Privacy Policy

Last Updated: 22 April 2018

Pad39 Limited (“Pad39”) intends to collect and use your personal data as set out in paragraph 3.1 of the Personal Information Collection Statement (“PICS”)  for direct marketing of the services, facilities or products referred in paragraph 3.2 of the PICS but Pad39 will not do so unless we have received your consent.


Pad39 Limited (referred to hereinafter as the “Pad39”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and all applicable laws and regulations in force from time to time. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by Pad39 is accurate. Pad39 will take all practicable steps to ensure the security of the personal data and to avoid unauthorised or accidental access, erasure or other use.

Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.

  1. Purpose: From time to time it is necessary for Pad39 to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by Pad39 for purposes, including:

1.1 offering, providing and marketing to you the products/services of Pad39, other companies of the Pad39 (“our affiliates”) or our business partners (see “Use and provision of personal data in direct marketing” below), and administering, maintaining, managing and operating such products/services;

1.2 processing and evaluating any registration, subscription orders, deliveries, uses, enquiries, feedback or requests made by you for products/services offered by Pad39 and our affiliates;

1.3 processing your subscriptions and related-billing and payment in relation to any products/services offered by Pad39 and our affiliates;

1.4 providing subsequent services to you, including but not limited to administering the policies issued;

1.5 running competitions, prize draws and promotions;

1.6 designing products/services for you;

1.7 conducting market research for statistical or other purposes;

1.8 matching any data held which relates to you from time to time for any of the purposes listed herein;

1.9 any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by Pad39 and/or our affiliates, including investigation of claims;

1.10 making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;

1.11 contacting you about specific recruitment opportunities if you register search criteria information on our recruitment sites;

1.12 carrying out other services in connection with the operation of Pad39’s business; and

1.13 all other incidental and associated purposes relating to any of the above, including seeking professional advice.

  1. Transfer of personal data: Personal data held by Pad39 relating to an individual will be kept confidential but may be provided to the following parties within Hong Kong for the purposes set out in paragraph 1 above except that any transfer of data to another party for sales and marketing purpose will be subject to paragraph 3 below:

2.1 any of the Pad39’s affiliates;

2.2 any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to Pad39 and/or our affiliates in Hong Kong and who has a duty of confidentiality to the same;

2.3 credit reference agencies or, in the event of default, debt collection agencies;

2.4 any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and

2.5 any government department or other appropriate governmental or regulatory authority in Hong Kong or elsewhere.

  1. Use and provision of personal data in direct marketing: Pad39 intends to use your personal data in direct marketing and Pad39 requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

3.1 use your name, age, date of birth, home address, home telephone number, mobile telephone number and email address held by Pad39 from time to time be used by Pad39 for direct marketing;

3.2 conduct direct marketing (including but not limited to providing reward, loyalty or privileges programmes) in relation to products and services that Pad39, our affiliates, our co-branding partners and our business partners may offer;

3.4 Pad39 also intends to provide the data described in paragraph 3.1 above to all or any of the persons described in paragraph 3.3 above for use by them in marketing those products and services, and Pad39 requires your written consent (which includes an indication of no objection) for that purpose;

3.5 Pad39 may receive money or other property in return for providing the data to the other persons in paragraph 3.4 above and, when requesting your consent or no objection as described in paragraph 3.4 above, Pad39 will inform you if it will receive any money or other property in return for providing the data to the other persons.

If you do not wish Pad39 to use or provide to other persons your personal data for use in direct marketing as described above, you may exercise your opt-out right by notifying Pad39 at any time and without charge. To opt-out, please inform us in writing to the address in the section on “Access and correction of personal data”.

  1. Access and correction of personal data: Under the PDPO, you have the right to ascertain whether Pad39 holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request Pad39 to inform you of the type of personal data held by it.

Requests for access and correction or for information regarding policies and practices and kinds of data held by Pad39 should be addressed in writing to our “Privacy Officer” at:

Pad39 Limited

2/F, Beverly House

93-107 Lockhart Road

Wan Chai, Hong Kong

A reasonable fee may be charged to offset Pad39’s administrative and actual costs incurred in complying with your data access requests.