Privacy Policy
Introduction
Welcome to CCG Hong Kong Limited (“CCG Hong Kong”)’s privacy policy.
CCG Hong Kong respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important Information and Who We Are
2. The Data We Collect About You
3. How Is Your Personal Data Collected
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
1. Important Information and Who We Are
Purpose of this privacy policy
This privacy policy is provided by CCG Hong Kong in accordance with the Personal Data (Privacy) Ordinance of Hong Kong. It aims to give you information on how CCG Hong Kong collects and processes your personal data when you become a member, when you use our services and when you use this website.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.
Controller
CCG Hong Kong Limited acts as a data controller/data user and responsible for your personal data (referred to as "CCG Hong Kong", "we", "us" or "our" in this privacy policy).
Changes to the privacy policy and your duty to inform us of changes
This version was last updated on the “Revised Date” at the bottom.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that individual can be directly or indirectly identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, membership number or similar identifier, title, date of birth and (for Authorized Dealer applicants) affiliated organizations and official capacities held.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, the level of your membership, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- User Contribution Data includes information about you and which is posted on message boards, chat rooms or other message areas, the NGC Registry, PMG Registry or CGC Registry or in feedback.
- Verification Data (for Authorized Dealer applicants) includes details of any existing or past bankruptcy, insolvency or receivership proceedings, complaints filed with courts or other authorities against your business, or criminal offences and convictions held by you or your organisation’s principals, shareholders, directors, officers, members, managers or employees.
- Referee Data (for Authorized Dealer applicants) includes name, address, phone number and affiliated companies of any nominated referees.
- Aggregated Data includes statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, when you apply to become a member or to use our services). In this case, we may not be able to accept your application for membership or to provide you with our services but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected
We use different methods to collect data from and about you including through:
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Direct interactions. You may give us your Identity, Contact, Verification and Financial Data by filling in forms (for example our Membership or Submission Forms) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to become a member;
- submit any items to us
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
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Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
-
Technical Data from the following parties:
(a) analytics providers such as Google based outside Hong Kong; - Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Authorize.net based outside Hong Kong.
- Identity and Contact Data from publicly availably sources such as Companies Registry and the Land Registry based inside Hong Kong.
- Identity and Contact Data from the CCG Companies based outside of Hong Kong.
- User Contribution Data from other members or users of our website based both inside and outside of Hong Kong.
- Referee Data from applicants for our Authorized Dealer membership who nominate you as a reference on their application form.
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Technical Data from the following parties:
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to collect outstanding fees from you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To process your application to become a member and to register you as a new member |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for the administration of our business) |
|
To process and fulfil your submissions and orders including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Verification (g) Referee (in respect to referees nominated by Authorized Dealer applicants) |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary to comply with a legal obligation |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To provide you with website features and functionality such as message boards, chat rooms or other message areas or the ability to leave feedback for other users. |
(a) Identity (b) Profile (c) User Contributions |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (for the administration of our website) |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To provide your personal data to our auditors, our insurers, our bankers or our legal advisors inside and or outside Hong Kong for accounting or compliance purposes | All data as specified in section 2 above | (a) Necessary for our legitimate interests (b) Necessary to comply with the legal obligation where this is required or permitted by law, regulation or an order from the court |
| To provide your personal data where this is required or permitted by law, regulation or an order from the court. | All data as specified in section 2 above | Necessary to comply with the legal obligation where this is required or permitted by law, regulation or an order from the court |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
You will receive marketing communications from us if you have requested information from us, are or have applied to be a member or have purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Promotional offers from third parties sent by us
We may send promotional offers from third parties to you if you have provided your express opt-in consent for these marketing communications. These emails are sent by us on behalf of third parties and none of your personal data is shared with any company outside the CCG Companies for these marketing purposes.
