(effective 25th May 2018)

General

This Privacy Policy sets out the policies and practices of Compass Offices in the collection, use, sharing and protection of customers’ personal information and applies to all markets and countries in which Compass Offices Group operates. Compass Offices may update or change this policy and these changes will be posted on Compass Offices’ website.

Collection of Customer's Personal Information

For the purpose of carrying on Compass Offices’ business including sale, provision, registration and advertisements of Compass Offices’ serviced offices and related products and services, Compass Offices will collect your personal information when you:

1. enter into an agreement for serviced office space, virtual offices or related services with Compass Offices;
2. enquire as to information about a product or service of Compass Offices;
3. contact Compass Offices with an enquiry or complaint;
4. enter any promotions, competitions, prize draws through Compass Offices’ services;
5. use Compass Offices’ products or services;
6. take part in market research; or
7. visit or browse Compass Offices’ websites or marketing promotion pages.

Types of Personal Data Collected

For the purpose of carrying on Compass Offices’ business including sale, provision, registration and administration of Compass Offices’ serviced office and related products and services, the information that Compass Offices includes but is not limited to the following:

1. your name;
2. correspondence address and/or billing address;
3. account details, including account numbers, service numbers or user accounts;
4. payment details including credit card information, bank account and other banking information;
5. contact details, including contact name and fixed and mobile telephone and email address;
6. your date of birth;
7. information for the verification of your identity including identification number;
8. your preferences for particular products or services;
9. a note or recording of a call that you made to Compass Offices’ hotlines;
10. an email or letter that you sent to Compass Offices; and other records of any contact you have with Compass Offices; and
11. your account information, such as dates of payment, the services you have subscribed to, and any other information relating to your account.
12. Information about your device or connection, for example your internet protocol (IP) address, log-in data, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our products or services and information we collect through cookies and other data collection technologies.

Cookies Policy

Cookies are small text files that are placed on your device by a web server when you access our Platform. We use cookies to identify your access and monitor usage and web traffic on our Platform to customise and improve our products and services.
We use both persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session lasts (usually the current visit to a website or a browser session).
We use the following types of cookies:
Analytical/performance cookies - these allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are easily finding what they are looking for.
Functionality cookies - these are used to recognise you when you return to our site.
Targeting cookies - these cookies record your visit to our site, the pages you have visited, and the links you have followed.
You can block cookies by activating the setting on your browser that allows you to refuse the use of all or some cookies. However, if you do so, you may not be able to access all or parts of our site.

Use of Customers’ Personal Information

Compass Offices may use and analyse your information for the following purposes including but not limited to:

1. for the daily operation of Compass Offices’ services provided to customers;
2. conducting credit checks when required;
3. designing services or products for customers’ use;
4. processing your order and providing the products and services that you have bought from Compass Offices;
5. keeping you updated of Compass Offices’ latest offers or promotions;
6. marketing the following products and services (in respect of which Compass Offices may or may not be remunerated):                     
   1. all products or services by Compass Offices including serviced office space, virtual offices and Internet connectivity;
   2. reward, loyalty or privileges programmes and related products and services; and
   3. products and services offered by Compass Offices’ business partners including travel, dining, entertainment, apparel, health & beauty, education, household, transportation, banking, insurance and other products and services. 
7. assisting you with any products or services enquiries, including investigating and resolving service affecting issues and dealing with any billing enquiries you may have;
8. billing you for using Compass Offices’ products or services;
9. analyzing usage of Compass Offices’ products and services by you and other customers so that Compass Offices can further improve Compass Offices’ products and services and/or better tailor the type of products and services presented to customers;
10. carrying out research and statistical analysis and monitoring customer use of Compass Offices’ products and services on an anonymous or depersonalised basis;
11. assisting Compass Offices in fraud or crime prevention;
12. debt tracing, debt recovery and credit management; and
13. contacting you if necessary.
14. Enhancing your website user experience.

Retention of Personal Data

Compass Offices will destroy any personal data it may hold in accordance with internal policy. Personal data will only be retained as long as Compass Offices needs it unless the personal data is also retained to satisfy any applicable statutory or contractual obligations or for the purpose of investigation, detection and prosecution of crime.

Disclosure and Sharing of Personal Data

All personal data held by Compass Offices will be kept confidential but Compass Offices may disclose information about you to the following parties:

1. companies in the Compass Offices Group;
2. contractors, agents and suppliers who are involved in delivering the products and services you have ordered and used;
3. any banking or financial institutions, charge or credit card issuing companies;
4. credit information or reference bureaus;
5. debt-collection agencies or other debt-recovery organizations;
6. emergency services;
7. professional advisors (including lawyers and auditors);
8. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to Compass Offices in connection with the operation of its business;
9. law-enforcement or government bodies, regulatory bodies, courts or as required by any applicable law;
10. any person to whom Compass Offices is under an obligation to make disclosure under the requirements of any relevant law binding on Compass Offices or under and for the purposes of any guidelines issued by regulatory or other authorities with which Compass Offices is expected to comply;
11. third party reward, loyalty and privileges programme providers;
12. business partners of Compass Offices;
13. external service providers (including but not limited to mailing houses, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that Compass engages for the purposes set out under the section “Use of Customers’ Personal Information”.

Transfer of Personal Data Outside of the Country in Which the Relevant Centre is Located

At times it may be necessary and/or prudent for Compass Offices to transfer certain personal data to other group companies or service providers outside of the Country in which the relevant centre is located. This may happen if Compass Offices’ servers or suppliers and service providers are based outside of the country of origin or if you use Compass Offices’ services and products while visiting countries outside the country of origin. Compass Offices will endeavour to ensure that your personal information used by such third parties is in accordance with this policy.

Your Privacy Rights

In accordance with the terms of any applicable local laws or relevant ordinances, and subject to the exemptions specified in such laws and ordinances, any customer:

1. has the right to check whether Compass Offices holds any personal data about him or her and has a right to receive copies of such data;
2. has the right to require Compass Offices to correct any personal data relating to him or her which is inaccurate; and
3. has the right to ascertain Compass Offices’ policies and practices in relation to personal data and to be informed of the kind of personal data held by Compass Offices.
4. has the right to request deletion of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
5. has the right to request deletion of your personal information object to or restrict the processing by us of your personal information (including for marketing purposes);
6. has the right to 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 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).

You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications or by contacting us. 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.

In accordance with the terms of any relevant laws or applicable ordinances, Compass Offices is entitled to charge a reasonable fee for processing a data access request.

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.

Requests for access to personal data, correction of personal data, information relating to the kind of data held and to stop receiving or re-commence receiving direct marketing may be made in writing by email or post to:

The Data Protection Officer
    Grand Strong Holdings Limited / Compass Offices
    Level 21, The Center,
    99 Queen’s Road Central,
    Central, Hong Kong

Please identify yourself with your name and contact number when writing to the Data Protection Officer.

Email: Marketing@compassoffices.cn

Publication of Privacy Policy

This Privacy Policy is subject to change from time to time and any changes will be posted on Compass Offices’ website compassoffices.cn

If there is any inconsistency or conflict between the version posted on the website and previous versions, this version shall prevail. If there is any inconsistency or conflict between the English and Chinese versions of this policy, the English version shall prevail.