Privacy Policy

Your privacy is of highest importance to us.

This policy ("Privacy Policy") sets out how First Pacific Company Limited ("First Pacific") collects, uses, stores and handles your personal data, as data controller.

We are committed to protecting the privacy, confidentiality and security of the personal data we hold, by complying with the applicable regulations including the Hong Kong Personal Data (Privacy) Ordinance.

For sake of clarity, "personal data" means any information or data relating directly or indirectly to a living individual.

• What this Privacy Policy covers and who it applies to
  We recognize the importance of your personal data and are committed to protecting your privacy and handling your personal data in an open, transparent and secure manner. This Privacy Policy shall apply to and govern any and all collection, use, storage and handling of your personal data by First Pacific. This Privacy Policy also serves as a personal information collection statement under the Hong Kong Personal Data (Privacy) Ordinance.
• What personal data do we collect?
  The types of personal data we collect from you will depend on the nature of our engagement with you. It includes the personal data you provide when you:
  
  
  
  • engage with us in relation to employment or experience opportunities at First Pacific, including when you apply for a role with First Pacific or participate in any assessment program relating to such a role;
  • visit and use our website;
  • provide information to us in your capacity as a shareholder or other holder of our listed securities;
  • otherwise contact us, whether as part of media or investor communications, as part of our community and stakeholder outreach activities or otherwise.
  In that respect, the personal data we collect or obtain typically includes:
  
  
  
  • your personal information (e.g. your name, gender, date of birth, passport, identity card number or other personally identifiable number);
  • your contact details including your address, telephone number, fax number, e-mail address;
  • your business information (e.g. company name, business title and associated contact information);
  • employment and education details;
  • your suggestions, feedback, enquiries; and
  • details of how you wish us to communicate with you.
  
  In some cases, we will also collect personal data about you indirectly from third parties such as: (i) recruitment agencies that you use to apply to First Pacific; (ii) background check providers; (iii) third party service providers that help us operate our business and run our website; and (iv) publicly available sources such as business and employment oriented social networking services (such as LinkedIn and Facebook).
  
  The provision of your personal data is generally voluntary. However, if you do not provide such personal data you may not be able to receive requested information from First Pacific. In some cases, the provision of your personal data may be a contractual requirement and you may be required to provide some personal data if you want to enter into an agreement with First Pacific.
  
  In any case, First Pacific undertakes to strictly observe the data minimization principle set forth under applicable data protection regulations and thus to only collect and process personal data strictly necessary for the purposes detailed under this Privacy Policy.
• How First Pacific uses your personal data
  First Pacific undertakes to determine clear and precise processing purposes prior to collecting your personal data and to refrain from processing such personal data for other purposes which are incompatible with the ones for which the said personal data were initially collected.We will use your personal data for the purposes outlined below because (i) it is necessary for our legitimate interest, (ii) it is necessary for legal and/or regulatory obligations or requests that we are subject to, such as keeping records for tax purposes or providing information to regulatory bodies or law enforcement agencies or (iii) it is necessary to perform contractual obligations that we owe to you or to take pre-contractual steps at your request:
  
  
  
  • financial accounting purposes;
  • prudential operational management;
  • prudential IT management (including management of our IT resources, infrastructure and business continuity);
  • undertaking recruitment activities, such as determining the suitability of your qualifications, checking for existing or potential conflicts of interest or any other restrictions which may otherwise restrict or prevent employment with First Pacific;
  • obtaining services from or managing external service providers (e.g. recruitment agencies);
  • managing our HR records and updating our employee database;
  • where relevant, managing and making available personal data within the First Pacific Group (as defined in Section 5 of this Privacy Policy below);
  • providing you with information on the First Pacific Group’s activities;
  • satisfying applicable legal or regulatory requirements;
  • responding to requests from, and other communications with, competent public, governmental, judicial or other regulatory authorities;
  • obtaining services from our professional advisers, such as lawyers, accountants and consultants;
  • considering, and entering into, any transaction involving the business or assets of the First Pacific Group;
  • protecting our rights and those of our stakeholders;
  • meeting our corporate and social responsibility;
  • informing you about any material changes to this Privacy Policy; and
  • otherwise corresponding and managing our relationship with you.
  
  In addition, subject to your prior express consent, First Pacific will use your personal data for the following purposes:
  
  
  
  • sharing your personal data with third parties who act as data controllers; and
  • where applicable, transferring your personal data outside the European Union.
  
