Legal and Data Protection

PRIVACY POLICY STATEMENT

This portion of the website www.sunrisein.com (“Website”) is owned and operated by SUNRISE SUCCESS INTERNATIONAL Hong Kong Ltd. (“SSI” or “we/us/our”).

We are committed to protecting the privacy, confidentiality and security of your personal data held by us.  We take all reasonably practicable precautions and exercise due diligence in this regard, and we treat compliance with the requirements of the Personal Data (Privacy) Ordinance (Cap 486 of the Laws of Hong Kong, hereinafter the “PDPO”) and the guidelines issued by the Office of the Privacy Commissioner for Personal Data (the “Privacy Commissioner”) with respect to the collection, use, retention and management of personal data as a matter of the utmost importance.  Our policy in respect of the handling of personal data is stated in this Privacy Policy Statement, which is publicly accessible on our Website, in particular our policy and practices as to what information is gathered and how such information will be used.

Recruitment Data

1. We may from time to time conduct recruitment activities by means of this Website, including but not limited to announcing vacancies and inviting online applications from persons interested in such vacancies.  Interested persons will be asked to provide their personal information such as their names, details of their identification documents, addresses, telephone numbers, email address, academic qualifications, work experience, age, gender and nationality through our Website when they submit their applications.  Provision of such personal data is entirely voluntary unless otherwise specifically indicated, but failure or refusal to provide any requested data, or the provision of inaccurate or incomplete data, may result in us not being able to process the application in question. 

2. Personal data collected during our recruitment activities (“Recruitment Data”) will be used by us solely for the purpose of recruitment and directly related purposes.  Unless required by law regulation or orders of a court of competent jurisdiction, we will not disclose or transfer our Recruitment Data to any third party without your express written and informed consent given voluntarily.  By providing the information requested by us, you will be deemed to have consented to our making enquiries with any relevant persons, organizations, professional bodies or governmental departments to verify the same for recruitment purposes.

3. The Recruitment Data will be kept by us in electronic form only and will be stored in our internal servers.

Technical Data

4. In addition to Recruitment Data, we also collect information about you and/or your behavior when you visit our Website. 

5. Our Website may make use of cookies[1] to collect the following information (“Technical Data”):

    • IP address of the visitor;
    • last visited website;
    • exact called URL (with subpages);
    • version of Browser;
    • version of Operation System; and
    • date and time of visit.

6. The information about you collected by means of cookies on our Website will be anonymized and will only be used for compiling aggregate statistics on how visitors make use of our Website.  Such statistics are of high value in improving the design of our Website.  We will not use the Technical Data for any other purpose; nor will we share the Technical Data with any third parties.

7. The default settings of most web browsers nowadays permit the use of cookies.  You may choose not to accept cookies by changing the relevant settings.  Please refer to the instructions manual of your own web browser in this connection.  Please note that if you do not accept cookies, there is a chance that some features or functions of our Website may thereby become inaccessible; some pages of this Website may also be prevented from displaying correctly.

Website Analytics

8. We do not use any website analytics.

Links to Third Party Websites

9. Our Website may contain links to websites owned operated or maintained by third parties.  This Privacy Policy Statement only applies to our own Website.  If you access other websites through such links, the owners or operators of those websites may collect information from you and handle such information in accordance with their own privacy policies and practices.  Under no circumstances shall we be held liable for the collection retention use handling or disclosure of information by such third parties.

Direct Marketing and Unrelated Purposes

10. We will not use or provide your personal data (including the Recruitment Data and Technical Data) to any third parties for direct marketing or purposes which are not directly related to those specified herein.

Data Retention

11. We will take all reasonably practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose (including any directly related purposes) for which such data was collected, unless any longer periods of retention are required by any applicable laws and regulations.

12. Recruitment Data provided by applicants who are unsuccessful will be retained by us for a period of 1 year after the date when their respective applications are refused or deemed refused (whichever is the later).  Upon the expiration of the said 1 year, all such personal data will be erased from our servers and will not be retained by us in any form. 

