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Personal Data(Privacy) Policy Statement (“Privacy Policy”)

John HuMigration Consulting Limited(“Company”) pledges to meet fully with the requirementsof the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong.In doing so, the Company will ensure compliance by its officers and staff tothe strictest standards of security and confidentiality in respect of allpersonal information and data submitted by users via 88db.com and itssub-domains (collectively referred to as the “Sites”) and the Company will notrelease such information to anyone without the prior consent of the relevantuser(s) of the Sites (whether registered or not) (“User(s)”) except to theauthorized persons listed under the section entitled “Disclosure or Transfer ofData”.

Users are strongly recommended to readthis privacy policy (“Privacy Policy”) carefully to have an understanding ofthe Company’s policy and practices with regard to the treatment of personalinformation and data provided by the Users on the Sites. This Privacy Policy isapplicable to both registered and non-registered Users.

If Users have questions or concernsregarding this Privacy Policy, they should first email to jhmigration@gmail.com.

 

1.Purpose of Collection of Personal Data

In the course of using the Sites, Usersmay disclose or be asked to provide personal information and/or data. In orderto have the benefit of and enjoy various services offered by the Sites, it maybe necessary for Users to provide the Company with their personal informationand/or data. Although Users are not obliged to provide the information and/ordata as requested on the Sites, the Company will not be able to render certainservices on the Sites in the event that Users fail to do so.

The Company’s purposes for collection ofinformation and data on the Sites include but not limited to the following:

(a) for the daily operation of theservices provided to Users;

(b) to identify Users who have posted, messages, views or comments or suchother information (collectively “Information”) on the Sites;

(c) to identify Users who have viewedthe Information posted on the Sites;

(d) to provide Users with marketing andpromotional materials for their enjoyment of benefits as members of the Sites(for further details, please refer to section headed “Subscription ofNewsletter/Promotional Materials/Marketing Materials” below);

(e) to identify Users who have enjoyedtheir benefits as members of the Sites by receiving and using marketing andpromotional materials;

(f) to allow members of the Sites to enjoytheir benefits as members by enrolling for special events and promotions hostedby the Company and/or its affiliates;

(g) to design and provide products,services and privileges to Users in relation to the above purposes includingbut not limited to discounts, product trial, photo printing offers and filmtickets; and

(h) to facilitate the Company and/or itsaffiliates to use the Users’ personal data for purposes relating to theprovision of services offered by the Company and marketing services and/orspecial events of the Company and/or its affiliates.

If the User is under the age of 13, theCompany would strongly recommend him/her to seek prior consent from a personwith parental responsibility for him/her, e.g. parent or guardian, who maycontact the responsible personnel of the Company at jhmigration@gmail.com for registering the User as member ofthe Sites.

2.Collection of Personal Data

The Company may collect personalinformation and/or data about a User such as his/her name, log-in ID andpassword, address, email address, phone number, age, sex, date of birth,country of residence, nationality, education level and work experience thatis/are not otherwise publicly available. Occasionally, the Company may alsocollect additional personal information and/or data from a User in connectionwith contests, surveys, or special offers.

Only duly authorized staff of theCompany will be permitted to access the Users’ personal information and data,and the Company shall not release such personal information and data to anythird parties save and except for the circumstances listed out under thesection entitled “Disclosure or Transfer of Data”.

3.Disclosure or Transfer of Data

The Company agrees to take allpracticable steps to keep all personal information and data of Usersconfidential and/or undisclosed, subject to the following.

Generally speaking, the Company willonly disclose and/or transfer Users’ personal information and/or data to theCompany’s personnel and staff for the purpose of providing services to Users.However, the Company may disclose and/or transfer such information and/or datato third parties under the following circumstances:

(a) where the information and/or data isdisclosed and/or transferred to any third party suppliers or external serviceproviders who have been duly authorized by the Company to use such informationand/or data and who will facilitate the services on the Sites, under a duty ofconfidentiality;

(b) where the information and/or data isdisclosed and/or transferred to any agents, affiliates or associates of theCompany who have been duly authorized by the Company to use such informationand/or data;

(c) where the Company needs to protectand defend its rights and property;

(d) where the Company considersnecessary to do so in order to comply with the applicable laws and regulations,including without limitation compliance with a judicial proceeding, courtorder, or legal process served on the Sites; and

(e) where the Company deems necessary inorder to maintain and improve the services on the Sites.

4.Subscription of Newsletter/PromotionalMaterials/Marketing Materials

The Company and its affiliates may fromtime to time send to members and Users of the Sites newsletters, promotionalmaterials and marketing materials based on the personal information and datathat they have provided to the Company. The Company may use the Users’ data indirect marketing and the Company requires the Users’ consent (which includes anindication of no objection) for that purpose. In this connection, please notethat:

(a) the name, log-in ID and password,contact details, age, sex, date of birth, country of residence, nationality,education level and work experience of Users held by the Company from time totime may be used by the Company and/or its authorised personnel or staff indirect marketing;

(b) classes of services, products andsubjects of over 50 categories ofspecific services may be marketed including but not limited to the following non-exhaustivelist of classes of services, products and subjects:

              i.       Overseas property managementservices;

             ii.       Financial planning services;

            iii.       Business for sale services;

            iv.       Business Consultation services;

             v.       Accounting & Auditingservices;

(c) The above products, services andsubjects may be provided or (in the case of donations and contributions)solicited by the Company and/or:

              i.       the Company’s affiliates;

             ii.       third party service providers providing the products,services and subjects listed in paragraph (b) above; and

 (d)in addition to marketing the above services, products and subject itself, theCompany also intends to provide the data described in paragraph (b) above toall or any of the persons described in paragraph (c) above for use by them inmarketing those services, products and subjects, and the Company requires theUsers’ written consent (which includes an indication of no objection) for thatpurpose;

(e) the Company may receive money orother property in return for providing the data to the other persons in paragraph(d) above and, when requesting the Users’ written consent as described inparagraph (d) above, the Company will inform the Users if the Company receivesany money or other property in return for providing the data to the otherpersons.

