Ethos

The More Chaos ethos is to help promote and encourage participation and support of local sports within Hong Kong. Our aim is to nurture and strengthen sporting excellence, by covering news surrounding domestic teams, and recognising achievements made by amateur sportsmen and women, helping to propel them toward success. In doing so, More Chaos aims to further promote sporting culture, and sportsmanship, endorse team work and praise talent, effort and skill, as well as highlight the social aspects of being involved with sports in Hong Kong.

 

Statement of Notice

We respect privacy. MORE CHAOS is wholly owned by MoreChaos Ltd and is committed to complying with all applicable personal data privacy laws and regulations.

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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.

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Statement of Practice

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Kinds of Personal Data Collected

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

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Account Records which include records containing the personal information of the account holders of our website, mobile apps and any other products or services.

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Personnel Records which include job applicants and our employees’ personal information.

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Event Attendee Records which include the personal information provided by the attendees of our events such as conferences, promotion or charity activities.

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Other Operational Records which include the personal data of such data subjects involved in newsgathering, determining local air quality, weather, and pollution levels, 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.

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Records collected on/from Webservers 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, platforms.

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Main Purposes of Processing Collected Personal Data

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Account Records are processed for the purposes of: (i) provision of account holding, weather conditions and air quality alerts, and any other subscription based products or services; (ii) billing and payment (if applicable); and (iii) conducting market research for statistical purposes.

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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.

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Event Attendee Records are processed for the purposes of: (i) organising and managing the relevant events; and (ii) running the related competitions, prize draws and promotions.

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Other Operational Records are processed for the purposes of facilitating the effective operation of our business such as newsgathering, determining weather conditions, air quality, security, maintenance, consultancy, technology, auditing, supplier, service provider, licensor and other data subjects providing services in relation to all aspects of our operations.

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Records collected on/from Webservers are kept for the purposes of: (i) providing and/or improving on weather, air quality, and pollution related updates, information and related services to you; and (ii) keeping abreast of and analysing the latest trends in the global sports, health, wellbeing, environmental and meteorological landscape.

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Data Protection Principles

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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.

 

Data Inventory

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We have also kept a data inventory and data flow process to determine various aspects of our data processing including:

• Business processes that use personal data.

• Purposes for collecting and/or using the personal data.

• Source of personal data.

• Processing activities.

• Any data transfer, and to whom.

• Any data access, correction or opt-out request.

 

Such data inventory would facilitate MoreChaos in tracking its data and the related processing activities, and put us in a better position to comply with the relevant privacy and other laws and regulations.

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Legal Basis of Data Processing

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

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Such legal basis includes: (i) legitimate business interests of MORE CHAOS (MoreChaos Ltd) 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.

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Legitimate Interests

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MORE CHAOS (MoreChaos Ltd) 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 MORE CHAOS (MoreChaos Ltd) except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires protection of personal data.

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Legitimate Interests Assessment

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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 MORE CHAOS’s (MoreChaos Ltd’s) legitimate interests before we conclude that MORE CHAOS (MoreChaos Ltd) can process the personal data on the basis of legitimate interests.

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Communicate with the Data subjects

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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 process of personal data and such collection and processing are within the data subjects’ reasonable expectation.

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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.

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Data Security Mechanisms

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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 minimisation, 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 MORE CHAOS (MoreChaos Ltd) in processing personal data under the legitimate interest legal basis.

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Having conducted the above assessment thoroughly, MORE CHAOS (MoreChaos Ltd) concludes that it is collecting and processing personal data under its legitimate interests as follows:

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a. Serving our Customers and Operational Needs

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The main purposes for processing the Categories of Personal Data have been set out above. They are legitimate interests for MORE CHAOS (MoreChaos Ltd) to process the same because all such purposes are essential to MORE CHAOS (MoreChaos Ltd) serving its customers and its operational needs as a corporation and environmental organisation.

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

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An environmental organisation such as MORE CHAOS (MoreChaos Ltd) 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 Account and Event Attendee Records together with Records collected on Webservers).

