Privacy and Personal Information Collection Statement

Privacy Policy


1. Our company recognizes the importance of your privacy and maintaining the confidentiality of your Personal Data. This Privacy Policy applies to all products and services provided by us and sets out how many we may collect, use and disclose your Personal Data. This Privacy Policy is governed by and observes the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (“the Ordinance”).


2. Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your account.

Personal Information Collection Statement

1. Please note that it is mandatory for you to provide certain categories of Personal Data (as specified at the time of collection, click here for details). In the event that you do not provide any Personal Data marked as mandatory, we may not be able to provide you with our products or services.


2. If you provide any Personal Data to us, you are deemed to have authorized us to collect, retain and use personal information about you for the following purposes:
a. processing your application for membership and maintaining and managing your membership;
b. verifying your identity;
c. verifying your eligibility to participate in this Scheme;
d. providing you with regular communications from us with details of this Scheme and its benefits;
e. providing you with customer service and responding to your queries;
f. marketing our promotions and services, including notifying you of special offers or new products and sending any advertising and/or promotional material to you relating to our promotions, services or website;
g. performing research or statistical analysis in order to improve our products and services and for marketing and promotional purposes;
h. making such disclosures as may be required for any of the above purposes or as required by law.

3. You further agree that we may disclose and transfer (whether in Hong Kong or abroad) your Personal Data to third party services providers engaged by us to assist with providing you with our services (including managing our customer database, sending you promotional materials, and customer services) (“Third Party Service Providers”). These Third Party Service Providers are under a duty of confidentiality to us and are only permitted to use your Personal Data in connection with the purposes specified at clause 10.4 above, and not for their own purposes (including direct marketing).

4. We may share aggregate data that does not allow to you to be identified with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services.

5. Any Personal Data supplied by you will be retained by us and will be accessible by our employees and any Third Party Service Providers engaged by us, for or in relation to any of the purposed stated in clause 4 herein.

6. All reasonable efforts are made to ensure that any personal data held by us is stored in a secure and safe place, and accessed only by our authorized employees or authorized Third Party Service Providers.

7. You should be aware that no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet.

8. If you would like to opt out from receiving direct marketing materials from us, you can email to by stating your English full name, registered email and Kabu Pass registration number.

9. Under the Ordinance, you have the right to access to personal information held by us and to request correction of the information.

10. All requests for access or correction or deletion or of Personal Data or any questions regarding this Privacy Policy should be in writing and addressed to: Customer Service Department, Kabushikigaisha Limited, Unit 03, L22, Tower 1, Enterprise Square Five, MegaBox, 38 Wang Chiu Road, Kowloon Bay.

11. In accordance with the Ordinance, we reserve the right to charge you a reasonable fee for the processing of any Personal Data access or correction request.