1. Introduction

1.1 Rethink Legal (“we”, “us”, “our”) is committed to protecting the privacy and security of personal information provided to us in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (”PDPO”). This includes personal information provided to us by clients and potential clients in the course of providing our services and people visiting our website at https://www.rethinklegal.com.hk (“Website”).  Our Website is under the direct control of Rethink Legal and may use ‘cookies’. Rethink Legal is the trading name of EMS Legal Solutions Limited a company incorporated in Hong Kong.   

1.2 Information provided to us constitutes personal data if it relates directly or indirectly to you and it either identifies you or can be used to do so.

1.3 The purpose of this privacy policy (“Policy”) is to inform you as to how we collect, use and store personal data as well as your rights in relation to the data that you provide to us.   

2. Personal data collection 

Your personal data shall be collected for lawful purposes only. Your personal data will be used for specific purposes stipulated in our Personal Information Collection Statement (“PICS”) (see below). You are entitled to withdraw your consent to this use, at any time, by giving us written notice.

3. Direct marketing 

Our use of your personal data for direct marketing (which includes business promotion) is subject to your consent. We will not sell or rent your personal data to any third party.  If you wish to unsubscribe from our mailing list, please send an email to this effect to contact@rethinklegal.com.hk.

4. Personal data retention

We will take reasonable steps to ensure that your personal data is retained only for as long as is reasonably necessary for the specific purpose(s) for which it was obtained and in accordance with the law. After that time, unless prohibited by law or some other limitation in the public interest, your data will be deleted.

5. Disclosure & security

We will undertake practicable measures, both technical and organisational, to hold your personal data and to prevent unauthorised use or access, processing, loss, and/or disclosure. Your personal data shall be used and disclosed only in accordance with our PICS.

6. Access & correction

You are entitled, in accordance with the PDPO, to have access to and correction of your personal data. Requests for access to or to correct personal data should be addressed to Ellie Patel at ellie@rethinklegal.com.hk. The PDPO entitles us to charge a reasonable fee for processing any data access or correction requests and, in appropriate cases, refuse such requests stipulating the reason for such refusal. 

7. Personal data (privacy) ordinance (PDPO)

You may wish to visit the official website of the Office of the Privacy Commission (https://www.pcpd.org.hk/) and Hong Kong e-Legislation (https://www.elegislation.gov.hk/) for more information about the PDPO.

Personal information collection statememnt (“PICS”)

This PICS sets out the purposes for which your personal data will be used after collection. You may be required to provide personal information to us when you use our services in the capacity of a client (or potential client), a user of our Website and other online services. We may use cookies on our Website.

1. How we collect personal information

The PICS applies to information we collect about you directly or indirectly whether through you or third parties. This may include the following situations:-

a. when you visit our Website;

b. when you subscribe to our mailing list or use our other online services or attend our events;

c. when you make enquires about our services or people;

d. when you are a potential client, a client or associated with our client(s) in the capacity of director, other officer, employee, staff member, authorised representative or other agents;

e. in the course of providing legal support to you;

f. in the course of managing our business activities; and/or

g. as and when required by law.

2. What we collect and why

We may collect personal information about you directly from you and/or from other sources including our clients (and their authorised representatives) and/or their counterparties. Information that we collect may include the following:

a. Identity:
We may collect information regarding your name, former names, contact details such as email address, contact number(s), postal and residential address, business address, occupation, nationality, gender, special information such as marital status, race, ethnicity, health related information, and documents in order to ascertain such information.

b. Business information:
We may collect information regarding your business interests, purpose of your business transactions, work permits, information regarding your business associates (such as affiliated companies, partnerships, directors, shareholders, authorised representatives).

c. Accounts:
We may collect information such as bank account details, billing address, information required for processing payments, source of funds etc.

d. Compliance:
We may collect all such information as required by law from time to time particularly information in relation to your identity and all information required for fulfilling obligations under the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (Cap. 615).

e. Information in the public domain
We may collect information about you that is publicly available including but not limited to information from third parties such as government agencies, regulatory bodies, information service providers, credit reporting agencies and social media platforms.

3. Scope of use

3.1 We may use your personal information for the following purposes:

a. to fulfil our legal, regulatory and risk management obligations, including establishing, exercising, or defending legal rights;

b. when it is necessary for our legitimate interests or a third party’s legitimate interests subject to your fundamental rights. Legitimate interests include using your information:

(i) for providing legal support to you;

(ii) for promoting our business;

(iii) for the functioning of our business and its operations;

(iv) for reasons required by applicable law;

(V) for development and improvement of the services we provide;

(vi) to manage and administer our relationship with you and/or your representatives;

(vii) if you have already made that information public;

(viii) if you have given your consent where necessary; and/or

(viii) your personal information is necessary for the abovementioned purposes and we may not be able to carry out any or all of the purposes unless we receive and use your personal information.

3.2 Your name and contact details may be used for promoting our business. You have the right to ask us, at any time, not to use your personal data for marketing purposes. You can exercise such right by sending an email stating this to ellie@rethinklegal.com.hk.

4. Operation

a. We hold your personal information for as long as necessary and in accordance with law.

b. We take appropriate technical and organisational measures to hold your personal data and to prevent unauthorised access, modification or disclosure. However, your data may be disclosed to and used by the following third parties:-

(i) government agencies, courts, tribunals, regulatory authorities and law enforcement agencies, as required and permitted by the applicable law and regulations;

(ii) our professional advisors, auditors, insurers, banks, and information technology service providers;

(iii) third parties to whom we outsource certain services, including, but not limited to, translation, printing, transcription, document review, parties involved in hosting or organising events, debt collection agencies;

(iv) third parties who are engaged in connection to the services we provide to you, including, but not limited to, barristers, trade mark attorneys, experts, investigation service providers; and

(v) our business partners.

c. In accordance with the terms of the PDPO and guidelines issued pursuant thereto, either you or any relevant person on your behalf may:

(i) make a request to ascertain whether Re-think Legal holds personal data about you and may request access to such data;

(ii) request Re-think Legal to correct any data relating to you which is inaccurate; and

(iii) request Re-think Legal to cease using the relevant personal data for its marketing purposes.

d. In accordance with the terms of the PDPO, Re-think Legal has the right to charge a reasonable fee for the processing of any data access request.

e. Re-think Legal reserves the right to reasonably refuse to comply with data access request where permitted or required by law.

f. If you need further information or have any questions or requests regarding Re-think Legal’s privacy policy or PICS, please write to:

Ellie Patel
Re-think Legal
21/f Hing Yip Commercial Centre
272-284 Des Voeux Road
Central
Hong Kong
Email: ellie@rethinklegal.com.hk