# Hong Kong Heichinrou Group Privacy Policy

> Hong Kong Heichinrou Group privacy policy. When a translation disagrees, the latest English text prevails.

## Privacy Policy

### 1) Purpose

1.1) The purpose of this Privacy Policy is to define the policies of the Group that relate to how privacy of the users of the Group's services is protected in accordance with the Personal Data (Privacy) Ordinance.

### 2) Kinds of Personal Data

2.1) The Group collects basic information that is available as part of the nature of the service. For example, on a website, this includes, but is not limited to, the user's IP address and information about the user's device and/or software being used to access the service.
2.2) The Group also collects, upon consent from the user, any and all information that has been willingly provided by the user. These include, but are not limited to, Personal Data and information particular to the service being provided.

### 3) Main Purposes of Collecting Personal Data

3.1) The most important purpose of collecting Personal Data is to provide the service being requested by the user.
3.2) The Group also collects information to measure the performance of the services and to improve upon them to provide better quality for the users in the future.

### 4) Retention Period of Personal Data

4.1) The information collected will be retained for as long as the purposes for which it was collected require.

### 5) Access to Personal Data

5.1) All users have the right to inquire about the information collected, and update or delete the data as they wish. Please refer to clause 7 to enquire about making such requests.
5.2) The only third parties that have access to Personal Data are companies that are contracted with the Group to provide specific services in order for the Group to provide its services to the users. These contracted third parties will be bound to the same or higher level of responsibility that the Group is committed to the user.
5.3) Unless required by law or permitted by the user, no other third party will have access to the Personal Data, except in such cases as defined in clause 6.
5.4) All information collected and retained by the Group is protected and internal access is restricted to authorised personnel only.

### 6) Legal Disclaimer

6.1) This Privacy Policy is made in accordance with the Personal Data (Privacy) Ordinance of Hong Kong and any other applicable laws.
6.2) When instructed or upon guidance from the Government of Hong Kong or any of its law enforcement agencies, the Group may, without prior notification to the users, disclose or share relevant data with the Government or any of its agencies or relevant third parties in order to identify and/or investigate any unlawful or potentially unlawful activities, or bring legal action against any party who may be unlawfully acting against the Group, its staff, or its users.

### 7) Enquiries

7.1) Any enquiries can be made from the Contact Us form at https://www.heichinrou.com/en/contactus/.

### 8) Updates to this Policy

8.1) We may occasionally update this Privacy Policy as and when required without prior notice.

### 9) Language

9.1) This Privacy Policy may be translated into languages other than English but when there is doubt in the meaning between translation, the most recent English version shall prevail.

### 10) Definition of Terms

- "Group" refers to each of, or collectively, Hong Kong Ping Jeng Lau Co. Ltd and its affiliates (including affiliates of affiliates).
- "Hong Kong" refers to the Hong Kong Special Administrative Region of the People's Republic of China.
- "Personal Data" refers to the term Personal Data as defined in the Personal Data (Privacy) Ordinance.
- "User" refers to any user or customer of a service provided by the Group.

This Policy was last updated on October 28, 2026.