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b. Inform the Public

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As a health, wellbeing, and sports media platform – MoreChaos respects the public’s right to know about what is happening in our community and the world. MORE CHAOS (MoreChaos Ltd) has an ethical duty to inform the public of such happenings (“duty to inform”).

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We collect and process such data as the name, email address, online identifier and/or location data of those data subjects who visit or use any of our news, media, apps or other websites. We take note of the web and app pages being viewed as well as the time and frequency of such viewing. All of such data (“Public View Data”) are used to recommend to such data subjects relevant articles, products or content which should be of their interests.

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Such recommendation does not prohibit or restrict anyone from viewing all of the other articles, products or content on such websites or apps which they can access at any time as available.

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c. Market Analysis

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We analyse the Public View Data to: (i) gain insightful knowledge of the reading habits, preferences or tastes of the public; and (ii) conduct market segmentation and related studies.

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Such analysis is necessary because it enhances MORE CHAOS’s (MoreChaos Ltd’s) capability to carry out its duty to inform and contribute to the welfare of our international community as a global digital environmental organisation. The knowledge and study results from such analysis would enable MoreChaos to fulfil its duty to inform more effectively by providing more relevant and timely information, products and services to the public.

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This would benefit not just MORE CHAOS (MoreChaos Ltd) – but also the international society as a whole. Protecting the environment requires globalised and inter-connected resources and communication. What is happening in one part of the world could have instant, far-reaching and/or significant ramifications on others.

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d. Direct Marketing

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MORE CHAOS (MoreChaos Ltd) also uses personal data for direct marketing purposes as part of its legitimate interests unless the data subject explicitly objects or such is otherwise specifically prohibited under applicable laws.

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How you use MORE CHAOS’s (MoreChaos Ltd)’s products or services (such as news, environmental advice and updates, media, advertising, events, etc.) may indicate your consumption preferences or inclinations. Based on such preferences or inclinations, we use such personal data to conduct direct marketing in respect of various goods and/or services offered by MORE CHAOS (MoreChaos Ltd), its affiliates or business partners including:

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(a) Insurance, banking and financial products and services;

(b) Products and services relating to airlines, hotel, health club, travel and hospitality;

(c) Beauty, skin care, health, medical devices, biotechnology, pharmacy and wellness;

(d) Eyewear and optical, fashion, sports, sports events, sports clubs, watches and jewellery, flower shop, stationery, toys, department stores and shopping malls;

(e) IT, electronic goods and electrical appliances, mobile phones and accessories, telecommunications and media products and services;

(f) Food and beverages and restaurants;

(g) Design, automotive, education, antique and auction, arts and gallery, boat and accessories, services for children, real property, construction, furniture and household items, interior design, consular services, trade or industry associations, non-governmental organisations, government services, energy, events and exhibitions, personal announcements, pets and accessories, post and courier services, public utilities, professional services, career, security services, shopping, transportation and logistics.

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We note that given the global spread of our businesses, there could be cases where our use of personal data for direct marketing is governed by laws of certain jurisdictions (such as Hong Kong) which require the consent of the data subject(s) in this regard. Please refer to the “Consent” section immediately below for more information.

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Consent

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

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(A) the consent has to be clear, explicit and specific;

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(B) 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 or direct marketing); and

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(C) 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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Rights of the Data subjects

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MORE CHAOS (MoreChaos Ltd) respects that data subjects have the following rights about the data processing, and the data which is recorded about them:

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(1) To request for access regarding the nature of information held and to whom it has been disclosed.

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(2) To prevent processing likely to cause damage or distress.

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(3) To prevent processing for purposes of direct marketing.

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(4) To be informed about the mechanics of automated decision-making process which will significantly affect them.

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(5) Not to have significant decisions that will affect them taken solely by automated process.

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(6) To sue for compensation if they suffer damage by any contravention of the applicable privacy and other laws.

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(7) To take action to rectify, block and erase including the right to be forgotten or destroy inaccurate data.

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(8) 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.

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(9) 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.

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(10) To object to any automated profiling which is occurring.

