Introduction
Total Credit Management Services Hong Kong Limited and Total Credit & Risk Management Group (collectively referred to as "TOTAL") is committed to protecting the privacy and confidentiality of personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong, "PDPO") and other applicable data protection laws and regulations in Hong Kong. This Data Protection Policy outlines our practices and procedures for the collection, use, storage, and disclosure of personal data.

Definitions
"Personal Data": Any data relating to a living individual who can be identified from that data or other information to which the data controller has or is likely to have access.
"Data Subject": An individual who is the subject of the Personal Data.

Scope
This policy applies to TOTAL and its employees, TOTAL’s clients, visitors of TOTAL’s website or any Data Subjects who directly or indirectly provide any Personal Data to TOTAL.

1. Purposes of Collection and Use
If you provide any Personal Data to TOTAL, you are deemed to have authorized TOTAL to collect, retain, transfer, process, and use such Personal Data for the following purposes:

   1.1. Sales, marketing, and promotional information: to provide sales, marketing, or promotional information to you or your company. This information will be related to products and services offered by TOTAL, its affiliates, or TOTAL’s customers, and it will be intended for use by your company in a business-to-business context. Please note that these communications are not intended for your individual benefit or use.

   1.2. Internal recording and services: to use Personal Data within TOTAL's internal database for purposes such as training, providing and administering any customer account for you or your company, delivering requested services or products, and fulfilling orders made by you, your company, or any other representative of your company. Additionally, your personal data may be used to provide products and/or services to TOTAL’S other customers.

   1.3. Internal use: to process and compile information based on Personal Data for internal recording or analyses. This may include researching and quality control, identifying operational and market needs.

   1.4. Legal obligations: to disclose Personal Data to protect TOTAL’S legal rights, or in other circumstances as required by law.

   1.5. Contractual obligation and business transactions: to use Personal Data to complete business transactions including to facilitate a sale or merger involving TOTAL’s assets or businesses, fulfil and confirm orders for products and services, administer individual accounts, update TOTAL's databases, provide customer support, answer your queries or requests for further information, and meet government regulatory requirements.

   1.6. Third-Party Disclosure: to share Personal Data with our affiliates, partners, contractors, or other service providers.

2. Data Retention and Removal
We will only collect and retain the Personal Data for as long as necessary to fulfil the purposes stated under paragraph 1, or as otherwise permitted or required by law.

3. Data Security
Appropriate measures are implemented to protect Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures will be regularly reviewed and updated to ensure their effectiveness.

4. Rights of Data Subject
Individuals have the right to access, correct, update, and request the deletion of their Personal Data held by TOTAL. Requests to exercise these rights should be submitted to the data privacy officer in writing to dpo@totalcredit.hk.