Privacy Policy

Action Investments Limited - Privacy Policy

This is the privacy notice to cover the activities carried out by the Action Investments Limited. In this document, “we”, “our”, or “us” refer to Action Investments as the legal owners of actioninvestmentsltd.com.

Introduction

1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.

3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.

4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

5. Our policy complies with local jurisdictions and specifically the EU General Data Protection Regulation (GDPR).

6. The regulations require us to tell you about your rights and our obligations to you regarding the processing and control of your personal data.

7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or any associated web-based data-capture forms.

The bases on which we process information about you

The regulation requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process

When you submit your details via any of the forms on our website, or otherwise agree to our terms and conditions, a relationship is formed between you and us.

To carry out our obligations to attempt to serve you we must process the information you give us. Some of this information may be personal information.

We may use it to:
1.1. verify your identity for security purposes
1.2. provide you with our services
1.3. provide you with relevant information, suggestions and advice on products, services and how to obtain the most from using our services
1.4. We may periodically send promotional email about our services, events or other information which we think you may find interesting using the email address which you have provided.

We process this information on the basis there is a customer/service provider relationship between us, or that you have requested we use the information before we begin a relationship.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the relationship between us ends.

2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a page on our website.

We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at:

complaints@actioninvestmentsltd.com. However, if you do so, you may not be able to use our website or our services further.

3. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having considered:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our business.
• responding to unsolicited communication from you to which we believe you would expect a response
• Providing you with up-to-date information relevant to your initial enquiry and/or personal information.
• protecting and asserting the legal rights of any party
• protecting your interests where we believe we have a duty to do so

4. Information we process because we have a legal obligation

Sometimes, we must process your information to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorization such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

5. Information provided on the understanding that it will be shared with a third party

Our website may allow you to post information with a view to that information being read, copied, downloaded, or used by us.

Examples include:
5.1. posting a comment on a blog
5.2. tagging an image
5.3. clicking on an icon next to another visitor’s post to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We may store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at complaints@actioninvestmentsltd.com.

6. Sending a message to our team

When you contact us, whether by telephone, through our websites or by e-mail, we collect the data you have given to us to reply with the information you need.

We record your request and our reply to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address to be able to track our communications with you to provide a high-quality service.

7. Complaints regarding content on our website

We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we must make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

8. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Use of information we collect through automated systems when you visit our website

9. Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

10. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

11. Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

12. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.

Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Disclosure and sharing of your information

13. Data may be processed outside the European Union

Our websites are hosted in the United States.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly, data obtained could be processed outside the European Union.

We use the following safeguards with respect to data transferred outside the European Union:

13.1. the processor is within the same corporate group as our business or organization and abides by the same binding corporate rules regarding data processing.
13.2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
13.3. we comply with a code of conduct approved by a supervisory authority in the European Union
13.4. we are certified under an approved certification mechanism as provided for in the GDPR
13.5. both our organization and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information

Access to your own information

14. Access to your personal information
14.1. At any time, you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
14.2. To obtain a copy of any information that is not provided on our website you may send us a request at enquiries@actioninvestmentsltd.com.
14.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

15. Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at complaints@actioninvestmentsltd.com.

This may limit the service we can provide to you.

16. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

17. Use of site by children
17.1. We do not sell products or provide services for purchase by children, nor do we market to children.
17.2. If you are under 18, you may use our website only with consent from a parent or guardian
17.3. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
17.4. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.

18. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

19. How you can complain
19.1. If you are not happy with our privacy policy or if have any complaint, then you should tell us by email. Our address is complaints@actioninvestmentsltd.com.
19.2. If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.


20. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
20.1. to provide you with the services you have requested;
20.2. to comply with other law, including for the period demanded by our tax authorities;
20.3. to support a claim or defense in court.

21. Compliance with the law

Our privacy policy has been compiled to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

22. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us

 Skyway Centre, Queen's Road   West,  Sheung Wan, Hong Kong
 (+852) 457-89899
 info@actioninvestmentsltd.com
 CR No.: 0843693
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