Last updated: 3rd February 2020

1. Introduction 
   

1.1  iNCUBEE | LCCS ("us", "we", or "our") takes the privacy of your information very seriously. Please read this policy, together with our Terms & Conditions to learn how we collect, use, share and otherwise process information relating to individuals (“personal information”), and to learn about your rights and choices regarding our processing of your personal information. By using our website https://www.lccs.com.hk (the “Site”) and any services we offer through it as a corporate services provider (the "Services"), you agree to be bound by this policy regarding your personal information collected through our Site.

1.2 By submitting your personal details in our online system, you agree on providing your explicit consent to us to control, save, transfer and process your personal data on a need-to-know basis as outlined in this Privacy Policy. We collect your personal data for specified, explicit and legitimate purposes and will not further process your personal data in a way incompatible with those purposes.

1.3 If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, send us an email at info@lccs.com.hk.

2. What information we collect about you

2.1 To enable us to provide you with our Services, we may ask you to give us certain information which may include, but is not limited to:
• (a) information you provide when filling in and submitting any one of the forms on our Site, for example, your name, email address, physical address, telephone number, and documentation;
• (b)information you provide when engaging with our staff via the live chat on our Site including any contact information, documentation, or screenshots;
• (c)records of correspondence if you contact us via email or any other correspondence;
• (d)particulars of your visits to our Site and the resources you access.

3. How we use information we collect
   

3.1 We will only use information provided by you for the following purposes:
• (a)processing your instruction;
• (b)sending you newsletters with the sole purpose of training and informing you about Hong Kong laws, practices and regulations and from time to time about related our product and service updates;
• (c)verifying your identity;
• (d)carrying out marketing analysis and making general improvements to our Site;
• (e)obtaining your views or comments on the services we provide;
• (f)collecting your payment for some of our Services;
• g)protecting the safety and security of our Site.

4. How we share information we collect 
   
   
4.1 We share information with third parties that help us operate, provide, support, improve, and market our products and services, for example, third-party service providers who provide cloud hosting, maintenance, backup, storage, infrastructure, billing, payment processing, customer support, business analytics, and other services.

4.2 Third-party service providers have access to your personal information for the purpose of performing their services in compliance with applicable laws and regulations.

4.3 We may transfer your personal information to a third party as part of a sale of some or all of our business and assets or as part of any business restructuring or reorganization while taking all necessary steps to ensure that your privacy rights will continue to be protected.

4.4 Other than as set out above we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if we are required to do so by a court order or to prevent fraud or other crimes).

5. Information automatically collected from your computer

5.1 As is true of most websites, we gather certain information automatically via log files. This information may include your IP address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning.

6. Cookies 

6.1 When you visit our Site we may store some information (commonly known as a "cookie") on your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Credit card number is not stored in cookies. A cookie helps you get the best out of our Site and helps us to provide you with a more customized service. We use cookies for the following purposes:
• (a) So you do not have to re-enter your details each time you visit our Site.
• (b) To monitor how our Site is used and to improve and update our content.

6.2 You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this), but certain parts of our Site will rely on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.

7. Security and Retention

7.1 We use secure operators to manage your data and protect payments (please see Terms & Conditions for more information on our online payment service provider and how they retain your data).

7.2 Note that our online payment service provider automatically saves credit/debit card details after every payment made via an electronic invoice issued through their platform. If you do not want this information to be retained, you will need to ask us to delete your credit/debit card details after each payment transaction made in the aforesaid manner.

7.3 We only retain personal data for so long as it is necessary. We will endeavour to protect your Personal Data in our possession or control against risks through reasonable and appropriate security measures. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the Internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.

8. Linking to Third Party Websites 

8.1 Our Site may contain links to third-party sites over which we have no control. If you follow a link to any of these sites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party sites before you submit information to them.

8.2 To the fullest extent permitted under laws, we cannot be responsible for a third-party’s acts, omissions, data policies or their use of cookies nor the content or security of any third-party websites, even if linked to our website. Any such liability is expressly disclaimed and excluded.

9. Your rights

9.1 You have the right to:
• (a)be informed of what we do with your personal information;
• (b)request a copy of personal information we hold about you;
• (c)require us to update and/or correct any inaccuracy or error in any personal information we hold about you;
• (d)request us to delete your personal information (note, however, that we may not always be able to comply with your request to delete if the personal information is still necessary for the purpose which we originally collected it for, or for record keeping or legal compliance purposes);
• (e)object to or restrict the processing by us of your personal information (including for marketing purposes);
• (f)request to receive some of your personal information in a structured, commonly used, and machine-readable format, and request that we transfer such information to another party; and
• (g)withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).

9.2 You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications or by contacting us (please refer to paragraph 1.2 for contact information). Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.

9.3 As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

9.4 Any request under paragraph 9.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

9.5 We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.

10. Changes To This Privacy Policy

10.1 Any changes in the provisions of this Privacy will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time for any reason, and it is your responsibility to check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

11. Policy towards children



11.1 Our products and services are not directed to individuals under 16. We do not knowingly collect personal information from individuals under 16. If we become aware that an individual under 16 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 16.

12. Governing Law and Jurisdiction

12.1 Nothing herein shall limit the rights of the data subject under the Hong Kong Personal Data (Privacy) Ordinance. This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region. As such you agree to submit to the exclusive jurisdiction of the Hong Kong courts.