Privacy Policy Statement (“Privacy Policy”)
Our commitment to protect your privacy
We, Kam Lung Motor Group (“KLM”) are committed to protecting your Personal Data (as defined hereinafter) by complying with the requirements of Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”). KLM will ensure compliance by our staff with the strictest standard of security and confidentiality.
You are strongly recommended to read this Privacy Policy carefully to have an understanding of KLM’s policies and practices with regard to the handling of Personal Data collected from you. If you have any questions or concerns regarding this Privacy Policy, you may contact our Customer Relations Department by writing to the following address: Kam Lung Centre, G/F, 53-57 Chai Wan Kok Street, Tsuen Wan, New Territories, Hong Kong or email to unsubscribe@kamlung.com.
By providing your Personal Data to us, you are consenting to this Privacy Policy and to the collection, use, access, transfer, storage and processing of your Personal Data as described in this Privacy Policy.
Collection of Personal Data
“Personal data” refers to any data or information from which an individual may be directly or indirectly identified (“Personal Data”).
We on different occasions collect and use Personal Data that we believe to be relevant and necessary to conduct our business. The types of Personal Data we collect may include, but not limited to:
1. Contact information such as your name, email address, mailing address, telephone number, and fax number;
2. Unique identifiers such as your date of birth, HKID, passport number and driver’s license numbers (or comparable);
3. Billing information such as your credit card number, bank account information, and billing address; and
4. limited location information (for example, an address code to help you find a nearby dealer or partner), user name and password.
Occasionally we may receive information about you from other sources which we will add to the information we already hold about you in order to assist us to provide, improve and personalise our services to you.
In general, KLM does not knowingly collect any Personal Data from any person under the age of 18. In any event, KLM will delete such Personal Data collected as soon as practicable after it is discovered.
If you choose not to provide your Personal Data, you will in most cases still be able to use this site. However, please note that it is mandatory to provide Personal Data marked with asterisks. In the event that you do not provide such Personal Data, we may not be able to provide you with some of our products or services or access to certain parts of our website which require registration, if any. Although you are not obliged to provide your Personal Data as requested, KLM will not be able to provide and administer products and services in the event that you fail to do so.
Use of Personal Data
The Personal Data provided by you or on your behalf to KLM from time to time as well as all other Personal Data related to you collected and held by KLM will be used for any of the following purposes (collectively, the “Purposes”):
1. Purchase of products/services of KLM and/or other companies associated or affiliated with KLM;
2. Using our website and online services;
3. Processing your application for and providing vehicle insurance and/or financing or leasing of vehicles;
4. Processing requests for test drives and transactions;
5. Verifying your identity and identify you/any membership you held with us;
6. Preventing fraud and enhancing the security of your account or our online services, responding to your requests and communicating with you;
7. Managing your preferences;
8. Providing you tailored content and marketing messages;
9. Arranging for vehicle registration, insurance, hire purchase and/or leasing of the vehicles;
10. Arranging for the maintenance, repair and other after-sale services of vehicles;
11. For authorized service dealer to conduct maintenance, repair and other after-sale services;
12. Assessment, maintenance and improvement of our services;
13. Providing you with customer service and responding to your queries, feedback or claims;
14. Conducting market analysis, statistical or other surveys, research and studies;
15. Marketing products and/or services of KLM and/or its affiliates, subsidiaries or associated companies and all other incidental and associated purposes directly relating thereto. Please refer to the section “Direct Marketing” below for further information;
16. Customizing our website and its content to your particular preference;
17. Notify you of any changes to our website or to services that may affect you;
18. Processing billing and payment, determining outstanding amounts and, if necessary, collecting outstanding payments;
19. Anticipating and resolving problems with any products/services supplied or to be supplied;
20. Complying with the applicable laws of any jurisdiction;
21. Making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines binding on KLM and/or its affiliates, subsidiaries or associated companies;
22. Assisting in law enforcement and/or investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;
23. Achieving any other lawful purposes relating to any of the aforesaid purposes; and
24. Any other purposes incidental and directly related to any of the above.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.
KLM will not be entitled to use your Personal Data for any purposes other than the Purposes without your express and informed consent in writing.
Usage and Other Information
In addition to the Personal Data described above, we may collect certain information about your use of our online services. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our online services. In addition, we may later associate the usage and other information we collect online with Personal Data about you.
For your convenience, KLM may in the future offer you the ability to access some of our offers and services through mobile applications and mobile optimized websites. When you interact with us through such channels, we may collect information such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information (such as precise geo-location information) through these channels.
