PRIVACY POLICY

MIRR ASIA BUSINESS ADVISORY & SECRETARIAL COMPANY LIMITED PRIVACY POLICY

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1. Introduction and Scope

MIRR ASIA BUSINESS ADVISORY & SECRETARIAL COMPANY LIMITED ("MIRR ASIA", "we", "us" or "our") respects your privacy and is committed to handling personal data responsibly and in accordance with the Personal Data (Privacy) Ordinance of Hong Kong ("PDPO"), applicable data protection and privacy laws and regulations in the jurisdictions in which we operate or provide services, and other applicable legal and regulatory requirements.

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This Privacy Policy explains how we collect, use, process, retain, protect and disclose personal data in connection with our website, communications and services.

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Where we collect or process personal data or personal information relating to individuals in jurisdictions outside Hong Kong, including the United States, Malaysia and other applicable jurisdictions, MIRR ASIA will handle such information in accordance with the privacy and data protection requirements applicable to the relevant processing activities and individuals, to the extent required by applicable law.

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Depending on the services requested, additional personal data may be collected for client onboarding, customer due diligence, AML/CFT, tax, regulatory or other legal requirements. Where appropriate, additional notices or service-specific terms may apply.​

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2. Collection and Use of Personal Data

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MIRR ASIA may collect and use personal data where reasonably necessary to:

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• respond to enquiries and provide requested services;

• communicate with clients, prospective clients and authorised representatives;

• conduct client onboarding, identification and due diligence;

• comply with applicable legal, tax, AML/CFT and regulatory requirements;

• process payments and maintain business and service records;

• manage complaints, risks and disputes;

• protect our legal rights and interests, including establishing, exercising or defending legal claims.; and

• improve our services, systems and website.

 

We seek to collect and use only information that is relevant and reasonably necessary for the applicable purpose.

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3. Types of Personal Data We May Collect

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Depending on the services requested, MIRR ASIA may collect:

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• Personal and Contact Information: name, nationality, date of birth, address, email and contact details;

• Corporate Information: company, directorship, shareholding, beneficial ownership and authorised representative details;

• Verification and Compliance Information: identification documents and information required for customer due diligence, AML/CFT, sanctions screening, tax or regulatory purposes;

• Service and Transaction Information: information provided through applications, instructions, correspondence and payments; and

• Website Information: where applicable, basic technical and usage information, including cookies.

 

MIRR ASIA seeks to collect only information reasonably necessary for the relevant service or legal and regulatory requirements.

 

4. Sources of Personal Data

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Personal data may be collected directly from you or, where reasonably necessary, from authorised representatives, clients, business partners, professional advisers, financial institutions, government authorities, regulators, publicly available sources or other lawful sources.

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Where you provide personal data relating to another individual, you should ensure that you are authorised to provide such information and, where required, that appropriate notice has been provided to that individual.

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5. Retention of Personal Data

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MIRR ASIA retains personal data only for as long as reasonably necessary for the purposes for which it was collected, or for such longer period as may be required or permitted by applicable law, regulation or regulatory requirements.

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Certain information may be retained for customer due diligence, AML/CFT, tax, accounting, regulatory, dispute resolution, record-keeping or other legal purposes.

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Retention periods may vary depending on the nature and sensitivity of the personal data, the purposes for which it was collected or processed, contractual requirements, applicable legal or regulatory obligations and the need to establish, exercise or defend legal claims.

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When personal data is no longer required, MIRR ASIA will take reasonably practicable steps to securely delete, destroy or anonymise it, subject to applicable legal and regulatory requirements.

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6. Disclosure and Sharing of Personal Data

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MIRR ASIA does not sell or commercially trade personal data.

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Where reasonably necessary to provide our services, administer the client relationship or comply with applicable requirements, personal data may be disclosed to relevant parties, including:

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• government authorities and regulators;

• banks and financial institutions;

• professional advisers and other professional service providers;

• corporate service providers, agents and business partners;

• technology, cloud, communication and operational service providers;

• payment and financial service providers; and

• other parties involved in providing the requested services.