13. On the other hand, Recruitment Data provided by persons who are eventually employed by us will be retained by us for as long as the employment relationship subsists and for a period of 7 years after termination of the same.  Upon the expiration of the said 7 years, all such personal data will likewise be erased from our servers and will not be retained by us in any form unless retention of the same is required by any applicable laws or regulations or is necessary for us to comply with our continuing obligations towards you.

14. Requests for earlier erasure of your Recruitment Data can be made to our Personal Data (Privacy) Compliance Director, whose means of contact can be seen in the section on “Access Rights and Correction” below.  We will consider such requests on a case-by-case basis.  We will either comply with your request or inform you in writing of our reasons for refusal as soon as is reasonably practicable.

15. All Technical Data collected will be retained by us for a period of maximum 6 months from the date of collection.  Upon the expiration of the said period, such Technical Data will be permanently erased from our computer system.  We will also procure our data processors (if any) to likewise destroy such Technical Data in their possession.

Data Security

16. We have and will continue to take all practicable steps to ensure that all personal data held by us are protected against unauthorized or accidental access, processing, erasure, loss or use in accordance with Data Protection Principle 4 as set out in the PDPO.

17. Without limiting the generality of the preceding paragraph, adequate technical security measures, which are reviewed on a regular basis, are taken to ensure the security of your personal information.  We have also adopted protective measures such as restricting access of personal data to relevant employees on a “need-to-know” basis, providing relevant training to our employees to ensure their proper handling of personal data and encrypting personal data where necessary.

18. However, please note that the transmission of information via the Internet is never completely secure.  While we will seek to protect your personal data as best as we can, we are not in a position to guarantee the security of your data transmitted through this Website.  By submitting your personal data through this Website, you agree to bear the security risks inherent in the transmission of information via the Internet.

19. So far as is reasonably practicable, persons engaged by us to handle personal data, including but not limited to IT contractors and website analytics service providers, will be made fully acquainted with our privacy policy as set out herein and requested to fully cooperate with us by complying with our said policy.

20. If we engage a data processor (that is to say a person who processes personal data on our behalf and who does not process the data for any of his own purposes), whether within or outside Hong Kong, to process personal data for us, we will adopt contractual and/or other means to prevent any personal data transferred to the data processor from being kept for longer than is necessary for processing of the data.  We will also adopt contractual and/or other means to prevent unauthorized or accidental access, processing, erasure, loss or use of the data transferred to the data processor for processing.

Access Rights and Correction

21. Under the PDPO, you have the right to find out whether we hold personal data about you.  To obtain a copy of your personal data held by us, please send a duly completed Data Access Request Form (Form OPS003), which is available from the website of the Privacy Commissioner, to our Personal Data (Privacy) Compliance Director by prepaid post at the following address (we do not accept any underpaid postal items):

22. We will verify the identity of all persons making data access requests as aforesaid to make sure that the requestor is entitled to make the request in question.  Details as to the evidence required (documentary or otherwise) will depend on the circumstances of individual cases and will be notified to the requestor as soon as is reasonably practicable after receiving the relevant data access request.

23. We may charge you a reasonable fee for complying with such data access requests.  We will inform you the details of the fee to be charged as soon as possible and in any event not later than 40 days after receiving your data access request.

24. We will supply a copy of the requested data to you within 40 calendar days after receiving your request.  Alternatively, we may refuse your request and inform you in writing of our reasons for refusal.  In that event, you may object to our refusal as aforesaid in writing. 

25. You may further request that your personal data held by us be corrected.  We will verify the identity and/or authority of the requestor upon receiving a data correction request.    Valid data correction requests will be complied with as soon as is reasonably practicable and in any event within 40 calendar days of our receipt of your data correction request; alternatively, we may refuse your request and inform you in writing of our reasons for refusal.  In that event, you may object to our refusal as aforesaid in writing. 

26. If you have any further queries concerning our privacy policy and practices, you may write to our Personal Data (Privacy) Compliance Director at the address given above.

Amendments to this Privacy Policy Statement

27. The Privacy Policy Statement as shown on this Website is the latest version.  However, we reserve the right to amend this Privacy Policy Statement from time to time without prior notice to you and without your prior consent.

