1. General

We, at Gall, are committed to protecting the privacy and security of personal information provided to us in accordance with the Personal Data (Privacy) Ordinance Cap. 486 (”PDPO”). This includes personal information provided by visitors to Gall’s website and to all the associated pages (together, the “Website”) under the direct control of Gall. Our Website uses ‘cookies’ and ‘cookies’ may also be used at certain third-party websites accessible through links on the Website.

Information provided to us constitutes personal data if it relates directly or indirectly to you and from which your identity can be ascertained.

The purpose of this privacy policy (“Policy”) is to elucidate upon the practices adopted by Gall to collect, use and store personal data as well as your rights in relation to such data.

2. Collection of your personal data

Your personal data shall be collected for lawful purposes only. Your personal data will be used for specific purposes stipulated in Gall’s Personal Information Collection Statement. You are entitled to withdraw your consent for use of your personal data by giving us notice in writing.

3. Direct marketing

Our use of your personal data for direct marketing (which includes business promotion) is subject to your consent. We will not sell or rent your personal data to any third party.  If you wish to unsubscribe from our mailing list, please send an email to this effect  to bonnieclarke@gallhk.com. For more information please see Gall’s Personal Information Collection Statement.

4. Retention of your personal data

We will take all practicable steps to ensure that your  personal data is retained only for as long as is reasonably necessary for the  specific purpose(s) which it was obtained and in accordance with law. After that time, unless prohibited by law or some other limitation in public interest, your data will be deleted.

5. Disclosure and security

We are committed to undertaking practicable measures, both technical and organisational, to hold your personal data and to prevent unauthorised use or access, processing, loss, or disclosure. Your personal data shall be used and disclosed only in accordance with Gall’s Personal Information Collection Statement.

6. Your right of access to and to correct personal data

You are entitled, in accordance with the PDPO, to have access to and correction of your personal data. Requests for access to or to correct personal data should be addressed to The Head of Marketing & Communications, Gall at bonnieclarke@gallhk.com. The PDPO, entitles us to charge a reasonable fee for processing any data access or correction requests, and in appropriate cases refuse such requests with reasons. 

7. Personal Data (Privacy) Ordinance

You may wish to visit the official website of the Office of the Privacy Commission (https://www.pcpd.org.hk/) and Hong Kong e-Legislation (https://www.elegislation.gov.hk/) for more information about the PDPO.

Personal Information Collection Statement

The Personal Information Collection Statement (“PICS”) sets out the purposes for which your personal data will be used after collection. You may be required to provide personal information to Gall when you use Gall’s services in the capacity of a client (or potential client), an online user of Gall’s Website and other online services, as a job applicant, an employee or in any other capacity. We use cookies on our website.

1. SCOPE OF APPLICATION
   1. The PICS applies to information we collect about you directly or indirectly whether through you or third parties. This may include the following situations :-
      1. When you visit our website and other associated pages on our website;
      2. When you subscribe to our mailing lists or use our other online services or attend events hosted by us;
      3. When you apply to Gall for positions for employment or internships;
      4. When you make enquires in relation to seeking our services;
      5. When you are a potential client, a client or associated with our client(s) in the capacity of director, other officer, employee, staff member, authorised representative or other agents;
      6. In the course of providing legal services to you;
      7. In the course of recruitment and business intake procedures;
      8. In course of managing our business activities;
      9. As and when required by law.

2. INFORMATION COLLECTION
   1. We may collect personal information about you directly from you and/or from other sources including our clients (and their authorised representatives) and/or their counterparties. Information that we collect may include the following:
      1. Identity related information:
         We may collect information regarding your name (including former names), contact details such as email address, contact number(s), postal and residential address, business address, occupation, nationality, gender, special information such as marital status, race, ethnicity, health related information, and documents in order to ascertain such information.
      2. Business details:
         We may collect information regarding your business interests, purpose of your business transactions, work permits, information regarding your business associates (such as affiliated companies, partnerships, directors, shareholders, authorised representatives)
      3. Recruitment related information:
         We may collect information regarding your current and former employment, educational and professional qualification background, business interests, work permits, visa, employment references, information obtained from recruitment agencies and your background check for criminal records (if any).
      4. Billing details:
         We may collect information such as bank account details, billing address, information required for processing payments, source of funds etc.
      5. Information for compliance:
         We may collect all such information as required by law from time to time particularly information in relation to your identity and all information required for fulfilling obligations under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
      6. Publicly available information:
         We may collect information about you that is publicly available including but not limited to information from third parties such as government agencies, regulatory bodies, information service providers, credit reporting agencies and social media platforms.

3. USE OF YOUR PERSONAL INFORMATION
   1. We may use your personal information for the following purposes:
      1. to fulfil our legal, regulatory and risk management obligations, including establishing, exercising, or defending legal rights;
      2. when it is necessary for our legitimate interests or a third party’s legitimate interests subject to your fundamental rights. Legitimate interests include using your information:
         1. for carrying out our business intake procedures;
         2. for providing legal services or advice to you;
         3. for promoting our business;
         4. for the functioning of our business and its operations;
         5. for reasons required by applicable law; and
         6. for development and improvement of the services we provide.
      3. to manage and administer our relationship with you and/or your representatives;
      4. if you have already made the information public;
      5. if you have given your consent where necessary; and/or
      6. Your personal information is necessary for the abovementioned purposes and we may not be able to carry out any or all of the purposes unless we receive and use your personal information.
   2. Your name and contact details may be used for promoting our business. You have the right to ask us, at any time, not to use your personal data for marketing purposes. You can exercise such right by sending an email stating this to bonnieclarke@gallhk.com.

4. SCOPE OF APPLICATION
   1. We hold your personal information on so long as necessary and in accordance with law.
   2. We take appropriate technical and organisational measures to hold your personal data and to prevent unauthorised access, modification or disclosure. However, your data may be disclosed to and used by the following third parties:-
      1. government agencies, courts, tribunals, regulatory authorities and law enforcement agencies, as required and permitted by the applicable law and regulations;
      2. our professional advisors, auditors, insurers, banks, and information technology service providers;
      3. third parties to whom we outsource certain services, including, but not limited to, translation, printing, transcription, document review, parties involved in hosting or organising events, debt collection agencies;
      4. third parties who are engaged in connection to the services we provide to you, including, but not limited to, barristers, experts, investigation service providers; and
      5. Our business partners;
   3. In accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) and guidelines issued pursuant thereto, either you or any relevant person on your behalf may:
      1. make a request to ascertain whether Gall holds personal data about you and may request access to such data;
      2. request Gall to correct any data relating to you which is inaccurate;
      3. request Gall to cease using his/her personal data for its marketing purposes.
   4. In accordance with the terms of the PDPO, Gall has the right to charge a reasonable fee for the processing of any data access request.
   5. Gall reserves the right to reasonably refuse to comply with data access request where permitted or required by law.
   6. If you need further information or have any questions or requests regarding Gall’s privacy policy or PICS, please write to:
      Ms. Bonnie Clarke
      Head of Marketing & Communications
      Gall
      3/F Dina House
      Ruttonjee Centre
      11 Duddell Street
      Central
      Hong Kong
      Email: bonnieclarke@gallhk.com