Privacy Policy

This sets out the policies and practices of CL Technical Services Limited and affiliated companies (“CLTS” or “We”) in relation to the handling of personal data.

Statement of Notice

We respect privacy. We are committed to complying with all applicable personal data privacy laws and regulations.

When we collect and process personal data, we will ensure that there is legal basis for us to do so – including but not limited to issuing a Privacy Notice and/or fulfilling any other requirements as provided under all applicable laws.

Statement of Practice

Kinds of Personal Data Collected

We collect personal data in five broad categories below (“Categories of Personal Data”):

  • Subscription Records which include records containing the personal information of the subscribers of our publications, job alert services and any other subscription based products or services.
  • Personnel Records which include job applicants’ personal information.
  • Event Attendee Records which include the personal information provided by the attendees of our events such as conferences, promotion or charity activities.
  • Other Operational Records which include the personal data of such data subjects involved in news gathering, security checks, cleaning, maintenance services, consultancy, technology, auditing, supplier, service provider, licensor and other data subjects providing services in relation to all aspects of our operations.
  • Records collected on/from web servers which include but not limited to the email addresses, location data and other online identifiers such as IP addresses of such data subjects who visit our websites and platforms.

Main Purposes of Processing Collected Personal Data

  • Subscription Records are processed for the purposes of: (i) provision of subscription, job alert orders and any other subscription based products or services; (ii) billing and payment(if applicable); and (iii) conducting market research for statistical purposes.
  • Personnel Records are processed for the purposes of: (i) recruitment; and (ii) human resources management and employment related activities such as employment benefits, termination, performance appraisal, and discipline.
  • Event Attendee Records are processed for the purposes of: (i) organizing and managing the relevant events; and (ii) running the related competitions, prize drawings, and promotions.
  • Other Operational Records are processed for the purposes of facilitating the effective operation of our business such as news gathering, security, maintenance, consultancy, technology, auditing, supplier, service provider, licensor, and other data subjects providing services in relation to all aspects of our operations.
  • Records collected from web servers are kept for the purposes of: (i) providing and/or improving on the news, information and related services to you; and (ii) keeping abreast of and analyzing the latest trends in the global recruitment landscape.

Data Protection Principles

All processing of personal data shall be conducted according to the data protection principles as follows:

  • Personal data must be processed lawfully, fairly and transparently.
  • Personal data can only be collected for specific, explicit and legitimate purposes.
  • Personal data must be relevant and limited to what is necessary for processing.
  • Personal data must be accurate and kept up to date with every effort to erase or correct.
  • Personal data must be kept in a form such that the data subject can only be identified if it is necessary for processing.
  • Personal data must be processed in a manner that ensures the appropriate security.

Legal Basis of Data Processing

We ensure that there is legal basis for our processing of personal data.

Such legal basis includes: (i) legitimate business interests of CLTS in processing personal data; (ii) if required by applicable laws or regulations, seeking your specific consent to process such personal data; and/or (iii) any other relevant basis under applicable laws and regulations.

Legitimate Interests

CLTS processes personal data under the “legitimate interests” legal basis which means that the processing of the personal data is necessary for the legitimate interest pursued by CLTS except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires the protection of personal data.

Legitimate Interests Assessment

In each relevant situation, we assess: (i) what these legitimate interests are; (ii) whether it is necessary to process such data to attain the objective; and (iii) the relevant rights of the data subjects; and balance such rights against our interests in achieving such objective, and ensure that such rights do not override CLTS’s legitimate interests before we conclude that CLTS can process the personal data on the basis of legitimate interests.

Communicate with the Data Subjects

All data subjects will be informed that we are collecting their personal data, the Categories of Personal Data concerned and the purpose of processing. This is to ensure that the data subjects are clear about our collection and processing of personal data and such collection and processing are within the data subjects’ reasonable expectations. Please be informed that all data subjects can object to our collection and processing of their personal data at any time, in addition to their rights of requesting for accessing and/or correcting their personal data in our possession.

Data Security Mechanisms

We have also implemented appropriate mechanisms, policies and procedures to protect the confidentiality and security of the personal data that we collect and process, as we respect the privacy and related rights of the data subjects relating to such personal data by reducing the risks or potential negative impact of processing including but not limited to data minimization, de-identification, encryption, restricted access and all other technical security methods and efforts to protect personal data. Such protection of the privacy and related rights of the data subjects would enable CLTS in processing personal data under the legitimate interest legal basis.

Having conducted the above assessment thoroughly, CLTS concludes that it is collecting and processing personal data under legitimate interest as follows:

  • Serving Customer and Operational Needs.