Last updated: 20.03.2018

Attention: please read this Privacy Policy Statement carefully before using this Website. If you do not agree to these statements, please do not use this Website. This Privacy Policy Statement apply to all visits to the Website, both now and in the future. We may revoke, revise, modify, or change these statement at any time by updating this posting. Users should re-visit this page from time to time to review the then current statement because they are legally enforceable.

Privacy Policy Statement

This portion of the website www.sunrisein.com (“Website”) is owned and operated by SUNRISE SUCCESS INTERNATIONAL (Shanghai) Limited. (“SSI” or “we/us/our”). We are committed to protecting the privacy, confidentiality and security of your personal data held by us.  We take all reasonably practicable precautions and exercise due diligence in this regard, and we treat compliance with the requirements of the applicable laws with respect to the collection, use, retention and management of personal data as a matter of the utmost importance.  Our policy in respect of the handling of personal data is stated below, which is publicly accessible on our Website, in particular our policy and practices as to what information is gathered and how such information will be used.

Recruitment Data

1. We may from time to time conduct recruitment activities by means of this Website, including but not limited to announcing vacancies and inviting online applications from persons interested in such vacancies.  Interested persons will be asked to provide their personal information such as their names, details of their identification documents, addresses, telephone numbers, email address, academic qualifications, work experience, age, gender and nationality through our Website when they submit their applications.  Provision of such personal data is entirely voluntary unless otherwise specifically indicated, but failure or refusal to provide any requested data, or the provision of inaccurate or incomplete data, may result in us not being able to process the application in question.

2. Personal data collected during our recruitment activities (“Recruitment Data”) will be used by us solely for the purpose of recruitment and directly related purposes.  Unless required by applicable laws and/or regulation, we will not disclose or transfer our Recruitment Data to any third party without your express written and informed consent given voluntarily.  By providing the information requested by us, you will be deemed to have consented to our making enquiries with any relevant persons, organizations, professional bodies or governmental departments to verify the same for recruitment purposes.

3. The Recruitment Data will be kept by us in electronic form only and will be stored in our internal servers.

Technical Data

4. In addition to Recruitment Data, we also collect information about you and/or your behavior when you visit our Website.

5. Our Website may make use of cookies to collect the following information (“Technical Data”):

  • IP address of the visitor;
  • last visited website;
  • exact called URL (with subpages);
  • version of Browser;
  • version of Operation System; and
  • date and time of visit.

6. The information about you collected by means of cookies on our Website will be anonymized and will only be used for compiling aggregate statistics on how visitors make use of our Website.  Such statistics are of high value in improving the design of our Website.  We will not use the Technical Data for any other purpose; nor will we share the Technical Data with any third parties.

7. The default settings of most web browsers nowadays permit the use of cookies.  You may choose not to accept cookies by changing the relevant settings.  Please refer to the instructions manual of your own web browser in this connection.  Please note that if you do not accept cookies, there is a chance that some features or functions of our Website may thereby become inaccessible; some pages of this Website may also be prevented from displaying correctly.

Website Analytics

8. We do not use any website analytics.

Links to Third Party Websites

9. Our Website may contain links to websites owned operated or maintained by third parties.  This Privacy Policy Statement only applies to our own Website.  If you access other websites through such links, the owners or operators of those websites may collect information from you and handle such information in accordance with their own privacy policies and practices.  Under no circumstances shall we be held liable for the collection retention use handling or disclosure of information by such third parties.

Direct Marketing and Unrelated Purposes

10. We will not use or provide your personal data (including the Recruitment Data and Technical Data) to any third parties for direct marketing or purposes which are not directly related to those specified herein.

Data Retention

11. We will take all reasonably practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose (including any directly related purposes) for which such data was collected, unless any longer periods of retention are required by any applicable laws and regulations.

12. Recruitment Data provided by applicants who are unsuccessful will be retained by us for a period of 1 year after the date when their respective applications are refused or deemed refused (whichever is the later).  Upon the expiration of the said 1 year, all such personal data will be erased from our servers and will not be retained by us in any form.

