our visitors use our website and the tool processes domains from provided form inputs (e.g. “leadinfo.com”) to correlate IP addresses with companies and to enhance its services. For additional information, please visit wwww.leadinfo.com. On this page: www.leadinfo.com/en/opt-out you have an opt-out option. In the event of an opt-out, your data will no longer be used by Leadinfo”.
    2. Information you Provide.

      • Your Personal Data. Examples of such Personal Data you may provide to us include your name, age, birth date, mobile number(s), telephone number(s), mailing or residential address, email address, passport or other identification number, and any other information relating to individuals that you have provided to us during our interaction with you.

      • Your Messages. We retain the contents of your messages delivered to the Osome Application during the course of providing Osome services to you. Once your messages (including chats, photos, videos, voice messages, files, and shared location information) are delivered, they are kept and are accessible to Osome staff and other government authorities. Your messages are stored on our server. In order to improve our Osome Application we store information relating to which country your device indicates you are located in, as well as the device model and operating system you are using. Additionally, your "last login" time and read receipts are visible to Osome staff.

      • We collect your Personal Data in the following ways:

        1. when you contact our chatbot and/or staff, for example, via chats, emails, telephone/video calls, letters, face-to-face meetings, social media platforms, and our website;
        2. when you submit forms on our Osome Application;
        3. when you enter information into documents we send to you via our Osome Application;
        4. when you request to be included in our mailing list;
        5. when you respond to Osome advertisements, promotions, initiatives;
        6. when we receive references from affiliates and third parties, if you have been referred by them;
        7. when you submit your Personal Data to us for any reason.
      • If you provide us with Personal Data relating to a third party (e.g. information relating to your spouse, children, parents, business partners and/or employees), by submitting such information you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

  3. Purposes for Collection, Use and Disclosure of Your Personal Data

    1. Osome collects, uses and discloses your Personal Data for the following purposes:

      • conducting due diligence exercises;
      • processing payments;
      • replying to your questions, feedback and requests;
      • managing Osome’s business operations;
      • complying with internal policies and procedures;
      • providing updates and other communications on the development of Osome’s business process and applications;
      • assessing and processing applications or requests made by you for Osome products and services offered including, but not limited to, corporate secretarial services, incorporation services, tax and accounting services and payroll services;
      • managing commercial risks and risk management;
      • managing the safety and security of our affiliates and employees;
      • managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance);
      • in connection with any claims, actions or legal proceedings (including but not limited to drafting and reviewing documents, transaction documentation);
      • conducting investigations relating to disputes, billing or fraud;
      • managing and preparing reports on non-compliance cases;
      • meeting or complying with any applicable laws, regulations, codes of practice or guidelines issued by legal or regulatory bodies;
      • financial reporting and audit;
      • project management;
      • requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
    2. If you have indicated that you consent to receiving marketing or promotional information via your telephone number, emails or other ways of communication, Osome may contact you from time to time with information regarding our products and services.

    3. As Osome relies on your Personal Data to provide products and services to you, you should ensure that all Personal Data submitted to us is complete, accurate, true and correct.

    4. We will seek your consent and notify you in advance when we collect information for purposes other than listed above or for purposes unrelated to the original purpose when collecting the data, unless with the data subject’s express and voluntary consent. You can withdraw your consent previously given by written notice.

  4. Accuracy and Duration of Retention

    1. Osome will retain your Personal Data for only as long as the purposes for which such data is collected or used continues, or where necessary for legal or business purposes.

    2. Osome will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for those purposes.

  5. Data Security

    1. Osome will take all practicable steps to protect the Personal Data against unauthorised or accidental access, processing, erasure, loss or use.

    2. Keeping Your Account Secure. You are responsible for keeping your device and your Osome account safe and secure, and you must notify us promptly of any unauthorized use or security breach of your account or our Osome Application.

    3. Third-party authorization. Our Osome application may allow you to invite new users into your chats and company profile to have access, use, or interact with our staff. Users will also be able to view some of your personal information, business data, content, and other products and services. For example, you may invite a new director to your company profile. Please note that when you invite new users into your company profile, we will need to conduct our diligence exercise as per applicable law. Please note Osome will not bear any responsibility if your Personal Data is used by unauthorized people that you invited into the Osome Application.

  6. Exemptions

    Personal Data transferred or disclosed by Osome for the purpose of a due diligence exercise conducted in connection with a proposed business transaction is exempted from the provisions (DDP3) of data protection principle (CAP 486 PERSONAL DATA (PRIVACY) ORDINANCE Section 63B Due diligence exercise).

  7. Contact Us

    1. To contact us regarding:

      • your Personal Data or our Privacy Policy,
      • making a subject access/correction request,
      • requesting to withdraw your consent to any use of your Personal Data as set out in this Policy; or
      • requesting to obtain access and make corrections to your Personal Data records,
        please use the following email address (for the attention of the Data Protection Officer): dpo@osome.com.
    2. If you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, Osome may not be able to continue to provide our services or provide access to Osome Application. Such withdrawal may also result in the termination of our services.


This privacy policy was last updated on 08 February 2022.

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