Daimler AG (“Daimler”) and Mercedes-Benz Hong Kong Limited (“MBHK”) (together referred to as “we”, “our” or “us”) appreciate your interest in our products and your visit to this website. Your privacy is important to us and we want you to feel comfortable visiting our site. The protection of your privacy in the processing of your personal data is an important concern to which we pay special attention during our business processes. Personal data collected during visits to our website are processed by us according to the applicable laws in Hong Kong including but not limited to the Personal Data (Privacy) Ordinance (Cap.486) (“PDPO”). In addition, our data protection policy complies with the Data Protection Code of Conduct applicable company-wide for Daimler insofar as it is not in conflict with the laws of Hong Kong. This website may include, however, links or references to other websites which are not covered by this Privacy Policy. You should consult the privacy policy of those websites before providing any personal data and we shall not be liable in relation to the activities of such websites.
Daimler Data Protection Code of Conduct
Collection and Processing of Personal Data
When you visit our website, our web server automatically records the name of your internet domain, internet service provider, browser and operating system used to access our website, the website from which you visit us, the web pages you actually visit and the date and length of your visit. This information allows us to measure site and user activity to tailor information to suit your individual preferences.
Personal data (for example your name, gender, age, email address, mailing address, telephone number, residency, nationality, company and job position) is only stored if volunteered by you, for example when you register with us, request for customer service or other assistance, submit a customer survey, enter into a contest or a contract through this website and / or through events organized by MBHK, or by MBHK in cooperation with Zung Fu Company Limited (“ZF Hong Kong”), Zung Fu Motors (Macau) Limited (“ZF Macau”) and Mercedes-Benz Financial Services Hong Kong Limited (“MBFS”) and/or other third party host or co-host of events/workshops. You should be aware that when you voluntarily disclose personal information in public areas of our website, such as bulletin boards, this information may be seen and used by others. We urge you to exercise good judgment when sharing personal information in these forums.
Use of Cookies
We use cookies to follow the preferences and actions of our visitors to optimise their visits to our website accordingly. "Cookies" are small text files that are stored on your hard drive when you access the website and visit certain web pages. Cookies are used in almost all major web sites. The purpose is to save you time and provide you with a more meaningful visit. If you are concerned about cookies, you may modify your browser settings to notify you when you receive a cookie. If you do not know how to modify your browser settings please consult your browser documentation or supplier website. However, it is possible that some parts of the website will not function properly if you modify your browser settings. Further, we will not be able to recognize you as a visitor over time.
Use and Disclosure of Personal Data and Purpose Specification
We will use your personal data for the following purposes only to the extent necessary in each specific case:-
• Carrying out the purposes for which such information was provided (including but not limited to responding to your questions, inquiries or concerns, and providing you with the relevant product, service or support);
• Technical administration of the website such as monitoring or improving the use of the website and performing cookie data analysis which assists in search engine optimization;
• Customer administration of the website such as communicating with you about changes to our policies;
• Administering and inviting you to participate in our product surveys;
• For direct marketing and promotional events (including test drives) organized by us and/or our exclusive authorised dealers in Hong Kong and Macau, ZF Hong Kong and ZF Macau respectively and/or by MBFS and/or by other third party host or co-host of events/workshops (including without limitation, advising, promoting, marketing and informing you about our automobile and related financial products and services and activities and events in connection therewith) or for promotion on or invitation to events/workshops hosted by us or other third party companies or co-hosted by us and other companies on automobile or non-automobile related products and services. Please refer to the section “Freedom of Choice” below for further information;
• Detecting, investigating and preventing activities that may violate our policies or be illegal, or for compliance with any applicable laws and regulations.
We will share and disclose your personal data with ZF Hong Kong, ZF Macau and/or MBFS and/or other third party host or co-host of events/workshops for handling, keeping and use for the purposes described in this Privacy Policy.
Apart from the above, we shall not share your personal data with any third parties except as follows:-
• We may disclose your data in cases where it is required by law;
• We may disclose your data when we believe in good faith that disclosure is necessary to protect your safety or the safety of others or investigate fraud;
• We may disclose your data to other Daimler companies, including but not limited to those companies listed herein, for the purposes described in this Privacy Policy;
• We may transfer, sell or assign any of the information described in this Privacy Policy to any third parties as a result of a sale, merger, acquisition, consolidation, change of control, transfer of assets, reorganisation of our business, liquidation, or sale or dissolution of assets;
• We may transfer your personal data to our agencies, service providers or suppliers engaged to provide us with information technology support or conduct server maintenance of our data banks, or process data on our behalf (such as those which perform cookie data analysis) and those which are commissioned by us to carry out special advertising campaigns;
• We may share your personal data to our employees who need to know such data in order to process it for us.
Our employees, agencies, ZF Hong Kong, ZF Macau and MBFS and other third party host or co-host of events/workshops are obliged by us to respect confidentiality. Whilst we will use every effort to keep your data confidential, we cannot guarantee that such data will not be disclosed inadvertently or otherwise. We shall not be responsible for any harm that you or any person may suffer as a result of a breach of confidentiality in respect of your use of this website or any information you transmitted to this website.
Freedom of Choice
We should like to use your data, and share your data with ZF Hong Kong, ZF Macau and/ or MBFS and/or other third party host or co-host of events/workshops, to inform you and market our automobile, related financial products and services and activities and events (including test drives and other promotional events organized by MBHK, Daimler, ZF Hong Kong, ZF Macau and/or MBFS) or for promotion on or invitation to events/workshops hosted by us or other third party companies or co-hosted by us and other companies on automobile or non-automobile related products and services and where applicable request your opinion. Naturally your participation is completely voluntary, and we may not so use your personal data unless we have received your consent (which includes an indication of no objection) or unless otherwise permitted under the PDPO and/or the guidance notes or directions of the Privacy Commissioner for Personal Data.
If you consent to our use of your personal data for direct marketing and promotional purposes, please tick the relevant box in the form by which your personal data is collected.
In any event, you can also inform us at any time that you wish us, and/or the companies mentioned herein to cease using your personal data for direct marketing and promotional purposes. Such notification should be sent to the contact details as set out in the paragraph headed “Freedom of Information” as set out below.
Security
In accordance with the PDPO, we have put into place reasonable safeguards and precautions such as the use of technical and organisational security measures to protect the data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorized persons. Our security procedures are continually enhanced as new technology becomes available.
However, while we try our best to safeguard your personal data once we receive it, no transmission of data over the internet or any other public network can be guaranteed to be 100% secure.
Changes
This Privacy Policy may be updated from time to time, including but not limited to when any privacy legislation and/or voluntary codes are introduced. We will notify you of any significant changes to our Privacy Policy by posting the new Privacy Policy onto the website.
Freedom of Information
Upon request, we (or our representatives) will, subject to an administrative fee payable by you, inform you without delay in writing as defined by the applicable law what personal data is stored by us.
You may also at any time request access to and correct your personal data held by us (or those held by ZF Hong Kong, ZF Macau as our exclusive authorized dealer in Hong Kong or Macau respectively, or by MBFS). If you wish to do so, please contact the following personnel whose contact details are as follows:-
Address: 32/F, Lee Garden One, 33 Hysan Avenue, Hong Kong
Email: cs@zungfu.com
Telephone: (852) 2504 6140
Contact: Customer Relations
Should you have questions regarding the processing of your personal data you can also refer to our chief corporate data protection officer, who is also available with his team for enquiries, suggestions or complaints.
Chief Officer Corporate Data Protection
Daimler AG
HPC 0824
D- 70546 Stuttgart
Germany
[*] 2018