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This privacy policy (“Policy”) describes how headrefer,com Limited (“Company”) collect, use and share personal information of consumer users of this website, (the “Site”). 


1. General

The platform (the “Website") is owned and operated by Limited, a Hong Kong limited liability company, which registered office is located at 3/F, Dah Sing Life Building, 99-105 Des Voeux Road Central, Central, Hong Kong, registered with the Hong Kong Companies Registry under identification number 2815025 ("", "we", "our" or "us").


This Privacy Policy Statement (the “Privacy Policy”), together with our Terms of Use and any other documents referred to in it, sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. For the purpose of this Privacy Policy, "Personal data" means data relating directly or indirectly to an individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained. "You" and "your" when used in this Privacy Policy includes any person who accesses the Website and submits Personal Data. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.


2. Your Consent

By using the Website, you consent to our collection and use of your Personal Data as described in this Privacy Policy. If we change our Privacy Policy and procedures, we will publish those changes on the Website to keep you aware of which information we collect, how we use it and under which circumstances we may disclose it.


3. Collection of Personal Data

In order to provide you with better service, we may collect and process the following Personal Data:

(a) Information that you provide by filling in forms on our Website;

(b) Correspondence we kept after you contacted us;

(c) Information you provided by completing surveys that we use for research purposes, although you do not have to respond to them;

(d) Details of transactions you carry through the Website and of the fulfilment of your orders;

(e) Details of your visits to our Website and the resources that you access; and

(f) Any other information that you spontaneously provided to, by any mean whatsoever.


Information provided to through our Website and other methods may be stored, analyzed and used for direct marketing purposes and to improve the way we do business with our current and potential customers. We only retain Personal Data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.

4. Security of Personal Data

Personal data is collected by lawful and fair means and only used for lawful purposes directly related to the functions and activities of We take all reasonably practical steps to ensure that Personal Data collected and retained are accurate and protected against unauthorized or accidental access, processing, erasure or other use. We limit the use of and access to your Personal Data to our designated employees, authorized agents and processors who are instructed to handle your Personal Data in accordance with this Privacy Policy.


All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.


5. Uses made of the information

The purposes for which information may be used by us in and outside the Hong Kong Special Administrative Region include:

(a) Ensuring that content from our Website is presented in the most effective manner for you and for your computer;

(b) Providing you with alerts, newsletter, education materials or information that you requested or signed up to;

(c) Carrying out our obligations arising from any contracts entered into between you and us;

(d) Allowing you to participate in interactive features of our services, when you choose to do so;

(e) Designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;

(f) Complying with laws and regulations applicable to us or any of our affiliates in or outside the Hong Kong Special Administrative Region;

(g) Legal proceedings, including collecting overdue amounts and seeking professional advices;

(h) Researching, designing and launching services or products including seminars/events/forums;

(i) Promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in Article 10 below); or

(j) Purposes directly related or incidental to the above.


We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

(a) Your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behavior, background and demographic data held by us from time to time may be used by us in direct marketing;

(b) The following classes of services, products and subjects may be marketed in direct marketing:

(1) Reward, loyalty or privileges programs, promotional offers and related services; and

(2) Invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.

(c) We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.


6. Disclosure of Personal Data will keep the Personal Data we hold confidential but may provide information to:

(a) Personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;

(b) Our overseas offices, affiliates, business partners and counterparts (if any);

(c) Persons under a duty of confidentiality to us;

(d) Persons to whom we are required to make disclosure under applicable laws and regulations in or outside the Hong Kong Special Administrative Region; or

(e) Actual or proposed transferees or participants of our services in or outside the Hong Kong Special Administrative Region.

(f) Any other information that you spontaneously provided to, by any mean whatsoever.


7. Data transfers

We may hold your data on servers in other territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any people listed under Article 6 above, who may be located in or outside of the Hong Kong Special Administrative Region.


8. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.


9. Access and Correction of Personal Data

Under the Hong Kong Personal Data (Privacy) Ordinance (the "Ordinance"), individuals have the right:

(a) To check whether we hold Personal Data about you and to access such data;

(b) To require us to correct as soon as reasonably practicable any data relating to you which is inaccurate;

(c) To ascertain our policies and practices in relation to Personal Data and the kind of Personal Data held by us; and

(d) To object to the use of your Personal Data for marketing purposes and we shall not use your personal Data for marketing purposes after you communicate your objection to us.

You may exercise your opt-out right by notifying us if you wish to object to the use of your Personal Data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to: Limited
Chief Technical Officer
3/F, Dah Sing Life Building, 99-105 Des Voeux Road Central, Central, Hong Kong


In accordance with the terms of the Ordinance, has the right to charge a reasonable fee for the processing of any Personal Data access request.


10. Changes to our Privacy Policy

Any changes makes to this Privacy Policy will be posted on this page. You should check our Privacy Policy regularly to ensure that you are aware of our latest policies.


11. Disclaimer shall implement the policies and practices in relation to Personal Data, which are set out in their entirety herein, without prejudice to the generality of the Ordinance.'s privacy statements provided therein are for reference only and shall not be regarded as having any legal binding force.


12. Governing law and jurisdiction

Nothing in this Privacy Policy shall limit the rights of the data subject under the Ordinance. This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region. You agree to submit to the exclusive jurisdiction of the Hong Kong courts.


Last updated: April 2019

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