Sims Trading Company Limited

Disclaimer

All the information contained in this web site is provided for general information and reference purposes only, and is not intended, nor should be construed, as investment or any other professional advice. It does not constitute an offer to sell any securities nor advocate any investment and must not be relied upon in connection with any investment decision. The Sims Trading Company Limited does not warrant or represent that the general information and the information regarding stock prices provided in this web site is complete and accurate, nor that the information is up to date. The Sims Trading Company Limited assumes no responsibility for the information contained in this web site and disclaims any or all legal liability in respect of such information.

Personal Data & Privacy Statement

General

1.1	This statement provides information on the policies of Sims Trading Company Limited ("SIMS") under the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong ("Ordinance").
1.2	Terms used in this statement shall, unless otherwise specified, be construed in accordance with the Ordinance.

Purpose of collection of personal data

2.1

The provision of any personal data by you or on your behalf to SIMS shall be voluntary and shall be deemed to authorise SIMS and its subsidiaries to collect, retain, update and use your personal data for the purpose of clause 2.2 below

2.2

The personal data provided by you or on your behalf to SIMS from time to time will be used for the following purposes:

(a)	Operating daily for provision of goods, facilities and services to you;
(b)	Providing additional goods, facilities and services to you as they may arise from time to time;
(c)	To fulfill requests submitted by you, whether online, over the phone, through our mobile services, or through other methods, such as gifts redemption;
(d)	Conducting statistics and market research for the purpose of providing products or services to you;
(e)	For marketing, promotional and customer relationship management purposes, such as sending you updates on the latest offers and promotions in connection with SIMS's co-branding / joint promotion business partners and for assessing eligibility for any marketing and/or promotional activities and/or offers from SIMS's co-branding / joint promotion business partners. (please see Section 8 - 'Use of personal data in direct marketing' for details)
(f)	To respond to, handle and process any enquires submitted by you;
(g)	To administer contests and sweepstakes conducted by us or on our behalf, including disclosing the winner of any such contest;
(h)	Updating and verifying your identity and other information in accordance with relevant laws;
(i)	To improve our security, including in relation to the processing of payment by credit card to guard against the risk of fraud, including carrying out matching procedures against databases of known fraudulent transactions (maintained by us or third parties);
(j)	Comparing the personal data provided by you with your other information possessed from time to time by any other members of SIMS for verification purposes;
(k)	Making such disclosures as may be required for any of the above purposes or by law;
(l)	Achieving any other lawful purposes relating to any of the aforesaid purposes;
(m)	Enforcing any legal or other rights of SIMS may have against you;
(n)	To fulfill the above purposes, you may be contacted via email, direct mailing, telephone marketing, SMS or other means that are allowed by local authorities.

2.3

In the event that, in the opinion of SIMS to which you provided personal data, the personal data provided by you is insufficient or such member is not satisfied that such data is true and accurate, such member reserves the right to refuse to withhold process of your application or provision of any service to you unless and until the personal data required by such member is provided.

2.4

For the purposes stipulated in clause 2.2 above, any employee of SIMS or any person retained by SIMS shall be entitled to inspect the personal data provided by you.

Use of personal data

SIMS will ensure the confidentiality of collected personal data but may provide such information to the following parties (including parties within as well as outside the Hong Kong Special Administrative Region ('Hong Kong')) for the purpose of implementing the 'purpose of collection of personal data' mentioned above:

(a)	Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, or other services to SIMS and our customers;
(b)	Any agent authorised by SIMS from time to time to process personal data of SIMS's customers;
(c)	Any other members of SIMS, within as well as outside Hong Kong;
(d)	Auditors, consultants or legal adviser(s) of SIMS, within as well as outside Hong Kong;
(e)	Any other person under a duty of confidentiality to SIMS; and
(f)	Any of the actual or proposed assignees or transferees of SIMS.

Duty of confidentiality

4.1	SIMS shall exercise reasonable endeavours to ensure that the personal data provided by you shall be kept confidential and be placed in secure locations. SIMS shall further exercise reasonable endeavours to ensure the integrity, prudence and competence of the persons who have access to such data.
4.2	In compliance with any law in Hong Kong, SIMS may disclose the personal data provided by you to governmental authorities or other regulatory bodies or persons.

Special provisions for personal data held by SIMS on the internet

5.1

By assessing SIMS through its website ('Site'), you shall be deemed to agree to the terms and conditions in this statement.

5.2

All reasonable efforts are made to ensure that any personal data held by SIMS from time to time through the Site is stored in secure and safe storage.

5.3

SIMS may use 'cookies' on the Site so as to:

(a)	enable tighter security;
(b)	enable you to complete the application process;
(c)	personalize the Site for you; and
(d)	build online profile for you.

5.4

You may disallow "cookies" at any time on your web browser.

