Privacy Policy Statement
P.B. Group Limited（倍搏集團有限公司）
(Incorporated in the Cayman Islands with limited liability)
(Stock Code: 8331)
1. Statement of Policy
P.B. Group Limited (the “Company“, together with its subsidiaries, the “Group“, “we“, “us” or “our“) respects the privacy of personal data. We are committed to complying with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “PDPO“) and its six Data Protection Principles when collecting, holding, processing and using personal data, and to ensuring that our employees and agents do the same.
This Privacy Policy Statement (this “Statement“) explains how the Company handles personal data through its website (the “Website“) and in the ordinary course of its operations as a listed company.
2. Scope
2.1 This Statement applies to
- visitors who browse or use the Website;
- persons who make enquiries to the Company through the Website, by email, telephone, post or other means, including investors, analysts and members of the media;
- shareholders of the Company and their proxies (in respect of matters that the Company is required to handle as a listed issuer);
- applicants for positions with the Company; and
- suppliers, service providers and business counterparties of the Company, and their contact persons.
2.2 Regulated businesses of subsidiaries
Certain subsidiaries of the Group operate regulated businesses and each provides its own personal information collection statement and privacy policy to its customers, including:
- P.B. Credit Limited: a licensed money lending business operated under the Money Lenders Ordinance (Chapter 163 of the Laws of Hong Kong);
- P.B. Wealth Management Limited: a licensed insurance intermediary registered with the Mandatory Provident Fund Schemes Authority; and
- P.B. Strategic Management Limited: professional manager and corporate management advisory services.
If you are a customer or applicant of any of the above subsidiaries (for example, when applying for a loan, purchasing insurance or MPF-related services, or entering into an advisory services contract), the relevant subsidiary will be the data user of your personal data, and your personal data will be governed by the personal information collection statement provided to you by that subsidiary at or before the time of collection. In case of any inconsistency between that statement and this Statement, that statement shall prevail in respect of that business.
The Website does not accept any loan, insurance or MPF applications, and does not collect any financial, credit or health information of customers through the Website.
2.3 Mainland China operations
The Group carries on bentonite mining and related businesses in Mainland China. Personal information processed in Mainland China is handled by the relevant Mainland subsidiaries in accordance with the Personal Information Protection Law of the People’s Republic of China and other applicable Mainland laws and regulations.
3. Types of Personal Data We Collect
| Category | Data that may be collected | Means of collection |
|---|---|---|
| Website browsing data | IP address, browser type and settings, operating system, language preference, pages visited, time of visit, referring URL | Server logs and cookies (see Section 7) |
| Enquiry and contact data | Name, organisation, job title, email address, telephone number, content of enquiry | Provided by you through contact forms, email or telephone |
| Shareholder data | Name, address, number of shares held, proxy details, attendance records of general meetings | The Company’s Hong Kong branch share registrar, CCASS participants, proxy forms, general meeting registration |
| Job applicant data | Curriculum vitae, education, work experience, contact details and other information you provide | Submitted by you |
| Business contact data | Name, job title, organisation, contact details | Business dealings |
Unless required by law or regulation, we will not ask you to provide sensitive data such as your identity card number, bank account details, credit or health information through the Website. Please do not submit such data in general enquiries.
3.1 Whether provision of data is voluntary or obligatory
You may browse the Website without providing any data that identifies you. Fields marked with an asterisk (*) on contact forms or other data collection forms are obligatory; if you do not provide such data, we may be unable to process your enquiry or request. All other fields are voluntary.
4. Purposes of Collection
The personal data we collect may be used for the following purposes, or purposes directly related to them:
- responding to and following up on your enquiries, requests or comments;
- handling investor relations matters, including sending you corporate information you request and arranging meetings or briefings;
- discharging the Company’s obligations as an issuer listed on GEM of The Stock Exchange of Hong Kong Limited (the “Stock Exchange“), including handling the register of members, general meetings, proxies, dividends and corporate communications;
- complying with applicable laws and regulations, the Rules Governing the Listing of Securities on GEM of the Stock Exchange (the “GEM Listing Rules“), the Securities and Futures Ordinance, the Codes on Takeovers and Mergers and Share Buy-backs, and requirements of regulators, law enforcement agencies, courts or government authorities;
- assessing job applications and handling recruitment matters;
- managing relationships with suppliers and business partners;
- maintaining the operation, security and performance of the Website, and compiling anonymous aggregate browsing statistics to improve the Website’s design and content;
- detecting, investigating and preventing fraud, abuse or other unlawful activities; and
- establishing, exercising or defending legal claims.
We will not use your personal data for a new purpose unrelated to the above purposes without your prescribed consent.
5. Direct Marketing
The Company will not use the personal data you provide through the Website for direct marketing, and will not provide your personal data to any third party for use in direct marketing, whether for gain or not.
If any member of the Group intends to use your personal data in direct marketing in future, it will first notify you in accordance with Part 6A of the PDPO of the kinds of personal data to be used and the classes of services or products to be marketed, and provide you with a response channel through which you may give your consent free of charge. You may withdraw your consent at any time free of charge.
6. Disclosure and Transfer of Data
We keep your personal data confidential. For the purposes set out in Section 4, we may, where necessary, disclose relevant data to the following classes of persons:
| Class | Examples and purposes |
|---|---|
| The Company’s share registrar | Handling the register of members, share transfers, dividends and corporate communications |
| Professional advisers | Auditors, lawyers, compliance advisers and company secretarial service providers, to the extent necessary for their professional services |
| IT and operational service providers | Website hosting, email, data storage, information security and document destruction service providers, processing data on our behalf only in accordance with our instructions |
| Regulators and government authorities | The Stock Exchange, the Securities and Futures Commission, the Companies Registry, law enforcement agencies, courts and other persons legally entitled to request the data |
| Relevant members of the Group | Only to the extent necessary to handle your enquiry or request; for example, an enquiry about a particular business will be passed to the subsidiary responsible for that business |
Save as set out above, we will not sell, rent or otherwise disclose your personal data to any third party without your prescribed consent.
