Introduction

Fortune Systems Limited takes its responsibilities in relation to protecting your personal data and compliance with applicable laws very seriously. We are committed to properly managing, protecting, and processing your personal data in accordance with this Privacy Notice (“Notice”), which shall apply to all personal data we collect from you in the context of the access and use of the website https://fortunesystemslimited.com/ (“Website”).

We encourage you to read this Notice carefully because this Notice explains how we protect and handle personal data you provide to us in the context of the access and use of the Website and we collect automatically. It also provides you with an overview of your rights under the applicable law.

1. Data user (data controller)

Fortune Systems Limited, a company registered under the legislation of Hong Kong, registration number 2623363, legal address: Unit 912, 9/F, TWO HARBOURFRONT, 22 TAK FUNG Street, HUNGHOM, Kowloon, Hong Kong (“We”, “Company”) controls the collection, holding, processing and use of your personal data within the access and use of the Website. Therefore, according to the Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) the Company is the data user.

Fortune Systems Limited may also carry out unsystematic processing of personal data of individuals within the European Economic Area. In this case, Fortune Systems Limited acts as a controller in the sense of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation” or the “GDPR”)

If you have any questions regarding the processing of your personal data, you can always contact us via email info@fortunesystemslimited.com or send a letter to Unit 912, 9/F, TWO HARBOURFRONT, 22 TAK FUNG Street, HUNGHOM, Kowloon, Hong Kong. For general contact please use this page of the Website.

2. Applicable law

The Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) applies to the processing of personal data in connection with the use of the Website except as provided in this Notice.

In case, the processing of personal data of individuals within the European Economic Area, the GDPR and local legislation of the host country are applicable.

3. How and what personal data we collect

In the course of your use of the Website, we collect and process various categories of personal data. At the same time, we are willing to collect only those personal data that are necessary for the purposes specified in this Notice. We may collect the following information:

Personal data we collect from you (“Data collected from you”). These personal data you give voluntarily when you contact us via the relevant page of the Website. In this case we may collect directly from you:

• Your name;

• Email address;

• Your address (optionally);

• Any information you voluntarily provide us in your message.

Personal data we obtain through automated collection (“Automatically Collected Data”). These personal data we automatically collect from your browser when you interact with our Website:

• IP address, information about your location, information about your mobile operator or Internet provider;

• data related to your device: its operating system, browser type, and version, screen resolution, set time zone, language settings, device type: its model and manufacturer (if applicable);

• information about your browsing session and any interaction with the Website interface (for example, the number of pages you visited, the number of pages you clicked);

• information about the source from which you visited the Website.

In addition, we collect data from cookies (hereinafter “Cookie Data“) in accordance with the Cookie Notice.

4. Purposes and legal bases for processing

We collect your personal data for several purposes and based on appropriate legal grounds, namely:

Provision of the Website correct functionality to you. We use Automatically Collected Data and Cookie Data to enable you to access and use the Website entirely and effectively.

According to Article 6 (1)(f) of the GDPR, if applicable, our use of Automatically Collected Data and Cookie Data for this purpose is based on our legitimate interests to make our Website work correctly and provide you with our Website functionality.

Ensuring the security of the Website. We use Automatically Collected Data and Cookie Data to keep our Website safe from any unauthorized access, use, and other unlawful and fraudulent activities that may damage our Website or cause incorrectness in its functionality.

According to Article 6 (1)(f) of the GDPR, if applicable, our use of Automatically Collected Data and Cookie Data for this purpose is based on our legitimate interests to protect our Website against unlawful and fraudulent activities and prevent any attempts of third parties to damage our Website.

Improvement of the Website. We use Automatically Collected Data and Cookie Data to analyze your activities on the Website and your interactions with its functions and content to update, modify, improve, or otherwise adjust the Website and its features.

According to Article 6 (1)(f) of the GDPR, if applicable, our use of Automatically Collected Data and Cookie Data for this purpose is based on our legitimate interests to make our Website performance better for you and enhance your experience on the Website.

Communication with you on general matters. We use Data collected from you to contact and communicate with you regarding your use of the Website and general information about our Company, our services and activities.

