Integrated Management Systems Hong Kong Limited (“We”) are committed to protecting and respecting your privacy. This privacy statement explains what Personal Data we collect from you, through our interactions with you and through our products, and how we use that data. Our Group means our ultimate holding company Integrated Management Systems Hong Kong Limited and its subsidiary Inter Biztech Solutions Limited. We respect your privacy rights about your Personal Data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap 486) (“Ordinance”) and the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).
We are not required to appoint a Data Protection Officer. However, correspondence on any data protection matters should be marked for the attention of Anastasios Papadopoulos at Integrated Management Systems, 36/F, 41 Heung Yip Road, Wong Chuk Hang, Hong Kong.
Who we are and what we do
We are a global management and digital consulting firm. We collect the personal data of the following types of data subjects to carry out our core business and provide you the best experiences with our services:
- Prospective and live client contacts, for digital initiatives;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers.
Information you give to us, or we collect about you
You have choices about the data we collect. When you are asked to provide Personal Data, you may decline. Information you provide is information you give us by filling in our forms or by corresponding with us by phone, email, Site live chat or otherwise — including when you register to use our Sites, subscribe to services, newsletters and alerts, register for or attend an event, participate in discussion boards, enter a competition, promotion or survey, request a white paper, and when you report a problem with our Site.
The information you give us, or we collect about you, may include your name, address, private and corporate email address, phone number, and other similar contact data. We may collect links to your professional profiles available in the public domain (e.g. LinkedIn, Twitter, business Facebook or corporate website), gender, language preferences, date of birth and other similar demographic data.
We may also automatically collect device and usage data when you interact with our Sites — including IP address, device identifier, operating system, web browser, regional and language settings, and browsing information collected through cookies, web beacons, pixels and other similar technologies. When this information relates to or identifies you, we will treat it as “Personal Data.”
What about sensitive Personal Data?
We do not generally seek to collect sensitive personal data (also known as special categories) through this Site or otherwise. In the limited cases where we do, we will do so in accordance with the GDPR. If you choose to provide us with unsolicited Sensitive Personal Data, you consent to our using the data, subject to applicable law as described in this policy.
Information we obtain from other sources
We may obtain information about you from third-party sources such as LinkedIn, corporate websites, your business card and personal recommendations. We protect data obtained from third parties according to the practices described in this statement. These sources have included:
- Data brokers from which we purchase demographic data to supplement the data we collect.
- Service providers that help us determine a location based on your IP address.
- Partners with which we offer co-branded services or engage in joint marketing activities; and
- Publicly-available sources such as open government databases or other data in the public domain.
How we use personal data
The core service we offer to our clients is the implementation of digital services, including digital transformation, advanced analytics, strategic planning, marketing, organisation and operations. Our legal basis for the processing of Personal Data is our legitimate business interests, the performance of a contract, legal obligations, and consent for some specific uses of data. We use information held about you to:
- Provide and improve our services, perform essential business operations, and conduct research and customer support;
- Identify the services provided to you and respond to customer service requests more effectively;
- Protect the security and safety of our customers, and detect and prevent fraud;
- Develop aggregate analysis and business intelligence to operate and report on the performance of our business;
- Administer a contest, promotion, survey or other Site feature, and send you information you agreed to receive;
- Process transactions and send periodic emails relating to your order or enquiries.
If you have given your consent to the processing, you have the right to withdraw your consent at any time by emailing support@imanagesystems.com. We will discontinue the processing of your information upon receipt of your withdrawal; any processing performed prior to your withdrawal remains legitimate.
Our legitimate business interests
“Legitimate Interests” means the interests of our company in conducting and managing our business to enable us to give you the best service and the most secure experience. When we process your Personal Data for our legitimate interests, we consider and balance any potential impact on you and your rights under data protection laws. The table below sets out further detail on the ways we process your data for our legitimate interests.
