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PERSONAL DATA (PRIVACY) POLICY STATEMENT (“STATEMENT”)

1. Collection policy and objectives

We, Toronto Investments (Hong Kong) Limited, pledge to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality.

You are strongly recommended to read the Statement carefully to have an understanding of our policy and practices with regard to the treatment of personal information and data provided by you to us at http://www.torontosports.com.hk/ (“Website“). By using the Website, you signify your agreement to the collection, use and disclosure of your personal data by us in accordance with the Statement.

Please note that the provisions herein may be updated, revised, varied and amended from time to time as we deem necessary. Your continued use of the Website following such revision shall be deemed as your acceptance of the amended Statement. It is your responsibility to check the Statement regularly for any amendments.

The Statement is written in both English and Chinese. In the event of any discrepancy or inconsistency between the English and Chinese version of the Statement, the English version shall prevail.

2. Purposes of collection of personal data

In the course of using the Website, you may disclose or be asked to provide personal information and data. In order to have the benefit of and enjoy our various services, information and promotional materials, it is necessary for us to collect some personal particulars from you. Although you are not obliged to provide the data or information as requested on the Website, we will not be able to render our services and provide information and promotional materials to you in the event that you fail to do so.

Our purposes for collection of the information and data on the Website include but not limited to the following:

2.1

to provide you with various services offered by us, online shopping, marketing materials, event information and promotional messages (such as Toronto newsletter);

2.2

to handle and follow up service calls, enquiries and complaints;

2.3

to contact you regarding administrative notices and communications relevant to your use of the Website and/or the services offered by us;

2.4

to assist us with developments for future marketing purposes and/or joint promotion events with third parties;

2.5

to verify your identity;

2.6

to obtain statistics about our users to analyze site usage in order to help its further development; and

2.7

to evaluate the effectiveness of our advertising and marketing campaigns.

Please note that if you are under the age of 13, we would strongly recommend you to seek prior consent from a person with parental responsibility for you, e.g. your parent or guardian, who may contact our responsible Customer Service Officer at websales@torontosports.com.hk for using any service offered on the Website.

3. Collection of personal data from users visiting the Website

When you access the Website, we will record your domain name server address and/or email address and track the pages you visit and store such information in “cookies”. This is done without you being aware that it is occurring. Generally, we use “cookies’ to estimate our audience size, gauge the popularity of various parts of the Website, track users’ progress and number of entries in our promotional activities and to measure users’ traffic patterns. Information and data collected by means of “cookies” will not be disclosed save and except for the circumstances listed out in paragraph 4.

4. Transfer and disclosure of personal data

We will not sell, rent or trade to any third party any personal information and data (in whole or in part) obtained from you without your consent.

We agree to take all practicable steps to keep all your personal information and data confidential and/or undisclosed save and except under the following circumstances whereby the said information and data may be disclosed and/or transferred:

4.1

to any third party suppliers or service providers who have been duly authorized by us to use the said information and/or data and who will facilitate our services;

4.2

to any agents, consultants, affiliates or associates of us who have been duly authorized by us to use the said information and/or data;

4.3

where we need to protect and defend our rights and property;

4.4

where we consider we are required to do so in order to comply with the applicable laws and regulations; and

4.5

where we deem necessary in order to maintain and improve our services.

By using the Website, you are deemed to have agreed to, consented to and authorized us to disclose and transfer your personal information and/or data under the circumstances stated above.

5. Links to other websites

To provide you with more information, the Website may provide links to other websites, including without limitation certain social media websites (such as Facebook). Personal information and data from you may be collected on these other websites when you visit such websites and make use of the services provided therein. Where and when you decide to click on any advertisement or hyperlink on the Website which grants you access to another website, the protection of your personal information and data which are deemed to be private and confidential may be exposed in these other websites.

The Statement is only applicable to the Website. You are reminded that the Statement grants no protection to your personal information and data that may be exposed on websites other than the Website. Where necessary, you may adjust the privacy and/or security setting in your computer/browser with respect to those other websites. To better protect your privacy rights, you are strongly recommended to refer to the privacy policy of such other websites. We assume no responsibility or liability for your use of such other websites.

6. Security

Protection of your personal information and data collected is our top priority. We will always strive to ensure that your personal information and data will be protected against unauthorized access. We have implemented appropriate electronic and managerial measures in order to safeguard, protect and secure your personal information and data.

All personal information and data provided by you will be SSL encrypted and transferred to our server or such other servers of third parties whom are duly authorized by us, and will be stored electronically with proper electronic password implementations. Such personal information and data are only accessible by our own or our authorized third party’s authorized personnel and such personnel shall be instructed to observe the terms of the Statement when accessing such personal information and data.

Please rest assured that your personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected as mentioned in paragraph [2] above, unless you request us to cease to hold the same. Such request may render us unable to further provide our services, information and/or promotional materials for your benefit in the future.

7. Marketing materials

We may from time to time send to you marketing and promotional materials and information regarding our products, services and the like based on the personal information and data that you have provided to us. If you do not wish to receive further marketing and promotional materials and information from us, you may opt-out by informing our Customer Service Officer at websales@torontosports.com.hk.

8. Access to Data

You may at any time request access to, make amendments to and/or obtain a copy of your personal information and data which are stored in our record. To exercise your rights, please email our Customer Service Officer at websales@torontosports.com.hk. We will endeavor to respond to your request(s) within 30 days after receiving the same wherever possible, but we may charge you a reasonable fee for doing so. Upon receiving the aforesaid request(s) from you, we may request you to provide personal details in order to verify your identity.

9. Enquiries

Should you have any queries, please email us at websales@torontosports.com.hk.

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