This Policy explains the manner in which we, The Workbook, collect, process and use your personal data and applies to all companies in The The Workbook group, which include The Workbook and its subsidiaries.
The Workbook understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://workbook.ooo/ (“Our Site”), and also our other digital platforms, namely the MyTEC Portal, the TEC Mobile App and also the TEC WeChat Mini-Program (Our Site and these various platforms being referred to collectively herein as our “TEC Digital Platforms”). This Policy applies to all of these digital platforms unless such application is expressly excluded by a provision set out herein. We will only collect and use your personal data as described in this Policy. Any personal data we collect will only be used as permitted by law.
Please read this Policy carefully and ensure that you understand it. Your acceptance of this Policy is required.1) Information About This Website
The TEC Digital Platforms are owned and operated by The The Workbook.2) What Does This Policy Cover?
This Policy applies to your use of TEC Digital Platforms and all parts of them. TEC Digital Platforms may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.3) What Is Personal Data?
3.1 ) Personal data is defined by legislation in various countries, including the Personal Data (Privacy) Ordinance in Hong Kong and the General Data Protection Regulation of the European Union (EU Regulation 2016/679) (the “GDPR”) (collectively, “the Data Protection Legislation”) and may generally be described as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
3.2 ) Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4.1) Under the applicable Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
b) The right to access the personal data we hold about you. Part 9 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.
d)The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 10 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 10 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for any particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, and we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data and may be able to re-use it with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
4.2) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.
4.3) It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
4.4 ) Further information about your rights can also be obtained from the Privacy Commissioner’s Office in Hong Kong or the equivalent body in other countries where we may conduct business.
4.5 ) If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Privacy Commissioner’s Office in Hong Kong or equivalent body elsewhere if applicable. We would welcome the opportunity to resolve your concerns ourselves, however, and so please contact us first, using the details in Part 10.
5.1) Subject to the following, we do not collect any personal data from you.
5.2.1) TEC Digital Platforms may collect certain personal and non-personal information automatically, including your IP address, the type of browser you are using, your location and certain non-personal data about your computer or device such as your operating system type or version, and display resolution.
Collection of personal data from our website
5.2.2) Your personal data will be collected and stored if you visit our website https://workbook.ooo/ and submit a business enquiry concerning the potential use of our services, submit an enquiry for a meeting room, or purchase a service plan from us online. Such data will be used to initiate and finalise a contract between us for the provision of our business services.
5.2.3) We do not, however, store details of your billing address or credit card data after using them to process a purchase request online.
5.2.5) All cookies used by us are anonymous and used solely for the purposes of marketing products and services that we believe you would be interested in as a result of your past visits to our website. You may therefore receive from us advertisements and promotions from third party suppliers in the form of digital advertising from time to time.
5.2.6) You may disable the cookies at any time by changing the settings on your browser but you should bear in mind that disabling cookies may restrict our ability to serve you with relevant products and services.
5.3)If you send us an email or sign up for an email newsletter, we may collect your name, your email address, other contact details, and any other information which you choose to give us for or on behalf of yourself or the company that you represent.
5.4) All data that we collect from you and other users of our services at or through The The Workboo and TEC Digital Platforms in particular will be distributed to and used on all our digital platforms and some parts of the data may be accessible to and visible by other users by means of our online members’ directory as further described in clause 8.4 below.
5.5 ) For the purposes of the Data Protection Legislation, we are the data controller responsible for such personal data.
5.6) The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of TEC Digital Platforms. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes. We shall collect your personal and other data when you apply for our services through TEC Digital Platforms or in person and, in particular, when you use our website https://workbook.ooo/ or the MyTEC Portal or our TEC Mobile App.
6.1 ) Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7 below.
6.2) Your personal data may be used for making reservations with us, for customer service, for maintaining your account and service agreement with us, for marketing and promotion of our services to you, for providing customer service and for facilitating communications between our members to cultivate business relationships should they wish to participate in our online members’ directory through our dedicated portal (“MyTEC Portal”) and mobile app (“TEC Mobile App) or our TEC WeChat Mini-platform. Subject to clause 8.4 below, the directory will enable members to contact other members via the TEC Digital Platforms but members will not be able to contact each other direct by using the data on our system.
6.3) As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email and such details will include members’ names, titles, locations and their companies’ details if relevant. The other technical data referred to above is necessary for the technical operation of TEC Digital Platforms and will not normally be used in any way to personally identify you.
6.4) Any and all emails containing your personal data will be deleted no later than seven years after the subject matter of your email has been resolved, or such earlier date that may be required by local legislation in a place where we conduct business, and no other personal data will be retained for any longer than is necessary.
6.5) We will not share any of your personal data with any third parties for any purposes other than storage on an email server which at present is located in the US and a web hosting server which at present is located in Singapore (but see clause 7 below).
7.1) We will usually store your personal data in Singapore or in the particular country in which we conduct business with you but we may also use the services of cloud service providers in multiple locations. Wherever stored, it will be fully protected under the Data Protection Legislation applicable to the place where we conduct business.
7.2) Personal data security is essential to us and to protect personal data, we take the following measures:
a) limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
b) procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Privacy Commissioner’s Office in Hong Kong or equivalent body elsewhere if we are legally required to do so;
c) security features available in our cloud hosting platform and employment of the security guidance and best practices as recommended by said platform to secure our servers and applications running on these servers.
8.1) We will not share any of your personal data with any third parties without your consent for any purposes, subject to the following exceptions.
8.2) If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way that we have used it, as specified in this Policy (i.e. to communicate with you).
8.3) In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
8.4.1) If you agree to initiate a service contract with us, you thereby authorise us to share your personal information (or such part of it as you decide to share) with other members in our community and this information will consist of the data referred to in 8.4.3 below. Such sharing would typically be for the purpose of facilitating general networking.
8.4.2) Your personal data, other than your billing address and credit card data, will be collected when you finalise your contracts with us and will be viewable by you (but not other users) on the MyTEC Portal, the TEC Mobile App and the WeChat Mini-Program.
8.4.3) Other users of the TEC Digital Platforms (except for Our Site) will be able to view some of your personal data in the TEC online directory, such data being restricted to your name, title, description, business logo, picture and business location (plus any other data that you may voluntarily provide for viewing by other users). You will be able to opt out of participation in the online directory at any time if you wish to withhold your personal information from other members.
8.4.4) You may initiate communication with other users (both companies and individuals) on an anonymous basis by using the viewable online directory but, for such purpose, you will not have access to any contact details such as telephone numbers or email addresses.
8.5) We may also share personal information with relevant existing members in the event that, for example, an employee of a member reserves or occupies office space provided by us and it becomes necessary to verify the employee’s status by contacting the employer.
9.1) If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
9.2) All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10. To make this as easy as possible for you, a Subject Access Request Form is available on request for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know in order to respond to your request as quickly as possible.
9.3) There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
9.4) We will respond to your subject access request within a period of less than one month and, in any case, not more than one month from the date of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
To contact us about anything to do with your personal data and data protection, including the making of a subject access request, please use the following details (for the attention of our Data Protection Officer)11) How Do I Contact You?
11.1) We may change this Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
11.2) Any changes will be immediately posted on TEC Digital Platforms and you will be deemed to have accepted the terms of the Policy on your first use of TEC Digital Platforms following the alterations. We recommend that you check this page regularly to keep up-to-date. This Policy was last updated on 1st June, 2020.