According to Article 6 (1)(f) of the GDPR, if applicable, our use of Data collected from you for this purpose is based on our legitimate interests to maintain communication with public and the Website users.

Communication with you to establish business relations with the organization you represent. If you are a representative of an organization interested in our services and contact us to discuss the conditions of further cooperation, we use Data collected from you to establish business relations with the organization you represent.

According to Article 6 (1)(f) of the GDPR, if applicable, our use of Data collected from you for this purpose is based on our legitimate interests to conduct our business successfully and engage new business partners and clients.

5. Period of personal data storage

We undertake to store your personal data no longer than it is necessary to achieve the purposes stipulated in this Notice.

We store Automatically Collected Data for 14 (fourteen) months from Your last visit to the Website.

We store Data collected from you for as long as we communicate with You. When our communication with You is terminated, we will be sure to delete this data. In the event of any dispute with you, we will store your personal information for as long as necessary to resolve the dispute.

The storage period for cookies is defined in the Cookie Notice according to the type of cookie.

6. Rights of personal data subjects

If you are on the territory of Hong Kong, you have the right to access to and correction of your personal data according to Part 5 of the Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486). We will do our best to respond to personal data access and correction requests within 30 days after receiving the request.

      6.1 If You are in the territory European Economic Area, we guarantee You the following rights:

• The right to be informed (Articles 13, 14 of the GDPR);

• The right to access data (Article 15 of the GDPR);

• The right to rectification (Article 16 of the GDPR);

• The right to erasure (Article 17 of the GDPR);

• The right to restriction of processing (Article 18 of the GDPR);

• Right to object (Article 21 of the GDPR);

• The right to data portability (Article 20 of the GDPR);

• Automated individual decision-making and profiling rights (Article 22 GDPR);

• The right to lodge a complaint with the supervisory authority (Article 77 of the GDPR).

We ask You to carefully read Your rights in accordance with the law applicable to the processing.

To exercise any of Your rights, contact us via info@fortunesystemslimited.com or send a letter to Unit 912, 9/F, TWO HARBOURFRONT, 22 TAK FUNG Street, HUNGHOM, Kowloon, Hong Kong.

7. Personal data of children

Our Website is not intended for use by children, and therefore we do not collect or process, at least intentionally, the personal data of individuals under 18 (eighteen) years.

8. Recipients of personal data

To ensure the proper operation of the Website, we may transfer your personal data to third parties, including:

1. Our contractors, subcontractors, external consultants. We may engage third parties to service the Website and, accordingly, transfer your personal data to them. We guarantee that these persons have a contractual obligation with us to process your personal data in accordance with this Notice and the applicable law.

2. Hosting Providers. We use the services of hosting providers and host our Website and other platforms we use on their server. In this regard, they may have access to your personal data, but in encrypted form.

3. IT services providers. We may also use the services of companies that analyze the operation of the Website, your interaction with it and help us to monitor and prevent any external threats to the Website. We currently use the services of the following providers:

Security services providers. To keep our Website safe we use the services of Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107, USA that helps us to optimize the operation of the Website and ensure its protection. Please read more in Cloudflare Privacy Notice.

Analytics services providers. We use services of Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, 368047, Ireland that provides Google Analytics services, and Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA that provides reCAPTCHA services. Please read more in Google Privacy Notice.

9. Cookie Notice

Cookies are small files that are created when You are using the website and stored on Your electronic device (computer or smartphone). Cookies do not allow You to identify You as an individual, but only Your device using special tags.

We use the following cookies:

 

Name of Cookie	Type of Cookie	Storage time	Purpose of use
__cfduid	Security Cookie	1 month	This Cookie helps to protect the Website from bots and other external threats.
_gid	and Analytics Cookies	1 day	Google Analytics uses these cookies in order to analyze how users interact with the Website. With this information, we can improve the Website.
_ga		2 hours
_gat_gtag_UA_157729701_1		1 minute

 

10. Changes to this Notice

If necessary, from time to time, we may make changes, corrections, additions to this Notice. The current version of the Notice will be posted on the Website, so please follow all updates.

Effective Date: May 6, 2021