Use of Cookies
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access the site. We use cookies on the website to:
1. Recognize you whenever you visit the site;
2. Obtain information about your preferences, viewing and browsing behavior, online movements and use of the Internet;
3. Keep track of the items stored in your shopping basket and take you through the checkout process;
4. Carry out research and statistical analysis to help improve our services and to help us better understand our visitor and customer requirements and interests;
5. Target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are customized to your interests;
6. Make your online experience more efficient and enjoyable; and
7. Enable tighter security.
The information we obtain from our use of cookies may not contain your Personal Data. Although we may obtain information about your computer or other electronic device such as IP address, browser settings, browsing records, referring/ exit pages, operating systems, date/time stamp and/or other Internet log information, we may not be able to identity you personally. To the extent that non-Personal Data is combined with Personal Data, we treat the combined data as Personal Data for the purpose of this Privacy Policy.
In most cases we will obtain your consent in order to use cookies on this site. The exception is where the cookie is strictly necessary in order for us to operate our website and/or to provide you with a service you have requested.
If you want to disallow the use of cookies, you can do so on your own web browser. If you disable cookies, you acknowledge that you may not be able to use some of the functionality of the site.
Direct Marketing
KLM intends to use your Personal Data for direct marketing carried out by KLM and/or its subsidiaries, affiliates and associated companies, and for such purpose, your Personal Data held by KLM may be provided to any of our affiliates, subsidiaries or associated companies for their use for direct marketing. The intended kinds of Personal Data to be used and the intended classes of marketing subjects are specified in this Privacy Policy. However, we will only use your Personal Data when we have received your consent or where the use is permitted under the Ordinance.
For direct marketing use, KLM intends to use your name and contact information for (i) the supply of our products and/or services which we may offer to you or you may require from us from time to time and (ii) marketing, promotional and customer relationship management purposes, including but not limited to:
1. Giving you updates on latest offers and promotions in connection with our products and services;
2. Conducting market research;
3. Brand activities;
4. Car shows and customer activities;
5. Motor-related services and products;
6. Motor-related insurance;
7. Motor sales and aftersales services; and
8. Redemption gifts, loyalty, reward or privileges programs.
Suitable measures are implemented by KLM to make available to you the option to “opt-out” of allowing your Personal Data to be used in any of the described direct marketing purposes. You can opt-out free-of-charge by writing to our Customer Relations Department, Kam Lung Centre, G/F, 53-57 Chai Wan Kok Street, Tsuen Wan, New Territories, Hong Kong or by sending email to unsubscribe@kamlung.com.
Disclosure of Personal Data
Personal Data supplied to KLM will be kept confidential. KLM does not sell or trade your Personal Data with third parties and we strive to protect your privacy. However, we may disclose such data to or such data may become accessible or known to all or any of the following persons or entities to the extent necessary for achieving the Purposes:
1. Our agents, service providers, contractors, and consultants who process data on our behalf, provide maintenance services of our database or data entry services or who otherwise provide us with administrative, telecommunications, computer, payment, data processing or storage, technical support, or other products/services;
2. Our duly authorized employees who need to know such data in order to process it for us or for the performance of their duties;
3. Our affiliates, subsidiaries or associated companies for Purposes mentioned above and all other incidental and associated purposes relating thereto for fulling the purposes for which it was collected (subject to any consent requirement relating to “Direct Marketing” above);
4. Other companies to bring you co-branded services, products or programs;
5. Any actual or proposed assignee, transferee, participant or sub-participant of KLM’s rights or business; and
6. Our professional advisers including financial advisers and legal advisers.
KLM may disclose the Personal Data to third parties under the following circumstances:
1. In cases where it is required by law, rules, regulations, codes of practice or guidelines binding on KLM or law enforcement agencies or a court order;
2. When we believe in good faith that disclosure is necessary to protect your safety or the safety of others or for the detection, investigation or prevention of illegal activities including fraud;
3. As a result of a sale, merger, acquisition, consolidation, group reorganization, change of control, liquidation, or transfer of our assets;
4. Where KLM needs to protect and defend its legal rights and property; and
5. Where KLM considers necessary to do so in order to comply with any applicable laws and regulations, or any orders or directions made or given by a court of competent jurisdiction.
KLM shall ensure that any disclosure is made in accordance with this Privacy Policy and is properly documented. Other disclosure of your Personal Data will only be made after we have obtained your prescribed consent, or as may be required by law.
