1. Introduction

This notice is issued by Andrew Moore & Associates Ltd (AMA) on behalf of itself, its subsidiaries, and its affiliates (together AMA, we, us and our) and is addressed to individuals outside of our organisation with whom we interact, including customers, visitors to our websites, and other users of our services (together, you).

For the purposes of this notice AMA is the controller and our contact details are provided in section 14 below.

We understand that your data’s privacy and how it is used is very important to you. AMA respect and value the privacy of everyone who visits our website (www.andrew-moore.com) and so we will only collect and use personal data in ways that are described below. This will also be in a way that is consistent with our obligations and your rights under applicable local and international law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our website. If you do not accept and agree with this Privacy Policy, you must stop using our website immediately.

2. Information About Us

Our website is owned and operated by Andrew Moore & Associates Ltd, which is a limited company registered in Hong Kong.

Registered address: 18B Casey Aberdeen House, 38 Heung Yip Road, Wong Chuk Hang, Hong Kong.

3. What Does this Policy Cover?

This policy will explain how our organisation uses the personal data we collect from you when you use our website.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulations of the EU (GDPR), as

“any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.

So, personal data is any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are Your Rights under GDPR?

You have the following rights, which we at AMA will always seek to uphold:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights.

If you make a request, we have one month to respond to you.

To contact us or for more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.

Further information about your rights can also be obtained from the Information Commissioner’s Office.  https://www.ico.org.uk/

Complaint:

If you have any cause for complaint about our use of your personal data, then please do not hesitate to contact us. You also have the right to lodge a complaint with the Information Commissioner’s Office.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

6. What Data do We Collect?

AMA collects certain information from you when you use our website, this includes:

• IP address
• Web browser type and version
• Operating system
• A list of URLs starting with a referring website, your activity on our website, and the website you exit to.
• Usage information – such as click(s) count and page(s) count.
• Device data and log information – including IP addresses, Operating System (OS), device ID and browser type, browsing history, session frequency, geolocation information.

7. How Do We Use Your Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your Account.
• Providing and managing your access to our website.
• Personalising and tailoring your experience on our website.
• Supplying our products and services to you.
• Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by sending an email to privacy@andrew-moore.com. We may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or post and/or text message with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
• Third Parties, whose content appears on our website or whose services support its operation may use third-party cookies,  an example of such use may occur when using the embedded Google Maps service to locate our offices.

Such third parties may themselves collect a user’s IP address, browser type, OS, geographic location, etc. As we do not control the activities of such third parties, nor the data that they collect from you and use themselves, we advise you to check the relevant privacy policies of any such third parties.

8. How Long Will We Keep Your Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• The data will be retained for as long as a representative of a business has assented to receive details of our products and services; has, at a point in time, entered into a contract to purchase our products and services; or has assented to receive news updates from Andrew Moore & Associates Ltd.

9. How and Where Do We Store or Transfer Your Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.

10. Do We Share Your Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to one important exception. In some circumstances, we may be legally required to share certain personal data, which might include yours, such as if we become involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is required by a third party, as described above, we will take steps to try to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

11. How Can You Control Your Personal Data?

In addition to your rights under the GDPR, as set out in Part 5, when you submit personal data via our website, you may be given options to restrict use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from which you may do by unsubscribing using the links provided in our emails)

12. Can You Withhold Information?

You may access certain areas of our website without providing any personal data at all. However, to use all features and functions available on our website you may be required to submit or allow for the collection of certain data.

13. How You Can Access Your Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and request a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How You may Contact Us?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: privacy@andrew-moore.com

Telephone number: +852 2861 3313

Postal Address:

Andrew Moore & Associates Ltd,

18B Casey Aberdeen House,

38 Heung Yip Road,

Wong Chuk Hang,

Hong Kong.

15. Changes to this Privacy Policy

We may change this Privacy Notice from time to time, and this may for example occur to take account of any changes in the law, or our business practices change in a way that affects personal data protection.

Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations. We recommend that you check this page regularly to keep up-to-date.