25th May 2017
This document comprises the Privacy Statement (“Statement”) of Binumi Agency (Hong Kong) Limited (“Binumi”, “we”, “us” or “our”). In providing our Service we are necessarily dealing with private information and this Statement sets out our policy for how we deal with subscriber and user data.
To make the information in this Statement easy to understand, we have highlighted different occasions when we could potentially collect personal information from you, when we do this and how this information may be used. These instances are broken down into the following sections:
- the legal bases on which we rely to process personal information
- the types of personal subscriber and user information we collect from you, either directly or indirectly,
- how and when this is done,
- how we may use this information,
- who we may share it with; and
- the steps we take to ensure data belonging to, or relating to, our subscribers and our users is safeguarded.
Personal information is any information that can be used to identify you or that we can link to you. The Statement also elaborates on the choices you can make about the data we collect, and how you can control these decisions.
The prime purpose of collecting personal data is to improve your experience of using our Service and so that we can provide you with support.
- At Binumi, as a fundamental guiding principle, we respect the privacy of your data and take your privacy rights very seriously. This Statement explains, in simple terms, how we collect and use subscriber and user data as part of our Service. This Statement is specific to subscriber and user data and is distinct from the way we protect the privacy of casual visitors to our website who may not be users of our Service.
- The data we collect and use is limited to the purpose for which our subscribers expressly subscribe to our Service and for the limited other purposes specified in this Statement.
- Our objective in collection of data is focused on servicing our subscribers' and our users’ requirements and in providing them with the benefits associated with the Service we provide
- This Statement is incorporated into and comprises part of the Standard Terms and Conditions for use of our Service which can be accessed on this website (Our Website).
- All capitalised expressions used in this Statement and not otherwise defined shall have the meanings ascribed to them in the Standard Terms and Conditions for use of our Service.
2. The Legal Bases we Rely upon for Processing Personal Information
There are different lawful bases that we rely on to use your personal information, namely:
Performance of a contract
The use of your personal information may be necessary to perform the agreement you have with us including the provision of our Service to you, to register and maintain your account, to help with service issues or to respond to your requests.
We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyse and improve our Service and the content available via the our Website and app, to send you notifications about software updates or information about our Service or for administrative, fraud detection or other legitimate purposes.
Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you, you may exercise your right to object by sending an email to email@example.com
3. Data Collection
In providing our Service we collect and retain certain information about our subscribers and the other users of our Service. This information can be categorised in one of two ways:
- Personally identifiable Information about our subscribers (Your Data)This means any information about our subscribers and our users from which they may be personally identified including their name, address, email address, telephone number, profession, credit card details and any other information which may be disclosed to us through use of our Service.
- Non-personally identifiable informationThis means information about subscribers and others users of our Service of a non identifiable nature collected by internet technologies we use to track delivery and improve the effectiveness of our Service.
We do not collect any personally identifiable information with the exception of that which is volunteered by subscribers and users in order to deliver our Service. For example we will request an email address in order to respond to support requests or to communicate with you.
4. How Do We Collect Data
5. When Do We Collect Your Data
We collect Your Data from you when you
- register to use our Service;
- when you post material on our Service;
- when you register to participate in seminars, tutorials, or competitions available via our Service;
- make a complaint or enquiry or provide other feedback to us; or
- otherwise disclose Your Data to us through our Service or otherwise at any time.
6. How Do We Use You Data
We use Your Data to:
- help us provide our Service;
- process and complete subscriptions including the administration of payments which you make via our Website;
- confirm and investigate any transactions or transfers of monies that may occur in respect of any subscription you make;
- process and deal with any complaints or enquiries made by you;
- monitor, develop, run, provide and improve the Service;
- ensure the Service is presented in the most effective manner for you and your computer;
- notify you about changes to the Service;
- (in accordance with your preferences) send you information by email about the Service;
- (in accordance with your marketing preferences), pass Your Data to third parties for marketing purposes if you have authorised us to do so.
You can change your mind and choose to receive or not to receive communications from us or any third party who you consented may contact you at any time by using the relevant unsubscribe link which we include in each email or by sending us an email – see “How to Contact Us” below
We will not keep Your Data for any longer than is necessary for the purposes of providing our Service.
7. Will We Share Your Information With Third Parties?
We will never sell or pass on Your Data to third parties for marketing or any other purposes without your consent.
We only pass on Your Data to third parties as follows:
- we may pass Your Data to our employees, agents, subcontractors and partner organisations to help operate our Service, take payments and provide relevant information to you;
- Your Data may be transferred to a successor company or other organisation in the event of a sale of our business or in the event we are placed into administration (but you will be notified and offered the chance to unsubscribe if this occurs);
- in some cases we may use a technical partner to conduct some processing of Your Data on our behalf, but this will always be subject to strict contractual control and in compliance with relevant data protection legislation;
- if, and only if, you have given your consent for such purpose, we may pass Your Data to third parties so that they can send you information about services and information which may be of interest to you; and
In addition, some general statistical information about our user base may be passed on to reputable third parties for research purposes but these details will never include information personally identifying you.