Suitable measures are implemented tomake available to such members the options to “opt-out” of receiving suchmaterials. In this regard, Users may choose to sign up or unsubscribe for suchmaterials by email to jhmigration@gmail.com.

5.Access

Any User is entitled to request accessto or make amendments to his/her own personal information and data kept withthe Company by email to jhmigration@gmail.com.

In the event that a User wishes toaccess or amend his/her personal information and data, the Company may requesthim/her to provide personal details in order to verify and confirm his/heridentity. HKID card number or passport number or business registrationcertificate number cannot be amended unless such data is proved to beinaccurate. The Company is required to respond to a User’s requests within 40days of his/her request and will endeavor to do so wherever possible.

6. Cookies and Log Files

The Company does not collect anypersonally identifiable information from any Users whilst they visit and browsethe Sites, save and except where such information of the Users is expresslyrequested. When Users access the Sites, the Company records their visits onlyand do not collect their personal information or data. The Sites’ serversoftware will also record the domain name, server, address and track the pagesthe Users visit and store such information in “cookies”, and gather and storeinformation like internet protocol (IP) addresses, browser type, referring/exitpages, operating system, date/time stamp, and click stream data in log files. All these aredone without the Users being aware that they are occurring.

The Company does not link theinformation and data automatically collected in the above manner to anypersonally identifiable information. The Company generally uses suchautomatically collected information and data to estimate the audience size ofthe Sites, gauge the popularity of various parts of the Sites, track Users’ movementsand number of entries in the Company’s promotional activities and specialevents, measure Users’ traffic patterns and administer the Sites. Suchautomatically collected information and data will not be disclosed save andexcept in accordance with the section entitled “Disclosure or Transfer ofData”.

7. Links to Other Sites

The Sites may provide links to otherwebsites which are not owned or controlled by the Company. Personal informationand data from Users may be collected on these other websites when Users visitsuch websites and make use of the services provided therein. Where and whenUsers decide to click on any advertisement or hyperlink on the Sites whichgrants Users access to another website, the protection of Users’ personalinformation and data which are deemed to be private and confidential may beexposed in these other websites.

Non-registered Users who gain access tothe Sites via their accounts in online social networking tools (including butnot limited to Facebook) are deemed to have consented to the terms of thisPrivacy Policy, and such Users’ personal data which they have provided to thosenetworking tools may be obtained by the Company and be used by the Company andits authorized persons in and outside of the User’s country for the purpose ofproviding services and marketing materials to the Users. These Users are deemedto have consented to the Company and its authorized personnel’s access and useof their personal data so obtained.

This Privacy Policy is only applicableto the Sites. Users are reminded that this Privacy Policy grants no protectionto Users’ personal information and data that may be exposed on websites otherthan the Sites, and the Company is not responsible for the privacy practices ofsuch other websites. Users are strongly recommended to refer to the privacypolicy of such other websites.

8. Security

The security of Users’ personalinformation and data is important to the Company. The Company will alwaysstrive to ensure that Users’ personal information and data will be protectedagainst unauthorized access. The Company has implemented appropriate electronicand managerial measures in order to safeguard, protect and secure Users’personal information and data.

All personal information and dataprovided by Users are only accessible by the authorized personnel of theCompany or its authorized third parties, and such personnel shall be instructedto observe the terms of this Privacy Policy when accessing such personalinformation and data. Users may rest assured that their personal informationand data will only be kept for as long as is necessary to fulfill the purposefor which it is collected. Registered Users should safeguard his/her uniqueUsername and Password by keeping it secret and confidential and never sharethese details with anyone.

The Company uses third party paymentgateway service providers to facilitate electronic transactions on the Sites.Regarding sensitive information provided by Users, such as credit card numberfor completing any electronic transactions, the web browser and third partypayment gateway communicate such information using secure socket layertechnology (SSL).

The Company follows generally acceptedindustry standards to protect the personal information and data submitted byUsers to the Sites, both during transmission and once the Company receives it.However, no method of transmission over the Internet, or method of electronicstorage, is 100% secure. Therefore, while the Company strives to protect Users’personal information and data against unauthorized access, the Company cannotguarantee its absolute security.

9. Retention of Personal Data

Once the Company has obtained a User’spersonal information and/or data, it will be maintained securely in theCompany’s system. Subject to legal requirements, the personal informationand/or data of Users will be retained by the Company after deactivation of therelevant service until the User requests the Company to erase his/her ownpersonal information and/or data from the Company's database or to terminatehis/her membership of the Sites.

10. Changes in this Privacy Policy

The Company reserves the right toupdate, revise, modify or amend this Privacy Policy in the following manner atany time as the Company deems necessary and Users are strongly recommended toreview this Privacy Policy frequently. If the Company decides to update,revise, modify or amend this Privacy Policy, the Company will post thosechanges to this webpage and/or other places the Company deems appropriate sothat Users would be aware of what information the Company collects, how theCompany uses it, and under what circumstances, if any, the Company disclosesit.

If the Company makes material changes tothis Privacy Policy, the Company will notify Users on this webpage, by email,or by means of a notice on the home page of the Company.

For any query, please email to jhmigration@gmail.com.

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