1. Purpose of this Privacy Policy

OnTheList Limited (referred to in this Privacy Policy as “OnTheList”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit us at,,, and  (the “Websites”), regardless of where you visit them from, or use the OnTheList mobile application for iOS or Android (the “App”) and tell you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Websites or App, including any data you may provide through the Websites or App when you sign up to our newsletter, purchase any products or services and/or take part in a competition.

The Websites and the App are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them.

  1. Data Controller

OnTheList is a “data controller” of your personal data.

In simple terms, this means that we (i) “control” your personal data, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or as otherwise permitted by law.

  1. Contact Information and Complaints

If you have any questions about this Privacy Policy or any questions regarding our use of your personal data, please contact our data privacy manager at [email protected].

Our full contact details are:

OnTheList Limited
G/F., Printing House,
6 Duddell Street,
Central, Hong Kong

Attn: Data Privacy Manager

If you are currently staying within the European Economic Area, you have the right to make a complaint at any time to your country's supervisory authority for data protection issues. For a current list of national data protection authorities, please visit the European Data Protection Board’s website at

We would, however, appreciate the chance to deal with your concerns before you approach your country's supervisory authority, so please contact us in the first instance.

  1. Changes to this Privacy Policy and Personal Data

This Privacy Policy is regularly reviewed and was last updated on 16th May 2019. We may amend or update our Privacy Policy from time to time. For this purpose, we will provide you notice of amendments to this Privacy Policy and update the “last updated” date above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. Third-Party Links

The Websites and the App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Websites or the App, we encourage you to read the privacy policy of every website you visit.


The types of personal data we collect, use and store about you will depend on the services you have requested from us and/or the nature of your interaction with us. When using our Websites or the App, we collect and process the following types of personal data:-

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. Direct Interactions

We collect Identity Data, Contact Data and Financial Data about you that you provide to us by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:-

  1. Automated Technologies and Interactions

As you interact with our Websites or the App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

A cookie is a small file of letters and numbers stored by computer after being sent to your computer when you visit a website. Whenever you visit the same website again, the information stored in the cookie can be retrieved to notify the website of your previous activity. We use cookies to facilitate website navigation, maintain quality of online service, provide additional security, allow the customization of your access to the Websites and remember you when you return to the Websites.

A cookie cannot give us access to your computer or to information beyond what you provide us and we don't store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience on our Websites. If you do not wish to enable cookies, you'll still be able to browse the Websites and use them for research purposes.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

When you visit our Websites, you may notice some cookies that are not related to OnTheList. If you go on to another website that contains embedded content, you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit or

  1. Third Parties

We are also working closely with third parties (including, for example, analytics providers and other third party providers of services).

We will receive personal data about you from such third parties as set out below:-

  1. Data Usage

We are committed to only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

We plan to use your personal data for the following purposes, and pursuant to the corresponding legal bases:


Type of Data

Lawful Basis and Basis of Legitimate Interest

Registration as a new customer

Identity Data;

Contact Data.

Performance of Contract

Processing and delivery of your order

Identity Data;

Contact Data;

Financial Data;

Transaction Data;

Marketing and Communication Data.

Performance of Contract;

Legitimate Interest (to recover debts due to us).

Management of our relationship with you

(i.e. notifications about changes to Privacy Policy and asking you to leave a review or take a survey)

Identity Data;

Contact Data;

Profile Data;

Marketing and Communication Data.

Performance of Contract;

Legal Obligations;

Legitimate Interest (to keep your records updated and to study how customers use our products/services).

Enabling you to partake in a prize draw, competition or complete a survey

Identity Data;

Contact Data;

Profile Data;

Usage Data;

Marketing and Communication Data.

Performance of Contract;

Legitimate Interest (to study how customers use our products/services and grow our business).

Administration and Protection of our Websites and App

(including troubleshooting, data analysis, testing, system maintenance, support reporting and hosting of data)

Identity Data;

Contact Data;

Technical Data;

Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);

Legal Obligations

Delivery of relevant website content and advertisements to you and understanding the effectiveness of the advertising we serve to you

Identity Data;

Contact Data;

Profile Data;

Usage Data;

Marketing and Communication Data;

Technical Data.

Legitimate Interest (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

Using data analytics to improve our Websites, the App, products/services, marketing, customer relationships and experiences

Usage Data;

Technical Data.

Legitimate Interest (to define types of customers for our products and services, to keep our Websites and the App updated and relevant, to develop our business and to inform our marketing strategy).

Suggestions and recommendations about goods or services that may be of interest to you

Identity Data;

Contact Data;

Profile Data;

Usage Data;

Marketing and Communication Data.

Legitimate Interest (to develop our products/services and grow our business).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please feel free to contact us any time.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Marketing and Promotional Offers

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing emails and newsletters from us if you have requested information from us or purchased products or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have expressly consented to receiving such marketing emails and newsletters.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  1. Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by:-

Where you opt-out of receiving these marketing messages or newsletters, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions (which we will continue to process in order to perform a contract with you or as a result of our regulatory or legal obligations).


We may share your personal data with the following parties for the purposes set out in the table above:-

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


We will share your personal data within our company in Hong Kong, but we may transfer your data to other jurisdictions.

Please understand that we will generally ensure a similar degree of protection to your personal data as it is afforded in the EEA by ensuring at least one of the following safeguards is implemented:

Please do not hesitate to contact us anytime if you want further information on the specific mechanism used by us when transferring your personal data.


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data: see Clause 9 (Your Legal Rights within the EEA) or Clause 10 (Your Legal Rights within Hong Kong) below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. List of Rights if you are staying with the EEA

If you are currently staying within the EEA, under certain circumstances, you may have rights under data protection laws in relation to your personal data. These rights include:-

If you wish to exercise any of the rights set out above, please contact us at [email protected].

  1. No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) in accordance with Clause 9.1 above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

  1. Information Required

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data in accordance with Clause 9.1 (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  1. Time Limit to Respond

We try to respond to all legitimate requests made in accordance with Clause 9.1 within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


If you are currently staying in Hong Kong, you are entitled, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486, the laws of Hong Kong) (the “Ordinance”), to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. Requests for access to or to correct personal data should be addressed to our Data Privacy Manager at [email protected]. In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.


In the event that we decide not to continue our business in Taiwan, you acknowledge and agree that we may, to the extent permissible by any applicable laws, transfer the entirety of your personal data to third parties to carry out the purposes, or directly related purposes, for which the personal data was collected.


This Privacy Policy is drafted in English and Chinese.  If there is a conflict between the English and the Chinese version of this Privacy Policy, the English version shall prevail to the maximum extent permitted by law.


In this Privacy Policy, the following expressions shall have the following meanings except where the context otherwise required:-

External Third Parties” shall mean (a) service providers based in Hong Kong who provide IT and system administration services; (b) professional advisors including lawyers, bankers, auditors and insurers based in Hong Kong who provide consultancy, banking, legal, insurance and accounting services; and (c) the Inland Revenue Department, regulators and other authorities based in Hong Kong who require reporting of processing activities in certain circumstances.

Legitimate Interests” shall mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Legal Obligations” shall mean processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Performance of Contract” shall mean processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.