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Privacy Policy




Regarding Personal Data


1. Definition of Personal Data


TRINGLE HONGKONG acknowledges personal data as data related to living individual, as stated in the ordinance concerning personal data protection (name, date of birth, and other information that can ascertain a specific individual). Personal data also include information of email address, user ID, password, credit card, etc. that can be related to a specific individual; and attribute information that is fully integrated with personal data, which includes interests, family structure, age, and so on.



2. Cookies・IP address


Regarding cookies and IP address information, we do not consider them as personal data, as them alone cannot be used to identify a specific individual. Nonetheless, if the mentioned information is integrated with personal data, we will assume them to be personal data. In addition, about cookies, you can set your browser to disable them. We will make further announcement in case that by disabling cookies you will not be able to enjoy our service.



3. Specification of the Purpose of Use of Personal Data


TRINGLE HONGKONG will endeavor to specify the purpose of use of personal data.



4. Restriction on Use of Personal Data


TRINGLE HONGKONG will never use personal data out of the scope necessary for achieving specified purpose of use, without approval of the person himself/herself.



5. Proper Collection of Personal Data


TRINGLE HONGKONG collects personal data in proper means. We do not collect any personal data through fraud or in any other unlawful manner. Also, we pay attention that we do not collect personal information from children under the age of 15 without the agreement of the person who possess parental authority.



6. Notification of Purpose of Use when Collecting Personal Data


TRINGLE HONGKONG announces the purpose of use of the personal data to be collected in advance. However, the following cases are exceptions.


(1) When noticing the purpose of use to the person, or announcing the purpose of use might cause infringement on life, body, estate, or other rights and interests of the person or third party.


(2) When noticing the purpose of use to the person, or declaring the purpose of use might cause infringement on TRINGLE HONGKONG’s rights or legitimate interests.


(3) In cases that we have to assist a national public organization or a local public organization to execute duty ordered by decree, and that noticing the purpose of use to the person, or declaring the purpose of use might cause interference to the execute of the duty.


(4) When the purpose of use is recognized as apparent judging from the situation of collecting personal data.



7. Change of Purpose of Use of Personal Data


In cases that TRINGLE HONGKONG changes the purpose of use of personal data, we will not change the purpose of use beyond the scope in which it is reasonable to find that the changed purpose of use is appropriately relevant to the original purpose of use, and we will announce the changed purpose of use.



8. Supervision of Trustees


When TRINGLE HONGKONG entrusts an individual or a business operator with the handling of personal data in whole or in part, we will sign non-disclosure contract with them, or we will ask for agreement with the adhesive terms and conditions determined by us, and exercise necessary and appropriate supervision over the trustee to ensure the security control of the personal data.



9. Restriction of Provision to A Third Party


TRINGLE HONGKONG will not, except in the following cases, provide personal data to a third party without obtaining the prior consent of the person:


(1) Cases in which the provision of personal data is based on laws and regulations.


(2) Cases in which the provision of personal data is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person.


(3) Cases in which the provision of personal data is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person.


(4) Cases in which the provision of personal data is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by one in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person are likely to impede the execution of the affairs.


(5) Cases in which we notify or announce the following in advance:

1) The provision to a third party is included in the purpose of use.

2) The items of the data to be provided to a third party.

3) The means or method of provision to a third party.

4) The fact that the provision of such personal data will be discontinued at the request of the person.


Nonetheless, in the following cases, the individual or business operator shall not be deemed a third party as mentioned above:


(1) Cases in which TRINGLE HONGKONG entrust the handling of personal data in whole or in part within the scope necessary for the achievement of the purpose of use.


(2) Cases in which personal data is provided as a result of the succession of business in a merger or otherwise.


(3) Cases in which personal data is used jointly between specific individuals or entities and in which this fact, the items of the personal data used jointly, the scope of the joint users, the purpose for which the personal data is used by them, and the name of the individual or business operator responsible for the management of the personal data is, in advance, notified to the person or put in a readily accessible condition for the person.


When TRINGLE HONGKONG meets cases in which personal data is used jointly between specific individuals or entities, the purpose of use or when the name of the individual or business operator responsible for the management of the personal data is changed, we will in advance, notify the change to the person or put in a readily accessible condition for the person.


10. Public Announcement of Matters Concerning Personal Data, etc.


TRINGLE HONGKONG, regarding the following items concerning personal data, will put them in an accessible condition for the person, and respond without delay at the request of the person.


(1) The purpose of use of personal data (however, this excludes the items that are not obligate for public announcement according to law concerning the protection of person data, When we decide not to response, we will notify the person without delay.)



11. Disclosure of Personal Data


TRINGLE HONGKONG will disclose personal data to the person without delay at the request of the person. However, if the following cases apply to the disclosure of personal data, we may keep all or part of the personal data undisclosed. When we decide not to disclose, we will notify the person without delay.


(1) Cases in which disclosure is likely to harm the life, body, property, or other rights or interests of the person or a third party.

(2) Cases in which disclosure is likely to seriously impede the proper execution of the business of TRINGLE HONGKONG.

(3) Cases in which disclosure violates other laws and regulations.


In addition, as a general rule, we will not disclose information such as access log, which is not personal data.



12. Correction of Personal Data, etc.


When TRINGLE HONGKONG is requested by a person to correct, add, or delete (noted as “correction” below) personal data on the ground that the personal data is contrary to the fact, we will, except in cases in which special procedures are prescribed by any other laws and regulations for such correction, make a necessary investigation without delay within the scope necessary for the achievement of the Purpose of Use and, on the basis of the results, correct the personal data. We will notify the person in such case.



13. Discontinuance of the Utilization of Personal Data, etc.


When TRINGLE HONGKONG is requested by a person to discontinue using or to erase (noted as “discontinuance of use, etc.” below) on the ground that the personal data is being handled out of the scope necessary for achieving specified purpose of use as announced in advance, or that the data was collected through fraud or in any other unlawful manner, we will make a necessary investigation without delay. Base on the result of the investigation, we will discontinuance of use of personal data, etc., and notify the person in such case. However, this provision shall not apply to cases in which it costs large amount or otherwise difficult to discontinuance of use, etc. the personal data and in which we can take necessary alternative measures to protect the rights and interests of the person, we will take the alternative measures.



14. Discontinuance of the Utilization of Personal Data, etc.


If TRINGLE HONGKONG decides to take the following actions despite the person’s request, we will endeavor to explain the reasons:

(1) Not notifying the purpose of use.

(2) Keep all or part of the personal data undisclosed.

(3) Not discontinuing the use of personal data, etc.

(4) Not stopping to provide personal data to a third party.



15. Enquiry


Shall you have any enquiries concerning TRINGLE HONGKONG’s privacy policy, please kindly fill in the following enquiry form.


Enquiry Form