Data Protection and Privacy Policy Vita Liberta

This Privacy Policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this policy to understand what personal data is collected or processed by us, and for what purposes it is used.
We want you to understand why and how Vita Liberta Limited (“Vita Liberta”, “we”, “us” and/or “our”) collects, uses, discloses and or/processes your Personal Data (as defined below) under Hong Kong’s Personal Data Privacy Ordinance (Cap. 486).
This Privacy Policy (“Policy”) applies to you and all Individuals (as defined below) who provide Vita Liberta with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by Vita Liberta in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which you may have provided to Vita Liberta, nor does it affect any legal rights that Vita Liberta may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data.
Vita Liberta may from time to time update this Policy. All updates to this Policy will be posted on this website and are effective from that moment. You shall be deemed to have accepted the Policy as amended by continuing your relationship with Vita Liberta after any amendments have been published on the Vita Liberta Website.
This Policy forms part of the terms and conditions, if any, governing your specific relationship with Vita Liberta (“Terms and Conditions”) and it should be read in along with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

Definitions: For the purposes of this Policy:

“Individual” (or “you”) means a natural person, whether living or deceased and “Individuals” (and “your”) shall be construed accordingly;
“Personal Data” means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to Vita Liberta;
“Personnel” means any Individual engaged under a contract of service with Vita Liberta including permanent or temporary employees as well as trainees and interns engaged by Vita Liberta.

Purposes for collection, use and disclosure of Personal Data

Vita Liberta will only collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary (There are some information which are mandatory for us to collect in order to provide our services to you as part of being regulated) for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:
a) Facilitating Vita Liberta’s provision of products and services which are used by you and from time to time with newsletters, marketing or promotional materials and any other information that may be relevant to you;
b) Communicating with you to assist you with your enquiries;
c) Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you;
d) Conducting market research and customer satisfaction surveys;
e) Any other purposes that we notify you of at the time of obtaining consent (collectively known as the “Purposes”).

Collection of Personal Data

Vita Liberta may collect Personal Data from you in one or more of the following ways or circumstances:
a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services.
b) Information collected automatically: Some information, such as an IP address (We use your IP address to determine your location in order to provide the most relevant content to you) and device type, is collected automatically when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.
c) Information from third parties: Most of the information is collected either directly from you or automatically. Some data may be collected from other sources, such as information that is available in the public domain or trusted third parties in order to conduct background checks as part of your relationship with us. We use this information to supplement the Personal Data that we have collected from you and automatically.
Information about you that we may collect:

Your Personal Data. Examples of such Personal Data you may provide to us include your name, age, birth date, mobile number(s), telephone number(s), mailing or residential address, email address, passport or other identification number, and any other information relating to individuals that you have provided to us during our interaction with you.
Your Messages. We retain the contents of your messages delivered to the us during the course of providing Vita Liberta services to you. Once your messages (including chats, photos, videos, voice messages, files, and shared location information) are delivered, they are kept and are accessible to Vita Liberta staff and other government authorities. Your messages are stored on our server.
We collect your Personal Data in the following ways:
1. when you contact us, for example, via chats, emails, telephone/video calls, letters, face-to-face meetings, social media platforms, and our website;
2. when you request to be included in our mailing list;
3. when you respond to our advertisements, promotions, initiatives;
4. when we receive references from affiliates and third parties, if you have been referred by them;
5. when you submit your Personal Data to us for any reason.

We seek to protect the information we share by imposing contractual privacy and security safeguards on the recipient of the information. Whenever redirected outside of Vita Liberta, we encourage you to read the provider’s relevant privacy policy in order to have a better understanding on how your data is being processed.

Purposes for Collection, Use and Disclosure of Your Personal Data

Vita Liberta collects, uses and discloses your Personal Data for the following purposes:

conducting due diligence exercises;
processing payments;

·replying to your questions, feedback and requests;
·managing Vita Liberta’s business operations;
·complying with internal policies and procedures;
·providing updates and other communications on the development of Vita Liberta’s business process and applications;
·assessing and processing applications or requests made by you for Vita Liberta products and services offered including, but not limited to, corporate secretarial services, incorporation services, tax and accounting services, company registration services;
·managing commercial risks and risk management;
·managing the safety and security of our affiliates and employees;
·managing the safety and security of our premises and services;
·in connection with any claims, actions or legal proceedings (including but not limited to drafting and reviewing documents, transaction documentation);
·meeting or complying with any applicable laws, regulations, codes of practice or guidelines issued by legal or regulatory bodies;

financial reporting and audit;
project management;

·requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
As Vita Liberta relies on your Personal Data to provide products and services to you, you should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
We will seek your consent and notify you in advance when we collect information for purposes other than listed above or for purposes unrelated to the original purpose when collecting the data, unless with the data subject’s express and voluntary consent. You can withdraw your consent previously given by written notice.

Processing of Personal Data

Where we collect Personal data, we will only process it:
a) To perform a contract with you, or
b) Where we have a legitimate interest to protect the Personal Data which is not overridden by your rights, or
c) In accordance with a legal obligation, or
d) Where we have your consent.
Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our Services to you or respond to your other requests.

Sharing Information Outside Vita Liberta

Vita Liberta shares information with external parties that are performing tasks on our behalf (including data processors and sub-contractors) and with other companies, organizations, government bodies, and individuals outside Vita Liberta where we have a legitimate legal reason for doing so (for example, in connection with any merger or acquisition or to comply with a court order) or where we have been instructed to share the information on behalf of our clients.

Duration of Retention

Vita Liberta will retain your Personal Data for only as long as the purposes for which such data is collected or used continues, or where necessary for legal or business purposes.
Vita Liberta will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for those purposes.

We may place and access certain cookie (a cookie is a small piece of data that is stored on your computer or mobile device.) on your computer and/or any electronic device used to access the Website. We use cookies to improve your experience using the Website and to improve our Services. We have taken steps to ensure that your privacy is protected and respected at all times. With regards to data that is collected by cookies, you may disable the use of cookies on your internet browser when accessing Vita Liberta’s Website. However, disabling the use of cookies may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which Vita Liberta’s website operates.

Security of Personal Data.

Vita Liberta will take all practicable steps to protect the Personal Data against unauthorised or accidental access, processing, erasure, loss or use.

Accuracy of Personal Data

Information voluntarily provided by you to Vita Liberta shall be deemed complete and accurate.
Vita Liberta will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you is complete and accurate.
Vita Liberta will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying us, from time to time, of any applicable changes to your Personal Data. Vita Liberta shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to Vita Liberta is complete and accurate.

Overseas Transfer

In the provision of our Services, the Personal Data we collect may be transferred to and processed by third parties in other countries. In all such instances, Vita Liberta shall ensure that the transfer of your Personal Data is carried out in accordance with any applicable laws and that appropriate safeguards (e.g. contractual, technical and organizational measures) are put in place before such transfer takes place.

To contact us regarding:

your Personal Data or our Privacy Policy,
making a subject access/correction request,
requesting to withdraw your consent to any use of your Personal Data as set out in this Policy; or
requesting to obtain access and make corrections to your Personal Data records,

please use the following email address: client@vitaliberta.com