 

Personal data will only be disclosed to the extent reasonably necessary for the relevant service, business or compliance purpose, or where required or permitted by applicable law.

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7. Legal and Regulatory Compliance

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MIRR ASIA may collect, use, retain or disclose personal data where reasonably necessary to comply with applicable laws, regulations, regulatory requirements, court orders or lawful requests from competent authorities.

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This may include requirements relating to customer due diligence, AML/CFT, sanctions screening, tax, corporate administration, accounting, regulatory reporting, record-keeping and fraud prevention.

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Where processing is required by law or regulation, separate consent may not be required to the extent permitted by applicable law.

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8. Cross-Border Processing

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Depending on the nature of the services, personal data may be processed, stored or accessed outside Hong Kong by MIRR ASIA, its service providers, professional advisers, financial institutions or other parties involved in providing the services. MIRR ASIA will take reasonably practicable steps to ensure that such handling is subject to appropriate safeguards and is carried out in accordance with applicable data protection requirements.

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9. Protection and Security of Personal Data

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MIRR ASIA takes the protection and confidentiality of personal data seriously and maintains reasonable and practicable technical, organisational and administrative safeguards designed to protect personal data against unauthorised access, use, disclosure, alteration, loss or misuse.

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Access to personal data is restricted to authorised personnel and relevant service providers who require such information for legitimate business, service or regulatory purposes and are subject to appropriate confidentiality obligations.

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MIRR ASIA regularly reviews and, where appropriate, updates its security measures and procedures to address reasonably foreseeable risks and changes in technology or business operations.

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Where a personal data security incident occurs, MIRR ASIA will take reasonably practicable steps to assess, contain and address the incident and make any notification required under applicable law.

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While MIRR ASIA maintains appropriate safeguards, no method of electronic transmission or storage can be guaranteed to be completely secure.

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10. Cookies and Website Technologies

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Our website may use cookies and similar technologies to support website functionality, understand website usage and improve user experience.

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You may manage or restrict cookies through your browser settings. Certain website functions may be affected if cookies are disabled.

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11. Direct Marketing

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Where permitted by applicable law, MIRR ASIA may use personal data for relevant marketing communications concerning our services, business updates, events, offers or other information that may be relevant to our clients or prospective clients.

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You may opt out of marketing communications at any time by using the unsubscribe option provided or by contacting us directly.

Opting out of marketing communications will not affect communications necessary for the provision or administration of our services.

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12. Access and Correction

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Subject to applicable law and relevant exemptions, you may request access to or correction of personal data held by MIRR ASIA about you.

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We may request reasonable information to verify your identity before processing such requests.

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Certain requests may be subject to legal, regulatory or record-retention requirements.

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13. Confidentiality and Third-Party Services

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MIRR ASIA takes reasonable steps to maintain the confidentiality of personal data and requires relevant personnel and service providers to handle such information appropriately.

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Our website may contain links to third-party websites, platforms or services. Such third parties operate under their own privacy policies and terms, and MIRR ASIA does not control or assume responsibility for their privacy practices, security measures or content.

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Where MIRR ASIA engages third-party service providers to process personal data on its behalf, MIRR ASIA will take reasonable steps to ensure that such providers process personal data only for authorised purposes and maintain appropriate contractual, confidentiality, security and data protection safeguards, to the extent required by applicable law.

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14. Changes to this Privacy Policy

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MIRR ASIA may update this Privacy Policy from time to time to reflect changes in our services, business practices, technology, applicable laws or regulatory requirements.

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Where appropriate, material changes may be communicated through our website or other reasonable means. The updated policy will take effect from the stated effective date.

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Nothing in this Privacy Policy limits any rights or remedies available to an individual under applicable privacy or data protection laws.

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15. Contact Us

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For any questions, requests or concerns regarding this Privacy Policy or the handling of personal data, please contact:

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MIRR ASIA BUSINESS ADVISORY & SECRETARIAL COMPANY LIMITED

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Email: legal@mirrasia.com

Telephone: +852-2187-2428