This policy statement provides information on the obligations and policies of the subsidiaries, affiliates, and associated companies of Golden Resources Development Limited (hereinafter collectively referred to as the “Company”) under the Hong Kong SAR Personal Data (Privacy) Ordinance Cap.486 (the “Ordinance”). Although this policy specifically addresses the Company’s obligations in respect of the laws of the Hong Kong SAR, the Company believes the principles embedded in the Ordinance are equal to any in the world in respect of the protections they provide to an individual. As such, the Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations globally. Where the Company’s operations are subject to privacy legislation other than that of Hong Kong SAR, then this policy shall be applied so far as practicable and consistent with such local legislation. Throughout this policy, our use of the term “personal data” has the meaning ascribed to it by the Ordinance.


The Company shall fully comply with the obligations and requirements of the Ordinance. The Company’s officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company. The Company shall endeavor to ensure all collection and/or storage and/or transmission and/or usage of personal data by the Company shall be done in accordance with the obligations and requirements of the Ordinance. Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in accordance with the times and manner stipulated within the Ordinance.


Types of Personal Data Collected

For the purpose of carrying on the Company’s business, including registration and administration of the Company’s web site and related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:

a. Your name;
b. Contact details, including contact name and telephone number or email address.
In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalized service, or provision of a product is dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:
a. Your age;
b. Gender;
c. Salary range;
d. Education and profession;
e. Hobbies and leisure activities;
f. Other related products and services subscribed to; and
g. Family and household demographics.
The Company’s Web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server’s usage so that we may better meet the demands and expectations of visitors to our sites. This type of data may include, but is not limited to:

a. The browser type and version;
b. Operating system; and
c. The IP address and/or domain name.

Use of Cookies

When you browse the Company’s website(s), the Company will record your visit only and will not collect any personally identifiable information from you unless otherwise stated. Cookies used (if any) in any part of our website(s) will not be deployed for collecting personally identifiable information. For your information, Cookies are computer files which will be stored in web surfer’s computer for the purposes of obtaining configuration information and analyzing web surfers’ viewer habits. They can save you from registering again when re-visiting a web site and are commonly used to track your preferences in relation to the subject matter of the website. You have a choice not to accept the Cookies, but to do so you may be unable to utilize or activate certain available functions in the Company’s website(s).

Use of Personal Data

The personal data provided by you to the Company may be used for the following purposes (“Purposes”):

a. Registration of membership in the Company’s website(s) in order to utilize and/or activate certain functions of the website(s);
b. Providing and delivering to you the products/services which you order, subscribe or request and communicating with you regarding the products/services concerned;
c. Carrying on the Company’s business, including registration and administration of the Company’s website(s);
d. Carrying out data sorting and analysis to enable the Company to better understand your characteristics and buying behavior and to provide other services better tailored to your needs; and to assist the Company in selecting products and services which are likely to be of interest to you;
e. Aggregated customer behavioral analysis, and any other analysis, research or study on any product/service of the Company;
f. Direct marketing to you in respect of Golden Resources products and for distribution of Golden Resources newsletter (if any);
g. Any other normal administration, management, operation and maintenance of the Company’s product/service/website(s); and
h. As required by law.

Retention of Personal Data

The Company will destroy any personal data it may hold in accordance with its internal retention policy. The policy states that:

a. Personal data will only be retained for as long as is necessary to fulfil the Purposes for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
b. Personal data are purged from the Company’s electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company’s internal procedures.

Disclosure of Personal Data

All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the Purposes, provide such information to the following parties:

a. Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;
b. Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the Purposes;
c. Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
d. Any person or persons that have a right under the Ordinance to gain access to such information provided they are able to prove their authority to access such information; and
e. Any party as ordered by court or competent authority. For example, if the Company were served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.

Security of Personal Data

Physical records containing personal data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a “need to know” basis that is commensurate with an individual’s Company responsibilities and their training. Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate and complies with the Ordinance. Audit records may be produced to validate data modifications in order to verify the data’s integrity. There may be violations logging processes for investigation of any unauthorized attempt to access information. Encryption technology, such as SSL, may be employed for the transmission of data collected online.

Access and Correction of Personal Data

Under the terms of the Ordinance, individuals have the right to:

a. Check whether the Company holds any personal data relating to them and, if so, obtain copies of such data;
b. Require the Company to correct any personal data relating to them which is inaccurate for the purpose for which it is being used; and
c. Ascertain the Company’s policies and practices in relation to personal data, which are those policies and practices set out in their entirety herein.

An individual may exercise his or her right of access by checking it online with assigned password and login name. The Company will, upon satisfying itself of the authenticity and validity of the access request, make every endeavor to comply with and respond to the request within the period set by the Ordinance. An individual may exercise their right of correction by login to personal data update with assigned password and login name. The Company will, upon satisfying itself of the authenticity and validity of the correction request, make every endeavor to comply with and respond to the request within the period set by the Ordinance.


In accordance with the requirements of the Ordinance, the Company will honor an individual’s request not to use his or her personal data for the purposes of direct marketing. The Company will not use or provide personal data to any person for use in direct marking without your consent or indication of no objection. Even you have indicated consent, you still have right to opt out from receiving direct marketing materials from us at any time. Should you wish to change your indication to receive or not to receive direct marketing material from the Company, please email to, or adjust your email preferences or unsubscribe via the link in the newsletters. (If there is any discrepancy/inconsistency between the English and Chinese version, the English version shall prevail.)