By accepting the terms of this agreement, you have explicitly given your consents for us to use your personal data for direct marketing purposes including but not limited to promotional offers from us and from third parties sent by us.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your membership with us, a submission or a product/service purchase.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is directly related with the original purpose. If you wish to get an explanation as to how the processing of your personal data for another reason is directly related with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Except as stated in this privacy policy or with your prior consent, we will not transfer or disclose your personal data to any other third party. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
At times it may be necessary and prudent for us to transfer and share your personal data with the CCG Companies or offices affiliated to us outside Hong Kong in order to carry out the purposes, or directly related purposes, for which the personal data were collected. This will involve transferring your data outside Hong Kong. Where such a transfer is performed, it will be done in compliance with the law.
Many of our external third parties are based outside Hong Kong so their processing of your personal data for the purposes or directly related purposes for which the personal data were collected will involve a transfer of data outside Hong Kong. Where such a transfer is performed, it will be done in compliance with the law.
By accepting the terms of this agreement, you have explicitly given your consents for us to use, store, disclose and transfer your personal data (whether within or outside the jurisdiction of Hong Kong and whether within or outside the CCG Companies).
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our members and customers for seven years after they cease being customers for tax purposes.
9. Your Legal Rights
Under and in accordance with the terms of the Personal Day (Privacy) Ordinance of Hong Kong and guidelines issued pursuant thereto, any individual may:
i. check whether we hold personal data about him/her and may request access to such personal data;
ii. request us to correct any personal data relating to him/her which are inaccurate;
iii. request us to specify the policies and practices in relation to personal data and to be informed of the kind of personal data held by us; and
iv. request us to cease using his/her personal data for marketing purposes.
Any such request shall be made to us in writing to the address or email address provided below. In accordance with the law, we have the right to charge a reasonable fee for processing any such request.
Email address: data@PMGnotes.hk
Postal address: 1208-10, 12/F, The Gateway, Tower 1, Harbour City, Kowloon, Hong Kong
Fees
In accordance with the provisions of the Personal Day (Privacy) Ordinance of Hong Kong, we have the right to charge a reasonable fee for the processing of any data access request.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Nothing in this Privacy Policy shall limit your rights as a data subject under the Personal Data (Privacy) Ordinance.
10. Protection Measures
CCG Hong Kong takes appropriate steps to protect the personal data we hold against loss, unauthorised access, use, modification or disclosure. We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Personal Data (Privacy) Ordinance of Hong Kong with respect to the management of personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations.
CCG Hong Kong may, where such disclosure or transfer is necessary to satisfy the purpose, or directly related purpose, for which the data was collected provide such information or copies to the relevant parties including authorized personnel, government bodies and other regulators as required under the law or pursuant to any regulatory arrangements or any person to whom we are required to make disclosure under any law applicable in Hong Kong.
11. Glossary
CCG Companies means our affiliated companies within the Certified Collectibles Group of companies including without limitation, Provenance NGC LLC d/b/a Numismatic Guaranty Company (“NGC”), a Florida, USA, limited liability company; Numismatic Conservation Services, LLC (“NCS”), a Florida, USA, limited liability company; Paper Money Guaranty, LLC (“PMG”), a Florida, USA, limited liability company; Certified Guaranty Company, LLC (“CGC”), a Florida, USA, limited liability company; Certified Sports Guaranty, LLC (“CSG”); a Florida, USA, limited liability company; Authenticated Stamp Guaranty, LLC (“ASG”), a Florida, USA, limited liability company; Collectibles Authentication Guaranty, LLC (“CAG”), a Florida, USA, limited liability company; and Certified Collectibles Group, LLC (“CCG”), a Florida, USA, limited liability company.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
The CCG Companies acting as processors or joint controllers based outside Hong Kong who assist us with the performance of services to you and with the running of our business.
External Third Parties
- Service providers acting as processors based outside of Hong Kong who provide direct marketing services on our behalf.
- Payment providers acting as processors based outside of Hong Kong who provide payment services on our behalf.
- Service providers such as that enable us to operate message boards and chat rooms.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Hong Kong and outside of Hong Kong who provide consultancy, banking, legal, insurance and accounting services.
- Inland Revenue Department, regulators and other authorities acting as processors or joint controllers based in Hong Kong who require reporting of processing activities in certain circumstances.
For a list of all External Third Parties acting as processors for us, click here.
Revised: 03/29/2019