The main purposes for processing the Categories of Personal Data have been set out above.

There are legitimate interests for CLTS to process the same because all such purposes are essential to CLTS serving its customers and its operational needs as a corporation.

A corporation like CLTS needs employees to work for its business (and hence Personnel Records) and service providers to keep it running (and therefore Other Operational Records).

CLTS needs the personal data of its subscribers, event attendees and website visitors so as to be able to have relevant and timely provision of information and/or other services (and thereby subscription and event attendee records together with records collected on webservers).

  • Market Analysis

We analyze the data to: (i) gain insightful knowledge of preferences or tastes of users; and (ii) conduct market segmentation and related studies.


Where applicable legal requirement demands specific consent must be obtained before we can process personal data, we will ensure that such specific consent will be obtained as follows:

  • the consent has to be clear, explicit and specific;
  • data subject is fully aware of the types of the personal data that we intend to use; and the purposes of such usage (such as improving our services to the data subject); and
  • the name/identity of the transferee (if we ever intend to transfer your data) and how the transferee shall use your personal data.


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Two general types of cookies are used on our website:

  • Session Cookies: temporary cookies are only used during a visit to our website and will be deleted at the end of each visit. Session cookies are used to compile anonymous statistics about the use of our website.
  • Persistent Cookies: persistent cookies remain in your browser for a longer period of time for the purpose of compiling anonymous statistics about the use of our website and/or tracking and recording your preferences.

To find out more about cookies, please visit .

You may refuse to accept cookies by modifying the settings feature of your browser or internet security software. However, if you do so you may not be able to utilize or activate some of the features and/or functions of our website.

Rights of the Data subjects

CLTS respects that data subjects have the following rights about the data processing, and the data which is recorded about them:

  • To request for access regarding the nature of information held and to whom it has been disclosed.
  • To prevent processing likely to cause damage or distress.
  • To be informed about the mechanics of automated decision-making process which will significantly affect them.
  • Not to have significant decisions that will affect them taken solely by automated process.
  • To take action to rectify, block and erase including the right to be forgotten or destroy inaccurate data.
  • To request the supervisory authority (eg. a privacy commissioner or a data protection officer) to assess whether any provision of the relevant privacy and other laws has been violated.
  • To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have such data transmitted to another data controller.
  • To object to any automated profiling which is occurring.

Transfer of Personal Data

We will keep confidential the personal data that we hold, which may be transferred to the following parties within Hong Kong for the purposes as stated above.

In the event of such transfer, CLTS shall use contractual or other means to ensure that the data transferees shall keep the transferred personal data confidential and comply with all relevant personal data privacy laws and regulations.

Outsourcing Arrangements

CLTS has been using internal resources to develop and maintain its IT systems. Occasionally CLTS engages third-party vendors to provide certain services relating to its IT systems. Such vendor does not have access to the personal data stored under usual circumstances.

In the exceptional case where such vendor has such access, CLTS uses reasonable measures to ensure that such vendor is contractually bound to keep such personal data confidential and adopt appropriate means to prevent any unauthorized access, use, loss, retention, modification, transfer or otherwise.

Data Retention

We implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which they were collected. Different retention periods apply to various types of personal data that we hold, depending on the respective data collection/usage purpose and relevant legal requirements. We have appointed a Data Protection Officer whose responsibilities include the following:

  • To inform and advise CLTS and its employees of their obligations pursuant to the applicable privacy and other laws and regulations (collectively “Privacy Laws”);
  • To monitor CLTS’s compliance with such Privacy Laws;
  • To co-operate with the supervisory authority (eg. privacy commissioner or equivalent bodies); and
  • To act as the point of contact for the supervisory authority on issues regarding the data processing and related matters.

Data Access / Correction and Other Inquiries

You have the right to know whether CLTS holds your personal data, access the data and/or correct any inaccuracies of such data. You also have the right to make reasonable inquiries about CLTS’s personal data policies and procedures. You have the right to object to the processing of your personal data or withdraw your consent (if applicable) at any time. Please note however that if you object to the processing of your personal data, it may affect CLTS’s ability to provide the services that you required to you or may affect the quality of such services. If you withdraw your consent (if applicable), CLTS will stop providing such services to you which applicable laws require specific consent.

All of the above requests should be made inwriting to our Data Protection Officer at

A reasonable fee may be charged in light of the administrative costs that CLTS shall incur in addressing your request(s).

We keep our Privacy Notice under regular review, and reserve the right to amend it from time to time as appropriate.