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Privacy policy

This Policy sets out the policies and practices of Hong Kong Cyberport Management Company Limited and all subsidiaries of which it forms part (“Cyberport” or “We”) in relation to the handling of personal data in respect of or collected through the platform of iTalent.

We collect and use personal data in the Hong Kong Special Administrative Region (“Hong Kong”) and this Policy is formulated in accordance with the applicable laws of Hong Kong.

1. Statement of Notice

We respect privacy. Cyberport is committed to complying with all applicable personal data privacy laws and regulations.

When we collect and process personal data, we will ensure that there is legal basis for us to do so – including but not limited to issuing a Privacy Notice and/or fulfilling any other requirements as provided under all applicable laws.

2. Statement of Practice

Kinds of Personal Data Collected

We collect personal data in five broad categories as set out below (the “Categories of Personal Data”):

  • Data collected through subscription services, which include the personal information of the subscribers of our publications, job alert services and any other subscription-based products or services (the “Subscription Records”).
  • Data of individuals, which include job applicants and our employees’ personal information (the “Personnel Records”).
  • Data of event attendees, which include the personal information provided by the attendees of our events such as conferences, promotion or charity activities (the “Event Attendees Records”).
  • Personal data collected in our operations, which include the personal data of such data subjects involved in news gathering, security checks, cleaning, maintenance services, consultancy, technology, auditing, supplier, service provider, licensor and other data subjects providing services in relation to all aspects of our operations (the “Other Operational Records”).
  • Data collected on/from our web servers from persons who visited our webs and media properties, which include, but are not limited to, the email addresses, location data and other online identifiers such as IP addresses of such data subjects who visit our websites and platforms (the “Web Servers and Public View Records”).


  • Subscription Records are collected and processed for the purposes of: (i) provision of subscription, job alert orders and any other subscription based products or services; (ii) billing and payment (if applicable); and (iii) conducting market research for statistical purposes.
  • Personnel Records are collected and processed for the purposes of: (i) recruitment; and (ii) human resources management and employment related activities such as employment benefits, termination, performance appraisal, and discipline.
  • Event Attendees Records are collected and processed for the purposes of: (i) organising and managing the relevant events; and (ii) running the related competitions, prize drawings, and promotions.
  • Other Operational Records are collected and processed for the purposes of facilitating the effective operation of our business, such as news gathering, security, maintenance, consultancy, technology, auditing, supplier, service provider, licensor, and other data subjects providing services in relation to all aspects of our operations.
  • Web Servers and Public View Records are collected and kept for the purposes of: (i) providing and/or improving on the news, information and related services to you; and (ii) keeping abreast of and analysing the latest trends in the global media landscape.
  • Other purposes and uses of your data:
    • providing updates, services, products, facilities or activities (including our website) and matters relating to administration, management, operation and maintenance (including processing applications or requests for services, products, facilities or activities);
    • communicating with you (including responding to your enquiries or requests for information);
    • designing and offering contests, games, lucky draws, promotions, surveys or events;
    • marketing services, products, facilities, activities or other subjects (please see further details in “Direct Marketing” section below and you may opt out from receiving marketing information);
    • offering, managing and operating any membership, loyalty or reward programmes;
    • administering and maintaining our website and diagnosing problems where necessary;
    • designing, reviewing, evaluating and enhancing our services, products, facilities or activities (including conducting research, survey and analysis for those purposes);
    • investigating and handling complaints, claims or incidents involving us or any of our customers, visitors or website users;
    • preventing, detecting or investigating suspicious or illegal activities;
    • making disclosure when required by any law, court order, direction, code or guideline applicable in or outside Hong Kong; and
    • purposes relating to any of the above.


All processing of personal data shall be conducted according to the data protection principles as follows:

  • Personal data shall be processed lawfully, fairly and transparently.
  • Personal data shall only be collected for specific and legitimate purposes.
  • Personal data shall be relevant and limited to what is necessary for processing.
  • Personal data shall be accurate and kept up to date by taking all practicable steps to erase or correct.
  • Personal data shall be kept in form such that the data subject can only be identified if it is necessary for processing.
  • Personal data shall be processed in a manner that ensures the appropraite security.


