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The Inclusive Company Personal Information Collection Statement

​Last updated: 21 August 2024

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This Personal Information Collection Statement (“PICS”) provides you with information that Inclusive International Company Limited (the “Inclusive Company”) is required by the Personal Data (Privacy) Ordinance (Cap 486) (the “Ordinance”) and applicable laws to provide to you in relation to the Personal Data that the Inclusive Company collects from you.

Under the Ordinance, Personal Data means any data or information relating to an individual and from which it is practicable for the identity of that individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable. 


Capitalised terms used but not defined herein have the meanings ascribed to them in The Inclusive Company’s Privacy Policy.
 

Purpose of Collecting Your Personal Data
It is voluntary for you to provide your Personal Data. However, if you do not provide sufficient information, we may not be able to offer certain services or features of our App, including personalized experiences and specific functionalities that rely on user data.


The Personal Data collected by us will be used to:

  • Operate, maintain, and provide you with the features and functionality of our App and Services;

  • Promote the security of our App and Services;

  • Process and complete your application for registration of a User Account and manage your User Account; and

  • Subject to the provisions of the Ordinance, send you marketing materials if you have consented or have not objected in writing.

 

‍How we collect your Personal Data

‍We collect your Personal Data when you:

  • Sign-up for and use the Services;

  • Log-in to our App;

  • Update your User Account;

  • Fill-out a membership or application form;

  • Fill out a survey; and

  • Submit enquiries directly to customer support or through third party tools. 

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Who We Share Your Data With

Your Personal Data held by the Inclusive Company will be kept confidential. To facilitate the purposes mentioned above, we may transfer, disclose, grant access to, or share your Personal Data with the following parties:

 

  • NGOs and Social Enterprises: To support social and educational initiatives.

  • Your Company: If you use your company email address to sign up for a User Account, for verification purposes.

  • Trusted Third-Party Service Providers: To assist with hosting our Services, facilitating communications on our App through messaging services, offering incentive programs, sending out emails and updates, processing payments, or providing back-office or IT services on our behalf.

These third parties are required to have privacy policies and security standards in place that are at least as protective of your Personal Data as our Privacy Policy. The information practices of these third-party service providers are governed by their privacy policies, which you should review to understand their privacy practices.

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Access to Personal Data

The Ordinance provides you with rights concerning the Personal Data that we hold about you, including the right to:

  • Request a copy of the Personal Data;

  • Request that we rectify, restrict, or delete your Personal Data;

  • Object to direct marketing; and

  • Unsubscribe from marketing communications.

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Retention of Personal Data

The Inclusive Company retains your Personal Data for as long as necessary to provide you with the Services or for other important purposes, such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you have a User Account with us, we will typically retain your Personal Data for ninety (90) days after you request your account to be closed or if it has been inactive for seven (7) years. After the retention period, your data will be securely deleted or anonymized.

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Security Measures

We take appropriate precautions, including organizational, technical, and physical measures, to safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use. We employ industry-standard encryption protocols to protect your data in transit and at rest, and ensure that physical access to our data storage facilities is restricted to authorized personnel only. Please refer to our Privacy Policy at https://www.theinclusive.asia/en/legal/privacy for further details.

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Enquiries

Please contact the customer service team of The Inclusive Company at cs@theinclusive.asia if you:

  • Have any questions regarding this PICS, our Privacy Policy or the way in which we handle your Personal Data;

  • Wish to submit a request to access or correct your Personal Data held by us; or

  • Wish to withdraw your consent to the receipt of any marketing materials.

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