Handling of personal data

All personal data handled by Headson Top Ltd. (Headson Top) is managed with the utmost care as follows:

Headson Top's basic approach to personal data

Headson Top has formulated a management system for the protection of personal data that complies with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (the "PDPO"). The company applies rigorous controls in the handling of personal data (the meaning of "personal data" is defined under the PDPO).

Purpose of the acquisition and use of personal data

Headson Top has clearly set out its objectives in using its customers' personal data that it handles, and employs legitimate and equitable means to acquire only the personal data that it requires and without such data it may not be possible for Headson Top to provide its products / services to customers and / or to satisfy customers' requests. Headson Top collects 2 types of information about visitors: (i)personal data such as name, address, telephone number, fax number, email address, date of birth, as well as data on transactions between the customer and Headson Top and its affiliates, to deliver its products by mail, send out data on products and services, and carry out credit management and recovery in relation to Headson Top transactions; (ii) tracking data such as visitors’ domain names and IP addresses which is automatically collected from every visitors and recorded on our log files. Headson Top may also disclose customers' personal data to other companies (as authorized / appointed by Headson Top) which deliver the products / services (as purchased by the customers from Headson Top) to the respective customers. Where possible, Headson Top will validate or verify personal data collected from customers. In some cases, Headson Top may have to check the original documentation (e.g. ID card or proof of address) before using the relevant personal data. Headson Top may use cookies, small pieces of information that a website transfers to your computer’s hard drive for record-keeping purposes to deliver content specific to your interests, to save your password so you may not have to re-enter it each time you visit our site, or for other purposes.

Voluntary submission of personal data

When conducting a transaction with Headson Top, the customer must supply his/her name, address, and telephone number and without such data it may not be possible for Headson Top to provide its products/services to the customer and/or to satisfy the customer's requests.

If these are not supplied or are incomplete, the company will contact the customer in order to ascertain the correct information.

The customer is under no obligation to declare any other items of personal data, however, failure to declare certain items may render the customer ineligible for certain services.

Provision of personal data

Subject to all the scenarios described in this Privacy Policy, Headson Top will not provide the personal data that it handles to third parties without the prior consent of the person concerned, except in the event of criminal investigation conducted by government or regulatory authorities, or when the law otherwise prescribes that it must.

Outsourcing involving personal data

Headson Top will sometimes outsource the handling of personal data in its possession to an external agency in order to achieve the objectives set out above in section 2. In so doing, Headson Top takes full responsibility for carefully selecting the agency, concluding a personal data protection contract with it prior to outsourcing operations, and providing proper management and guidance with respect to personal data.

Measures for the protection of personal data

In order to appropriately manage the personal data that it acquires, Headson Top takes all necessary security measures and engages in preventing unauthorized or accidental disclosure, destruction, or loss of personal data. Headson Top also regularly instructs its employees to protect and closely manage its customers' personal data.

Retention period of personal data

Personal data obtained via will only be retained by Headson Top for as long as is necessary to fulfill the original or directly related purpose for which it was collected unless such data is also retained to satisfy any applicable statutory or contractual obligations.

Customers have the right to:

• Check whether Headson Top holds any personal data relating to them and, if so, obtain copies of such data;
• Require Headson Top to correct any personal data relating to them which is inaccurate for the purpose for which it is being used; and
• Ascertain Headson Top Ltd.'s policies and practices in relation to personal data, which are those policies and practices set out herein.

For requests of access, alteration, or deletion of personal data handled by Headson Top, please contact our customer services as indicated below.

The applicant will then be informed about what kind of data will be provided in response to the request for access, how the identity of an individual or their representative is verified, and the relevant handling charges. The applicant's data access request will then be complied with/without delay (and in any event within the statutory time limit).

Direct marketing/direct mailing of promotional materials

Should you wish not to receive direct marketing materials from Headson Top, please contact Customer service at 1-844-4BYLYSE / 1-844-429-5973 or e-mail us at Any such request should clearly state details of the personal data in respect of which the request is being made. Please also include the corresponding account numbers (if any) which are printed on Headson Top's statement/invoices/receipts, etc.