Your rights

6.1	In the event that you have objections to any use of the personal data in accordance with clause 2 or any provision or disclosure of such data in accordance with clause 3 above, please inform SIMS to which you provided your personal data in writing. The address of SIMS is:

	8/F DCH Building, 20 Kai Cheung Road, Kowloon Bay, Kowloon

	SIMS shall cease the use and/or provision or disclosure of such data upon confirmation of your request.
6.2	Unless you request SIMS to dispose of all personal data provided by you, you acknowledge that SIMS shall retain all such personal data and may continue to deliver to you marketing information even after cancellation or withdrawal of your application for membership of any of the clubs organized by SIMS and its subsidiaries or your membership in such clubs, expiry of the warranty period of any goods supplied or service provided by the SIMS and its subsidiaries or completion of any sale of goods or provision of services by SIMS and its subsidiaries (as the case may be).

Access and correction request

7.1	You have the right to request access to and correction of your personal data in accordance with the Ordinance.
7.2	In the event that you intend to correct any personal data, please inform the member of SIMS to which you provided your personal data in writing so that such member shall be able to make the amendments accordingly.
7.3	Enquiries concerning the personal data collected, including access and corrections, should be addressed to the address stated in the relevant forms/contracts executed between you and the member of SIMS or any other address from time to time stipulated by SIMS.
7.4	In accordance with the terms of the Ordinance, SIMS has the right to charge a reasonable fee for the processing of any data access request. You agree to pay such fees.

Use of personal data in direct marketing

SIMS intends to use a customer's personal data in direct marketing and may not so use the data unless SIMS has received the customer's consent (which includes an indication of no objection) to such intended use. In this connection, please note that: -

(i)

the name, contact details, products and services portfolio information, transaction pattern and behaviour, consumption preference, financial background and demographic data of the customer held by SIMS and its subsidiaries from time to time may be used by SIMS in direct marketing;

(ii)

the following classes of goods, facilities, services, and other marketing subjects may be marketed by SIMS, namely:

(a)	products and services provided by SIMS and its subsidiaries;
(b)	SIMS group activities, offers, gifts redemption, online shop, SIMS group news & update;
(c)	reward, loyalty or privileges programs and related services and products of SIMS and its subsidiaries;
(d)	services and products offered by DCH Group's subsidiaries or co-branding / joint promotion business partners who provide the following classes of products, facilities or services (whether through direct mailing, email or SMS)¡Gmotor & motor service, traveling, hotel & catering, food & beverage, publications & media, sports, auction, group buying, transportation & logistics, insurance, entertainment, art & culture, agricultural products, telecommunications, electronic & electrical products, health & beauty, medical, personal care, wedding, finance & banking, credit card service, information technology, home furnishing, pets related, household, apparel & accessories, education, social networking, engineering, manufacturing, property/ real estate management, private club, professional service, shopping malls, energy, lubricant & petroleum (and side products), baby & child caring, planning & design, lab & R&D, jewelry & watches, environmental protection;
(e)	donations and contributions for charitable and/or non-profit making purposes;

(iii)

the above goods, facilities, services and marketing subjects may be provided or solicited by SIMS and/or:

(a)	any subsidiary, affiliate or associated company of SIMS;
(b)	any third party goods and/or services provider;
(c)	any third party reward, loyalty, co-branding or privileges programme provider; and
(d)	any charitable organization;

(iv)

in addition to marketing the above goods, facilities, services and other marketing subjects by itself, SIMS also intends to provide the above personal data to all or any of the persons described in sub-paragraph (iii) above for use by them or it in marketing those goods, facilities, services and other marketing subjects, and SIMS may not so provide the data unless SIMS has received the customer's written consent (which includes an indication of no objection) to the intended provision.

If the customer does not wish SIMS to use or provide to any other persons his personal data for use in direct marketing as described above, the customer may exercise his opt-out right by notifying SIMS, in which event SIMS must, without charge to the customer, cease to use or provide to other persons the customer's personal data for use in direct marketing.

The customer may provide his consent to SIMS's using or providing to other person his personal data for use in direct marketing as described above by notifying SIMS's Data Protection Officer, whose contact details are set out below, or through such other channel which the customer may be advised of when providing personal data to SIMS.

9.	Data protection officer of SIMS
	The person to whom requests for access to data or correction of data or for information regarding SIMS's privacy policies and practices and kinds of data held and for any other communications hereinabove described are to be addressed is as follows: -
	The Data Protection Officer
	Sims Trading Company Limited
	7/F., DCH Building, 20 Kai Cheung Road, Kowloon Bay
	Fax.: 25621798
	E-mail: webmaster@sims.com.hk

10.	Language
	If there is any discrepancy between the Chinese and English versions, the English version shall prevail.