If you post any information, including any of Your Data, on the public wall within the Binumi Service, this will be generally available to all users of the Binumi Service. If you do not want any of Your Data or any other information to be passed on to third parties you should not post this on the public wall and Binumi shall have no liability to you to the extent you post any information on the public wall and this information is passed on to third parties by any other user.
You can change your mind about the passing of Your Data to third parties at any time by updating your marketing preferences – see “Your Rights and How to Contact” us below.
8. How Do We Protect Your Information?
- SecurityWe will take all reasonable steps to protect Your Data. All the data collected by us is and will at all times be stored on a secure server. Your browser will encrypt all sensitive information (including payment details) which you input before it is sent to us. It is, however, an inescapable fact that the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of Your Data transmitted to our Website and any transmission is at your own risk. Once we have received Your Data, we will, however, use strict procedures and security features to try to minimise the likelihood of any unauthorised access.
- StorageYour Data collected by Binumi may be stored and processed in your region or in any other country where Binumi or its affiliates, subsidiaries or service providers are located or maintain facilities. Binumi has put in place adequate mechanisms to protect Your Data when it is transferred internationally.
- RetentionBinumi will retain Your Data for as long as we deem it necessary to enable you to use our WEbsite and as is necessary to our service Service to you, to comply with applicable laws (including those regarding document retention), to resolve disputes with any parties and otherwise as necessary to allow us lawfully to conduct our business. All of Your Data that we retain will be subject to this Privacy Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process, please send an email to firstname.lastname@example.org
- Third Party SitesPlease be aware that our Service contains links to other websites which may be accessed by you. We are not responsible for the privacy policies, content or security of those other websites should you utilise any of these links.We do not store any credit card numbers entered into our Website or payment systems.
9. Your Rights, Complaints and How To Contact Us
- Your RightsWe want you to be in control of how Your Data is used by us. You can do this in the following ways:
If we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or in the public interest, you have the right to object at any time to that use of your personal information.We rely on you to ensure that Your Data is complete, accurate and up to date. Please do inform us promptly of any changes or inaccuracies by contacting email@example.comIf you wish to access, edit or remove profile information, change your password, close your account or request deletion of your personal data, you can do so by sending an email to firstname.lastname@example.orgWe will respond to any request to access or delete your data as soon as possible, and in any event, within 30 days.
- you have the right to request a copy of Your Data at any time;
- you can inform us of any changes to Your Data, or if you want us to correct any of Your Data we hold about you;
- in certain situations, you can ask us to erase, block or restrict Your Data, or object to particular ways in which we are using Your Data; and
- in certain situations, you can also ask us to send Your Data to a third party.
- ComplaintsWe are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to file a complaint with the data protection authority in your country (if one exists in your country) or with any other relevant supervisory authority.
INFORMATION ABOUT US
We are Binumi Agency (Hong Kong) Limited, a company registered in Hong Kong with company number 640440). Our registered address is at Room 2103, Futura Plaza, 111 How Ming Street, Kwun Tong, Hong Kong, Hong Kong.
Anti-bribery and Anti-corruption Policy Statement
25th May 2017
1. Policy Statement
1.1 Binumi Agency (Hong Kong) Limited (Binumi) is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on Binumi's behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.
1.2 We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
1.3 The purpose of this policy statement is to:
- set out our responsibilities, and of those working or providing services for us, (which for the purpose of this statement includes our service providers), in observing and upholding our position on bribery and corruption;
- provide information and guidance as to how we expect those working for us to conduct themselves and how to recognise and deal with bribery and corruption issues; and
- set out how to raise concerns with us including in relation to any perceived breaches of this policy statement
1.4 Binumi is committed to implementing and enforcing effective anti-bribery and anti-corruption systems throughout the company.
2. What is bribery?
A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. This can exist in the context of both giving and receiving. An offence is committed when the inducement is coupled with an intention of inducing a person to performing his function improperly in anticipation of a reward or if the request, agreement to accept or acceptance of the inducement itself constitutes or is believed to constitute the improper performance of that function. For the avoidance of any doubt, offering a bribe to a public official to induce that public official to obtain or retain business or to provide an advantage in relation to any aspect of the conduct of that business is not acceptable under any circumstances.
The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for Binumi or under our control as well as anyone to whom a bribe, facilitation payment or kickback may be offered. Reporting an attempted bribe or other corrupt behaviour should be dealt with as referenced in paragraph 7 below.