6.1 Data processors
Where we engage a data processor to process personal data on our behalf, we will adopt contractual or other means to prevent the data from being kept longer than necessary, and to prevent unauthorised or accidental access, processing, erasure, loss or use of the data.
6.2 Cross-boundary transfer
The Group has operations in both Hong Kong and Mainland China. Personal data may, for business needs, be transferred to, stored or processed in places outside Hong Kong, including Mainland China. In such cases, we will take reasonably practicable steps to ensure that the data is afforded a level of protection comparable to that in Hong Kong, including, where appropriate, adopting the recommended model contractual clauses for cross-border transfer of personal data issued by the Office of the Privacy Commissioner for Personal Data, or the Standard Contract for Cross-boundary Flow of Personal Information Within the Guangdong-Hong Kong-Macao Greater Bay Area (Mainland, Hong Kong).
6.3 Publicly disclosed data
As a listed issuer, the Company is required under the GEM Listing Rules and other applicable rules to publish announcements, circulars, annual reports and other documents on the HKEXnews website and the Website. Such documents may contain personal data of directors, senior management, the company secretary, substantial shareholders and other relevant persons, such as their names, biographies and interests. Such data is made public in accordance with the law so that investors and the public may access information about the listed issuer.
7. Cookies and Website Browsing Data
7.1 Cookies we use
The Website uses only cookies that are necessary for its operation, mainly:
- Language preference cookie: remembers the language you have chosen for the Website (繁體中文, English or 简体中文); and
- Website administration cookies: used only when authorised personnel log in to the Website’s back office; ordinary visitors will not receive them.
7.2 Server logs
Our web server automatically records your browsing activity, including your IP address, browser type, pages visited and time of visit. We use these records only to maintain Website security, diagnose technical problems and compile anonymous aggregate statistics. We do not use them to identify individual visitors, except where necessary for investigating security incidents or where required by law.
7.3 Refusing cookies
Most browsers accept cookies by default. You may change your browser settings to refuse or delete cookies. Refusing cookies will not affect your access to the public content of the Website, but the Website may be unable to remember your language preference.
7.4 External links
The Website may contain links to third-party websites, such as the HKEXnews website. We are not responsible for the privacy practices of third-party websites, and we recommend that you read the privacy policies of those websites.
8. Data Retention
We will retain personal data only for as long as necessary to fulfil the purposes of collection, except where a longer retention period is required by law, regulation, the listing rules or a regulator, or where retention is necessary for handling disputes, investigations or legal proceedings. In general:
- General enquiries: retained for a reasonable period after being handled, and then deleted;
- Shareholder data: retained in accordance with applicable laws and the practice of the Company’s share registrar;
- Data of unsuccessful job applicants: generally destroyed within 2 years after the end of the recruitment process, unless you consent to our retaining it for future recruitment; and
- Server logs: rotated and deleted periodically according to security and operational needs.
Personal data that is no longer required will be securely deleted or destroyed.
9. Data Security
We adopt reasonably practicable technical and administrative measures to protect personal data against unauthorised or accidental access, processing, erasure, loss or use, including:
- encrypting all connections to the Website by HTTPS;
- protecting servers with firewalls and access restrictions;
- allowing access to personal data only by designated personnel who need it for their duties;
- backing up data regularly and applying access controls; and
- reminding employees of their confidentiality obligations and the relevant requirements on personal data privacy.
No transmission over the Internet can be guaranteed to be completely secure. In the event of a data breach that may pose a real risk of harm to you, we will, in accordance with the guidance of the Office of the Privacy Commissioner for Personal Data, notify the affected persons and the Office of the Privacy Commissioner for Personal Data as soon as practicable and take remedial measures.
10. Minors
The Website is intended for investors, business partners and the general public, and is not designed for minors. We do not knowingly collect personal data of persons under the age of 18 through the Website. If you are under 18, please provide personal data to us only with the consent of your parent or guardian.
11. Rights of Access and Correction
Under the PDPO, you have the right to:
- ascertain whether we hold your personal data;
- request access to your personal data held by us;
- request correction of any inaccurate personal data;
- ascertain our policies and practices in relation to personal data and the kinds of personal data we hold; and
- withdraw any consent you have given for direct marketing.
11.1 How to make a request
A data access request must be made in writing. We recommend that you use the Data Access Request Form (OPS003) specified by the Privacy Commissioner for Personal Data and send the completed form to the email address below. To protect your privacy, we may ask you to provide information sufficient to verify your identity.
We will handle your data access request within 40 days after receiving it. We may charge a fee for complying with a data access request, but the fee will not be excessive and will be limited to the costs directly and necessarily incurred in complying with the request. If a fee is payable, we will inform you in advance.
11.2 Contact us
For requests for access to or correction of data, or enquiries about this Statement, please email:
P.B. Group Limited
Email: office@thepbg.com
For customer data relating to the businesses of our subsidiaries (loans, insurance or MPF services, advisory services), please contact the relevant subsidiary directly, or make your request through the contact details set out in its personal information collection statement.
12. Amendments to this Statement
We may amend this Statement from time to time to reflect changes in law, regulatory requirements or our practices. The amended Statement will be published on the Website. We recommend that you visit this page regularly.
13. Language
This Statement is available in Traditional Chinese, English and Simplified Chinese. In case of any ambiguity or inconsistency between the versions, the English version shall prevail.