| Processing purpose | Legitimate interest |
|---|---|
| Individual rights | We may need to retain and continue processing your Personal Data after you have exercised your right to erasure/to be forgotten, in order to keep basic data to identify you as an individual, and retain it solely for suppression purposes to prevent further unwanted processing. |
| Suppression | We may hold Personal Data about you on a suppression file to ensure there is a record of your objection to direct marketing. We will hold a minimised amount of Personal Data in order to uphold this request. |
| Personalisation | We may analyse non-sensitive Personal Data to inform our marketing strategy and to enhance and personalise the consumer experience we offer you. |
| Monitoring | Our customer support team use software solutions that utilise big data to identify recurring problems and analyse patterns of customer behaviour — including LiveChat, web forms, and FAQ activity — to ensure optimum staff performance and serve our customers better. |
| Artificial intelligence | Our customer support team puts in place algorithms that help us manage customer service requests, using AI methods to route customer contacts to the most appropriate part of our organisation. |
| Web analytics | We use online social platforms that use diagnostic analytics to assess the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns. |
| Automated processing based on customer history | We may conduct automated processing based on your transactional history, to predict what other products and services you may be interested in. |
| Information, system, network and cyber security | We may process your Personal Data from online interactions to monitor, detect and protect our organisation, systems, networks, infrastructure, and other rights from unwanted intrusion, unauthorised access, and data and system breaches. |
| Product development and enhancement | We may process your Personal Data to deliver and improve our products or services. |
| Communication, marketing and intelligence | We may process your Personal Data to gather market intelligence, promote products and services, communicate with you and tailor our service offering. |
Consent
Should we want or need to rely on consent to lawfully process your Personal Data, we will request your consent for the specific activity we require consent for and record your response. Where consent is the lawful basis for our processing, you have the right to withdraw your consent at any time.
Cookies and other tracking technologies
Our website may use cookies and similar technologies for record-keeping, to track information about you, to enhance your experience and distinguish you from other users. You may set your web browser to refuse cookies or to alert you when cookies are being sent; if you do so, some parts of our Site may not function properly. We use cookies for sign-in and authentication, security, storing information you provide, social media, feedback, interest-based advertising, analytics, and performance/load balancing.
How to control cookies
Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Certain features of our products and services depend on cookies — if you choose to block cookies, you may not be able to sign in or use those features, and preferences dependent on cookies may be lost.
Disclosure of your information
We may share your personal information with:
- Business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract;
- Our auditors;
- Banks and financial institutions, when you provide payment data, for transaction processing and fraud prevention.
We may also disclose your personal information to third parties in the event we sell or buy any business or assets, if our assets are acquired by a third party, or if we are under a duty to disclose to comply with any legal obligation or to enforce our terms of use and other agreements.
Where we store and process your Personal Data
The data we collect from you will not be transferred to, or stored at, a destination outside of our organisation in Hong Kong, and will not be processed by staff operating outside of our organisation. All information you provide is stored on our secure servers and any payment transactions are encrypted. Unfortunately the transmission of information via the internet is not completely secure; although we will do our best to protect your Personal Data, any transmission is at your own risk.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information. Sensitive and private data exchanged between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures.
Retention of your data
We only retain personal data for as long as we need it for our legitimate business interests. Accordingly, we have a data retention period of up to 6 years and run data routines to remove data we no longer have a legitimate business interest in maintaining. We may archive, pseudonymise, or retain part of your Personal Data on our financial systems only, deleting all or part of it from our main CRM system.
Collection of data from children
When our offerings or services collect age, they will block users under 16 years. We will not knowingly ask children under 16 years to provide data.
Your rights
You have the right to ask us not to process your Personal Data for marketing purposes. You can exercise your right to accept or prevent such processing by checking consent boxes on our forms, managing your subscriptions via unsubscribe links, or by contacting us at support@imanagesystems.com. Guided by the GDPR, we provide you with the following rights:
- Right to be informed about the collection and use of your Personal Data;
- Right of access to your Personal Data and supplementary information;
- Right to rectification;
- Right to erasure (the ‘right to be forgotten’);
- Right to restrict processing;
- Right to data portability;
- Right to object to the collection and processing of your Personal Data.
All requests should be submitted to support@imanagesystems.com; we will respond without undue delay, within one month (extendable by two further months where necessary due to complexity or volume of requests).
Changes to our privacy notice
We have the discretion to update this privacy policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you by email. It is your responsibility to review this privacy policy periodically.
How to contact us
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to support@imanagesystems.com, or by completing our web form. We will respond within 30 days. Our address is Suites 2301–02, 23rd Floor, South Island Place, 8 Wong Chuk Hang Road, Wong Chuk Hang, Hong Kong. Telephone: +852 3611-0130.