This policy sets out the basis on which Coherent Capital Advisors Limited of 25/F, Two Harbour Square, 180 Wai Yip Street, Kwun Tong, Hong Kong SAR (Company Registration Number: 1941148) (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called “Coherent” or “we”) collects personal data from you and how we process such data. 

By visiting our website https://www.coherent.com.hk  (our “Site”) or using Coherent Product Factory, Coherent Flow, Coherent Pulse, Coherent Connect, Coherent Quick Quote, or any other solutions licensed for use by Coherent or any other applications or software we provide from time to time (collectively our “Software”), you accept and consent to the practices and terms set out below. 

1 Collection of information 

1.1 For the purposes outlined in Section 2, we may collect and process the following information: 

(a) Information provided by you when subscribing to and/or accessing our Software, including information about your clients and any authorized users of the Software, which may include a person’s full name, address, email address, telephone number, credit card information and other personal data provided to us by filling in forms on our Site or submitting through our Software, or by corresponding with us (by phone, email or otherwise), for example: 

(i) when you and/or your authorized users report any problem to us; 

(ii) when you use certain features on our Site or our Software; 

(iii) when you request any support or services from us; or 

(iv) when you complete any survey or questionnaire we send you. 

(b) Information we collect about you – information automatically collected when you visit our Site or use our Software, for example: 

(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your log-in information, demographic data, browser type and version, time zone setting, browser plug-in types and versions, browsing behaviour, operating system, patterns of software (and its features) usage, usage time, user’s behaviour and platform; 

(ii) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer services number. 

1.2 We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists. 

1.3 Although you are not obliged to provide all the information and/or data as requested by us, in the event that certain information is not provided, it is possible that we will not be able to render certain services to you, and/or you may not be able to access certain features the Software. 

2 Uses made of the information

We use information held about you for the following purposes: 

(a) registering, and administrating your subscription account with us; 

(b) providing, evaluating, improving and developing our services; 

(c) researching, designing and launching new features, products or software; 

(d) presenting content and information on our Site and our Software in the most effective manner for you and for the device you use; 

(e) processing payment instructions; 

(f) providing you with alerts, updates, materials or information about our services, products, software or other types of information that you requested or signed up to; 

(g) responding or taking part in legal proceedings, including but not limited to seeking professional advice from legal or accounting professionals; 

(h) complying with applicable laws, rules and regulations; 

(i) communicating with you and responding to your questions or requests; and 

(j) purposes directly related or incidental to the above. 

3 Disclosure of your information 

We will keep personal data that we hold confidential but you acknowledge and agree that for the purpose of providing our software and services to you, we may provide information, on a need-to-know basis, to: 

(a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the Law of Hong Kong; 

(b) personnel, agents, advisers, auditors, contractors, financial institutions, and other third-party information technology, data management service providers and related entities in connection with our operations or services (for example staff engaged in the provision of support services), some of which may be located abroad; 

(c) our overseas offices, affiliates, business partners and counterparts; 

(d) persons under a duty of confidentiality to us for the purpose of seeking professional advice; 

(e) persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or 

(f) actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world. 

4 Cookies 

4.1 Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. 

4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies.  

4.3 We use persistent cookies and session cookies. Persistent cookies stay in your browser and will be read by us when you return to our Site or a partnering site that uses our services. Session cookies only last for as long as the session (usually limited to the current visit to our Site or a browser session). 

4.4 We use the following cookies: 

(a) Strictly necessary cookies – These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to access secured areas of our Site, use a shopping cart, make use of e-billing services or give payment instructions. 

(b) Analytical/performance cookies – They allow us to recognise and count the number of visitors to the Site and to see how visitors navigate our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. 

(c) Functionality cookies – These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 

4.5 You can block cookies by activating the relevant settings on your browser that allow you to disable cookies. However, if you do so, you may not be able to enjoy our Site in its entirety or access to all or parts of our Site. 

4.6 We may use third-party web services on our Site. The service providers that administer these services may use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analysing how visitors use our Site and optimising the content to your interests. As such, the information collected through these means (including IP addresses) may be disclosed to these service providers. These data analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network that would not be directed to you. 

5 Third-party sites 

Our Site, our Software or our communication with you may from time to time contain links to third-party websites over which we have no control. We do not endorse or will not be responsible for any linked third-party websites. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies, website’s terms and cookie policy of these websites to understand your rights and how use of these websites may affect you. We accept no responsibility or liability for any practices or contents of third-party websites, in particular on their accuracy, timeliness or continued availability or existence of such content. 

6 Security 

6.1 All information you provide to us will be stored on our secure servers which may be located in any parts of the world. 

6.2 Any payment transactions will be encrypted using TLS/SSL technology. 

6.3 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

6.4 We restrict access to personal information to our employees, authorized service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations. 

6.5 We shall review our internal personal information collection, storage and processing practices from time to time to safeguard against unauthorised access, processing or use and to ensure compliance with the applicable privacy laws and regulations. 

6.6 You acknowledge and agree that the transmission of information over the Internet will not be completely secure. Although we will do our best in implementing reasonably suitable measures to protect your personal data, we cannot guarantee the security of your data transmitted to or through our Site; any transmission is at your own risk. 

7 Your rights

7.1 You have the right to:

(a) check with us whether we hold personal data about you; 

(b) access any personal data we hold about you;  

(c) require us to correct, rectify, object and/or delete your personal data we and/or the aforesaid authorized third-party hold about you; and 

(d) to withdraw any consent which you have provided in respect of your personal data. 

7.2 Any request under this Section 7.1 can be made by writing to us at customerservice@coherent.com.hk and may be subject to a small administrative fee to meet our cost in processing your request. 

8 Changes to our privacy policy 

We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our Software after the changes come into effect, it means that you agree to be bound by the revised policy. 

9 Contact us 

If you have any questions, comments or requests regarding personal data, please address them to us by sending us an email at customerservice@coherent.com.hk. 

Last updated: 2 January 2020