Storage of Personal Data
Due to the international nature of our business, we may process and store your Personal Data outside Hong Kong. We may therefore transfer your Personal Data to our affiliate, subsidiary or associated companies outside Hong Kong for data processing and storage. This may involve a transfer of your Personal Data to a jurisdiction where the level of personal data protection may be different.
Your data may be transferred and stored outside of Hong Kong in a secure KLM system or a third party system under contract with KLM or a KLM affiliate. By submitting personal information to KLM or using any KLM website, you understand and consent to such transfer.
Data Retention
All Personal Data that has been collected from you may be retained for a period of time necessary for achieving the purposes for which it is collected or as long as required by applicable law.
In the event any law enforcement agency or regulatory body requests that any Personal Data collected by KLM be preserved for the purpose of an active investigation of a crime, the relevant Personal Data may be retained until such time when it is collected by the relevant law enforcement agency or regulatory body.
Data Security
KLM endeavors to take appropriate steps to ensure that your Personal Data will be protected. We use a variety of physical, technological and organizational measures to safeguard and secure your personal data from unauthorized or accidental access, processing, erasure or other use.。
All KLM’s staff members, contractors and service providers are required to strictly adhere to this Privacy Policy. All Personal Data provided by you are only accessible by KLM or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such Personal Data. You may rest assured that your Personal Data will only be kept for as long as is necessary to fulfill the purpose for which it is collected.
Please however note that no data transmission over the internet can be guaranteed to be completely secured. As such, we do not guarantee the security of any data that are transferred from you or to you via the internet.
Third party websites
This Privacy Policy does not extend to third-party websites that may be linked from our website, or from any other broadcast affiliated with us.
Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his or her behalf and has agreed that you can:
1. Give consent on his or her behalf to the processing of his or her Personal Data;
2. Receive on his or her behalf any data protection notices;
3. Give consent on his or her behalf to the processing of his or her Personal Data;
4. Give consent on his or her behalf to the processing of his or her Personal Data;
Changes to the Privacy Policy
KLM hereby expressly reserves the right to update, revise, modify or amend this Privacy Policy at any time as KLM deems necessary and you are strongly recommended to review this Privacy Policy frequently. If KLM decides to update, revise, modify or amend this Privacy Policy, KLM will post those changes at www.kamlung.com and/or other places KLM deems appropriate so that you would be aware of any updates to our Privacy Policy.
If KLM makes material changes to this Privacy Policy, KLM will notify you on our website or by email.
Updating Your Personal Data
You are entitled at any time to request our confirmation as to whether your Personal Data has been collected by KLM and if so, access to your Personal Data held by us, or to request for correction or deletion of such data, or to withdraw your consent regarding its future use by KLM. We may charge a reasonable fee for the processing of such data access or correction or deletion requests.
You may direct your requests in writing to our Customer Relations Department, Kam Lung Centre, G/F, 53-57 Chai Wan Kok Street, Tsuen Wan, New Territories, Hong Kong or by email to unsubscribe@kamlung.com.
In the event that you wish to access or amend your Personal Data, KLM may request you to provide proof of your identity and all such requisite information to ascertain your identity.
As a customer of KLM Power, you may receive offers from KLM Power that are tailored towards your personal preferences based on analyzing your purchase history, your participation in promotions, surveys and your use of Websites, Apps and other digital channels (“Personalised Offers”).
With Personalised Offers, we would like to notify you of KLM Power products, events and promotions that we believe may be of interest to you. You may receive your Personalised Offers by regular mail, email, SMS, through KLM Power Website, App (through push notifications), social media, coupons or any other digital channels used by you. If you are a KLM Power customer you may adjust your Contact Preferences & Account Settings at any time via the KLM Power Website.
When you visit or use the Website or App, we process some technical information about you (such as your IP address, your location as obtained through our App if this is something that you have previously consented to) and provide you the functionalities of our online services and to manage them. With this technical information we are able to manage the Website and Apps, for example to resolve technical failures or to improve their reliability.
We process technical data such as the IP address, your location and recorded journeys and vehicles co-ordinates, speed and acceleration on KLM Power Drive of your computer, tablet or smartphone, details of the pages you have visited on the Website or App, the web browser you use to surf, previous/subsequent sites that you have visited and the length of your visit/session.
Miscellaneous
This Privacy Policy shall be read in conjunction with other policy documents issued by KLM. If there is an inconsistency between any of the provisions in this Privacy Policy and other policy documents of KLM, the provisions in this Privacy Policy shall prevail.
This Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong.
This Privacy Policy is available in the Chinese and English versions. In the event of inconsistencies or discrepancies between the two versions, the English version shall prevail.