We have also kept a data inventory and data flow process to determine various aspects of our data processing, including:

  • Business processes that use personal data.
  • Purposes for collecting and/or using the personal data.
  • Source of personal data.
  • Processing activities.
  • Any data transfer, and to whom.
  • Any data access, correction or opt-out request.

Such data inventory would facilitate Cyberport in tracking its data and the related processing activities, and put us in a better position to comply with the relevant privacy and other laws and regulations.


We ensure that there is a legal basis for our collection and processing of personal data.

Such legal bases include: (i) legitimate interests of Cyberport in processing personal data; (ii) compliance with applicable laws or regulations, after having sought your specific consent to process such personal data; and/or (iii) any other relevant basis under applicable laws and regulations.

Legitimate Interests

If Cyberport processes personal data under the "legitimate interests" legal basis, it means that the processing of the personal data is necessary for the legitimate interest pursued by Cyberport, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires the protection of personal data.

Legitimate Interests Assessment

In each relevant situation, we assess: (i) what these legitimate interests are; (ii) whether it is necessary to process such data to attain the objective; and (iii) the relevant rights of the data subjects. We will then balance such rights against our interests in achieving such objective, and ensure that such rights do not override Cyberport’s legitimate interests before we conclude that Cyberport can process the personal data on the basis of legitimate interests.


All data subjects will be informed of our collection of their personal data, the Categories of Personal Data concerned and the purpose of processing. This is to ensure that the data subjects are clear about our collection and processing of personal data and such collection and processing are within the data subjects’ reasonable expectations. Please be informed that all data subjects can object to our collection and processing of their personal data at any time, in addition to their rights of requesting for accessing and/or correcting their personal data in our possession.


We have also implemented appropriate mechanisms, policies and procedures to protect the confidentiality and security of the personal data that we collect and process, as we respect the privacy and related rights of the data subjects relating to such personal data by reducing the risks or potential negative impact of processing, including, but not limited to, data minimisation, de-identification, encryption, restricted access and all other technical security methods and efforts to protect personal data. Such protection of the privacy and related rights of the data subjects would enable Cyberport to process personal data under the legitimate interest legal basis.


Cyberport uses personal data for direct marketing purposes unless the data subject explicitly objects or such is otherwise specifically prohibited under applicable laws.

  • Insurance, banking and financial products and services;
  • Products and services relating to airlines, hotel, health club, travel and hospitality;
  • Beauty, skin care, health, medical devices, biotechnology, pharmacy and wellness;
  • Eyewear and optical, fashion, sports, sports events, sports clubs, watches and jewellery, flower shop, stationery, toys, department stores and shopping malls;
  • IT, electronic goods and electrical appliances, mobile phones and accessories, telecommunications and media products and services;
  • Food and beverages and restaurants;
  • Design, automotive, education, antique and auction, arts and gallery, boat and accessories, services for children, real property, construction, furniture and household items, interior design, consular services, trade or industry associations, non-governmental organisations, government services, energy, events and exhibitions, personal announcements, pets and accessories, post and courier services, public utilities, professional services, career, security services, shopping, transportation and logistics.

Our use of personal data for direct marketing is subject to the consent of the data subjects in this regard. You may also exercise your opt-out right at any time. We will cease using your personal data in direct marketing once we receive your notification indicating your objection to receive any direct marketing materials from us. Please also refer to the "Consent" section below for more information.


Personal data may be provided or transferred in the following circumstances as we may consider necessary whether the recipients are inside or outside of Hong Kong:

  • to any agent, contractor or service provider of Cyberport for a purpose that is not inconsistent with the purposes for which the personal data was collected.
  • to any partner that offers any services jointly with Cyberport on the platform of iTalent.
  • to the media, to the extent that the purpose of such transfer is not inconsistent with the purposes for which the personal data was collected.
  • to any person to whom Cyberport is under an obligation or is otherwise expected to make disclosure according to any law and regulations applicable to Cyberport, including for the purposes of detecting, preventing and/or addressing fraud and other illegal activities or of preventing any injuries, damages or losses to any persons.