4. Gifts and Hospitality
4.1 Binumi permits small and appropriate gifts, normal and appropriate corporate entertainment, hospitality and promotional expenditure (given and received) (to or from third parties) provided that:
- it or they are not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
- it or they are not made with the suggestion that a return favour is expected.
- it or they are in compliance with local law.
- it is given in the name of the company, not in the name of an individual.
- it or they are does not include cash or a cash equivalent.
- it is or they are appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
- it or they are of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
- it or they are given/received openly, not secretly.
- it is or they are not selectively given to a key, influential person, clearly with the intention of directly influencing them.
- it or they are not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company.
- Binumi employees may not give gifts with a value in excess of US$50 unless prior approval has been given by the company.
- Binumi employees may not receive gifts with a value in excess of US$50 unless prior approval has been given by the company. Any gifts offered that exceed the US$50 value threshold must be declined and will be recorded.
- Gifts in the form of cash must never be accepted by our employees or service providers and therefore must not be offered and any offers of cash by any Binumi employee should be immediately reported to the company’s Chief Executive.
- The giving or receiving of promotional material is not considered a gift.
4.3 The giving and receiving of corporate entertainment and hospitality for our employees must never be excessive and should be reasonable in all the circumstances. In this respect the intention behind the gift of hospitality offered should always be considered.
5. Facilitation payments and kickbacks
5.1 Binumi and its service providers must not make or accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government or corporate action by a government official or corporate manager. Kickbacks are typically payments made in return for a business favour or advantage. Binumi expects all of its employees and service providers to avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by it.
5.2 If you are asked to make a payment on behalf of Binumi you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should in addition in every instance ask for a receipt which details the reason for the payment.
6. Record Keeping
6.1 Binumi keeps, and expects its service providers to keep, financial records and have appropriate internal controls in place which will evidence the business reasons for giving and/or receiving all payments from/to third parties.
6.2 All transactions entered into by Binumi must be recorded so that there is never any attempt to hide the way a contract will work.
7. Raising Concerns
If you believe or suspect this policy has been breached in any way please report this to Binumi’s CEO, Anthony Copping, (email@example.com) who will immediately arrange to investigate the matter.
25th May 2018
Modern Slavery Act Statement
23th May 2017
What is Modern Slavery?
Modern slavery is an international crime affecting millions of people around the world kept in a state of effective servitude. This issue transcends age, gender and ethnicity and affects people forced to work illegally against their will, very often for little or no compensation. The United Kingdom Modern Slavery Act 2015 requires certain organisations to publish an annual ‘Slavery and Human Trafficking Statement’ setting out steps that a an organisation has taken, if any, during the year to ensure that no modern slavery or human trafficking is taking place within its supply chain
Binumi Agency (Hong Kong) Limited (Binumi) is not based in the United Kingdom or obliged to issue an Anti-slavery Statement. The company, however, understands the issues related to modern slavery and wish all of our counterparties to understand that we will not tolerate slavery or anything equivalent to slavery anywhere within our supply chains. In this respect our policy is to understand all potential modern slavery risks related to our business and to assess the risk of violation of anti-human trafficking and anti modern slavery laws on a regular basis. We adopt procedures to ensure that modern slavery does not occur in our business or supply chains and we expect all organisations with whom we do business to adopt and enforce policies to comply with all relevant legislation.
Binumi is a provider of an internet based multimedia library and video editing platform. The Binumi Group has a development team based in Bangkok, Thailand, and has employees and consultants representing the business in multiple countries including the UK. Binumi is headquartered in Hong Kong. Binumi’s supply chains consist of computer programmers, channel marketing partners, resellers, employees, consultants, service providers and its registered subscribers and other users.
Binumi’s Board is committed to delivering high standards of corporate governance and a key element of this is managing the Group in a socially responsible way. The Group aims to employ the highest ethical and professional standards and always to comply with all local laws and regulations applicable to our business. It follows that Binumi is absolutely committed to preventing slavery and human trafficking or anything remotely resembling the same in its corporate activities and its supply chains. This commitment is emphasised in our employee training programmes and company policies. Binumi also expects the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers, counterparties and subscribers.
Due to the nature of our business and our approach to governance, we assess that there is very low risk of slavery and human trafficking in our business and supply chains. Notwithstanding this we aim, periodically, to review the effectiveness of all relevant policies and procedures that we have in place. Should any instance of slavery come to our attention it will be addressed immediately by reporting the same to relevant authorities and taking whatever internal action may be appropriate to combat the same.
This statement sets out the approach taken by Binumi Agency (Hong Kong) Limited to the issues of modern slavery and human trafficking and the actions undertaken to mitigate any such risks during the financial year ended 31 December 2017.
This statement is approved by the Board and issued on its behalf by:
CEO, Binumi Agency (Hong Kong) Limited