13. On the other hand, Recruitment Data provided by persons who are eventually employed by us will be retained by us for as long as the employment relationship subsists and for a period of 10 years after termination of the same.  Upon the expiration of the said 10 years, all such personal data will likewise be erased from our servers and will not be retained by us in any form unless retention of the same is required by any applicable laws or regulations or is necessary for us to comply with our continuing obligations towards you.

14. Requests for earlier erasure of your Recruitment Data can be made to our Personal Data (Privacy) Compliance Director, whose means of contact can be seen in the section on “Access Rights and Correction” below.  We will consider such requests on a case-by-case basis.  We will either comply with your request or inform you in writing of our reasons for refusal as soon as is reasonably practicable.

15. All Technical Data collected will be retained by us for a period of maximum 6 months from the date of collection.  Upon the expiration of the said period, such Technical Data will be permanently erased from our computer system.  We will also procure our data processors (if any) to likewise destroy such Technical Data in their possession.

Data Security

16. We have and will continue to take all practicable steps to ensure that all personal data held by us are protected against unauthorized or accidental access, processing, erasure, loss or use in accordance with the applicable laws.

17. Without limiting the generality of the preceding paragraph, adequate technical security measures, which are reviewed on a regular basis, are taken to ensure the security of your personal information.  We have also adopted protective measures such as restricting access of personal data to relevant employees on a “need-to-know” basis, providing relevant training to our employees to ensure their proper handling of personal data and encrypting personal data where necessary.

18. However, please note that the transmission of information via the Internet is never completely secure.  While we will seek to protect your personal data as best as we can, we are not in a position to guarantee the security of your data transmitted through this Website.  By submitting your personal data through this Website, you agree to bear the security risks inherent in the transmission of information via the Internet.

19. So far as is reasonably practicable, persons engaged by us to handle personal data, including but not limited to IT contractors and website analytics service providers, will be made fully acquainted with our privacy policy as set out herein and requested to fully cooperate with us by complying with our said policy.

20. If we engage a data processor (that is to say a person who processes personal data on our behalf and who does not process the data for any of his own purposes), whether within or outside China, to process personal data for us, we will adopt contractual and/or other means to prevent any personal data transferred to the data processor from being kept for longer than is necessary for processing of the data.  We will also adopt contractual and/or other means to prevent unauthorized or accidental access, processing, erasure, loss or use of the data transferred to the data processor for processing.

Access Rights and Correction

21. If you want to know whether we hold personal data about you, and to obtain a copy of your personal data held by us, please send a request to our Personal Data (Privacy) by prepaid post at the following address (we do not accept any underpaid postal items):

22. We will verify the identity of all persons making data access requests as aforesaid to make sure that the requestor is entitled to make the request in question.  Details as to the evidence required (documentary or otherwise) will depend on the circumstances of individual cases and will be notified to the requestor as soon as is reasonably practicable after receiving the relevant data access request.

23. We may charge you a reasonable fee for complying with such data access requests.  We will inform you the details of the fee to be charged as soon as possible and in any event not later than 40 days after receiving your data access request.

24. We will supply a copy of the requested data to you within 40 days after receiving your request.  Alternatively, we may refuse your request and inform you in writing of our reasons for refusal.  In that event, you may object to our refusal as aforesaid in writing.

25. You may further request that your personal data held by us be corrected.  We will verify the identity and/or authority of the requestor upon receiving a data correction request.    Valid data correction requests will be complied with as soon as is reasonably practicable and in any event within 40 days of our receipt of your data correction request; alternatively, we may refuse your request and inform you in writing of our reasons for refusal.  In that event, you may object to our refusal as aforesaid in writing.

26. If you have any further queries concerning our privacy policy and practices, you may write to our Personal Data (Privacy) at the address given above.

Amendments to this Privacy Policy Statement

27. The Privacy Policy Statement as shown on this Website is the latest version.  However, we reserve the right to amend this Privacy Policy Statement from time to time without prior notice to you and without your prior consent.

Last updated: July 3rd, 2019

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