Where relevant legal requirement demands that specific consent of the data subject must be obtained before we can process personal data in a certain way, such as conducting direct marketing, we will ensure that such specific and explicit consent will be obtained and that the data subject is fully aware of the types of the personal data that we intend to use, the purposes of such usage (such as improving our services to the data subject or direct marketing) and, if we intend to transfer the data, the name/identity of the transferee and how the transferee shall use the data subject’s personal data.


Cookies are data files stored on your device. Our website automatically installs and uses cookies on your browser when you access it. We use cookies to give you a better browsing experience on our website.

Two general types of cookies are used on our website:

Session Cookies: temporary cookies are only used during a visit to our website and will be deleted at the end of each visit. Session cookies are used to compile anonymous statistics about the use of our website.

Persistent Cookies: persistent cookies remain in your browser for a longer period of time for the purpose of compiling anonymous statistics about the use of our website and/or tracking and recording your preferences.

You may refuse to accept cookies by modifying the settings feature of your browser or internet security software. However, if you do so you may not be able to utilise or activate some of the features and/or functions of our website.


Cyberport acknowledges that data subjects have certain rights about the data processing and the data which is recorded about them under the applicable laws and regulations, and we will take all practicable steps to ensure that these rights are respected and exercisable in respect of the data kept by Cyberport.


Cyberport uses internal resources to develop and maintain its IT systems and also engages third-party vendors to provide certain services relating to its IT systems. Your personal data may also be stored by third parties, via cloud services or other technology, with whom Cyberport has contracted. Such vendors and third parties will only have access to the personal data collected for purposes that are not inconsistent with the purposes for which the personal data was collected, including cloud storage and retrieval.

In case where any vendor or third party stores or has access to any personal data, Cyberport uses reasonable measures to ensure that: (i) such vendor is contractually bound to keep such personal data confidential and adopt appropriate means to prevent any unauthorised access, use, loss, retention, modification, transfer or otherwise.


We implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which they were collected. Different retention periods apply to various types of personal data that we hold, depending on the respective data collection/usage purpose and relevant legal requirements.


We have appointed a Data Protection Officer whose responsibilities include the following:

  • To inform and advise Cyberport and its employees of their obligations pursuant to the applicable laws and regulations concerning personal data;
  • To monitor Cyberport’s compliance with such laws and regulations;
  • To co-operate with the supervisory authority (e.g. the privacy commissioner or equivalent bodies); and
  • To act as the point of contact for the supervisory authority on issues regarding the data processing and related matters.


You have the right to know whether Cyberport holds your personal data, access the data and/or correct any inaccuracies of such data. You also have the right to make reasonable inquiries about Cyberport’s personal data policies and procedures. You have the right to object to the processing of your personal data or withdraw your consent (if applicable) at any time. Please note however that if you object to the processing of your personal data, it may affect Cyberport’s ability to provide the services that you required to you or may affect the quality of such services. If you withdraw your consent (if applicable), Cyberport will stop providing such services to you which applicable laws require specific consent.

All of the above requests should be made in writing to our Data Protection Officer at [] or via mail to [Level 6, Cyberport 2, 100 Cyberport Road, Hong Kong].

A reasonable fee may be charged in light of the administrative costs that Cyberport shall incur in addressing your request(s).


Third party vendors, such as Google, may use cookies to serve ads based on a user's prior visits to our website or other websites.

Such use of advertising cookies enables these third party vendors and their partners to serve ads to you based on your visit to our website and/or other sites on the Internet.

Users may opt out of personalized advertising at their own discretion.


We keep our Privacy Policy under regular review, and reserve the right to amend it from time to time as appropriate by posting an updated version on our website.


The other provisions of Cyberport’s General Privacy Policy Statement shall apply to the platform of iTalent to the extent that they are consistent with the policies set out herein.

This Policy was last updated on [21 April 2021].