  You are entitled to withdraw your consent at any time without affecting the lawfulness of processing based thereon before this withdrawal. For exercising your right of withdrawal, please refer to Section 11 (“Contact”) below.
• How long does First Pacific retain your personal data?
  First Pacific shall retain your personal data for no longer than is necessary for the purposes identified under this Privacy Policy. Please note that the data retention period actually applied by First Pacific may vary, depending on the relevant purpose.If you have entered into an agreement with First Pacific, First Pacific will keep your personal data for as long as it has a contractual relationship with you and for no longer than three (3) years after its termination unless otherwise required by applicable laws or needed for dispute resolution purposes.If you have not entered into an agreement with First Pacific, First Pacific will keep your personal data for three (3) years after your last correspondence with First Pacific.On the expiry of the applicable data retention period, First Pacific undertakes to erase or irrevocably anonymize the relevant personal data.
• Disclosure of your personal data
  For the purposes referred to under this Privacy Policy in the section 3 (“How First Pacific uses your personal data”), First Pacific may need to rely on third parties and thus to share certain personal data with them. Such third parties will either act as another data controller or as data processor acting on behalf and upon the instructions of First Pacific.Please note that no information will be shared with third parties acting as data controllers without your prior express consent, unless First Pacific is under a legal obligation imposed by applicable law to share such information with a third party, such as courts, public authorities, government bodies and/or other regulatory authorities.The third parties which First Pacific may share your personal data with for those purposes are as follows:
  
  
  
  • First Pacific’s subsidiaries, associated companies and other related companies (collectively, with First Pacific, referred to in this Privacy Policy as the “First Pacific Group”);
  • any agent, contractor or service provider who provides assistance necessary to the operation of First Pacific’s website or the achievement of the above purposes;
  • our Hong Kong branch share registrar, in relation to communications with shareholders;
  • any person or authority to whom First Pacific is under a legal obligation to make disclosure as required by any applicable law, such as courts, public authorities, government bodies and/or other regulatory authorities; and
  • any person or authority in order to protect the rights, property or safety of First Pacific, any of its clients or the general public.
• Transfer of your personal data outside the European Union
  You are hereby expressly informed that, as part of its processing activities, and notably where it shares your personal data with third parties for the purposes specified under this Privacy Policy, First Pacific may transfer your personal data to countries outside the European Union, which do not provide an adequate level of data protection.In such a case, First Pacific will seek your express consent prior to transferring your personal data outside the European Union or rely on the relevant EU standard contractual clauses approved by the EU Commission. You have the right to obtain further information about the data transfer by contacting us by email or mail at the address specified in Section 11 (“Contact”).
• Your rights
  As a data subject, you have various rights in relation to your personal data. In particular, you have a right to:
  
  
  
  • request to be informed whether First Pacific holds any of your personal data;
  • request a copy of your personal data held by First Pacific;
  • request that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
  • request that we delete personal data we hold about you, or restrict the way in which we use such personal data;
  • object to the processing of your personal data;
  • withdraw consent to our processing of your personal data (to the extent such processing is based on consent);
  • receive your personal data in a structured and standard format; and
  • lodge a complaint with a local supervisory authority about how your personal data has been processed by First Pacific.
  
  To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us by email at the email address specified in Section 11 (“Contact”) of this Privacy Policy, or by mail to the address specified in Section 11. First Pacific will respond to your request in a reasonable timeframe, and in any event within one month from receipt thereof.
  
  Please note that, for the purpose of enabling you to exercise the above mentioned rights, First Pacific may request information from you in order to confirm your identity and ensure that you are entitled to access the relevant personal data. The timeframe for addressing your request may be extended by the time needed for you to provide the required information.
  
  In accordance with the Personal Data (Privacy) Ordinance of Hong Kong, we have the right to charge a reasonable fee for the processing of any data access request.
• Protection of your personal data
  First Pacific uses a range of physical, electronic and managerial measures to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure or alteration of your personal data. These measures include:
  
  
  
  • education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical controls to restrict access to personal data on a “need-to-know” basis;
  • technological security measures, including firewalls, encryption and anti-virus software; and
  • physical security measures, such as staff security passes to access our premises.
• Cookies
  Cookies are small text files that are placed on your computer or mobile phone when you browse our website. First Pacific uses cookies for email alert signup, online registration for financial results’ audio conferences, teleconferences, add to calendar, and to carry out statistics activities.If you consent to our use of cookies but later wish to opt out, you may at any time change your browser settings in order to block the cookies. Alternatively, the following links provide instructions in order to manage your cookies preferences:
  
  
  
  • Chrome: https://support.google.com/chrome/answer/95647?hl=en
  • Safari: https://support.apple.com/kb/PH21411?locale=fr_FR&viewlocale=en_US
  • Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
  • Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies
  
  Finally, you may visit www.aboutcookies.org, a website providing comprehensive information about how to manage your cookies settings on a broad variety of browsers.
  We consider that your consent to cookies is valid for a maximum period of thirteen (13) months.
• Changes to this Privacy Policy
  This Privacy Policy was last updated on 25 July 2018.This Privacy Policy may be amended from time to time. You may access and obtain a copy of this Privacy Policy, as amended from time to time, at www.firstpacific.com so that you are always informed of the way we collect, use, store and handle your personal data.Any substantial change to this Privacy Policy will be notified to you by any means First Pacific deems appropriate to this end.
• Contact
  If you have any questions about our collection, use, storage or handling of your personal data, or in relation to this Privacy Policy, please email us at: info@firstpacific.com. Alternatively, please write to us at: 24/F Two Exchange Square, 8 Connaught Place, Central, Hong Kong.You may also use these contact details if you wish to make a complaint to us relating to your privacy.