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Transfer of Personal Data

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

 

Delivery agents of MORE CHAOS (MoreChaos Ltd) for delivering magazines or other publications;

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(ii) Agents, contractors or third parties which/who provide administrative, technology or other services to MORE CHAOS (MoreChaos Ltd) for its operations;

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(iii) Credit reference or debt collection agencies; and

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(iv) Any affiliates of MORE CHAOS (MoreChaos Ltd).

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In the event of such transfer, MoreChaos 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.

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Regarding the situation as described under sub-clause (iv) above – If such intra-group transfer among MORE CHAOS (MoreChaos Ltd) affiliates involves cross-border data transfer, MORE CHAOS (MoreChaos Ltd) may adopt binding corporate rules for safeguarding the security of such personal data; and ensuring that all affiliates involved shall comply with the relevant privacy and other laws.

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Outsourcing Arrangements

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MORE CHAOS (MoreChaos Ltd) uses third-party vendors to develop and maintain its IT systems. This vendor does not have access to the personal data stored in the IT systems under usual circumstances.

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In the exceptional case where such vendor has such access, MORE CHAOS (MoreChaos Ltd) uses reasonable measures to ensure that: (i) such vendor is contractually bound to keep such personal data confidential and adopt appropriate means to prevent any unauthorised access, use, loss, retention, modification, transfer or otherwise.

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Data Retention

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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.

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Different retention period apply to various types of personal data that we hold, depending on the respective data collection/usage purpose and relevant legal requirements.

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Anti-Spam

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This Anti-Spam Policy Notice governs the use of the website and app and its associated services, web pages, domains and sub-domains, which are owned and operated by MORE CHAOS (MoreChaos Ltd).

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This sets forth our policy with regard to the use of “Spam” marketing techniques in connection with Internet Marketing. In the event that we deem you to be in violation of these policies, we shall immediately revoke your rights and close any active account.

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We have a strict policy against spamming. We forbid the sending of unsolicited mass Emails or unsolicited Emails of any kind in connection with the marketing of our programs, products and services.

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We reserve the right to terminate your account and participation in our programs “for cause” if we deem you to be in violation of our anti-spamming policies. We also reserve the right to suspend your account and participation pending review upon receipt of any complaint or other evidence that you may be engaging in any spamming activity.

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We consider spamming to be any activity whereby you directly or indirectly transmit email messages to any email address that has not solicited such email and does not consent to such transmission. We also consider spamming to constitute posting advertisements in various comment sections and product reviews that are off topic, or in areas that do not specifically permit advertisements.

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If you are “spammed” by anyone regarding our products, services, website, app, or any other matters, please report this activity to MORE CHAOS (MoreChaos Ltd) at info@MoreChaos.com

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Cookies - What are Cookies and other tracking technologies?

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Cookies are small files which are stored on your internet browsing device (e.g computer, tablet or phone) when you visit one of our websites, use our app or see one of our adverts elsewhere on the internet. Cookies don't store personal details such as your credit card details, your name or your date of birth. They play an important role in helping us to enhance the usability and performance of our websites and your experience using them. Some cookies are also essential to enable you to move around our Website and use its features. Other tracking technologies, like web beacons, clear GIFs, page tags and web bugs, are used to understand how people are using our services and to target advertising.

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When you first use our Website, we will ask you to consent to our use of cookies and give you information about them. If you continue to browse our Website, and don't take steps to change your preferences, you are consenting to our use of cookies.

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What types of Cookies do we use?

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Our Website uses session cookies and persistent cookies. Session cookies operate from the moment you enter the Website until the moment you leave. Once you log off session cookies are deleted. Persistent cookies will not be deleted after each session.

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Strictly Necessary Cookies are essential to our Website, if these are disabled, your experience on our Website may be interrupted and you may not be able to use a shopping basket or make payment.

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Performance Cookies collect anonymous data about visitors. We use the data to improve your future experience and identify issues that our users may be experiencing.

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Functionality Cookies customise the look and appearance of our Website. For example, a functionality cookie will remember your username and language preferences next time you visit.

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Targeting or Advertising Cookies deliver advertisements which are tailored to your web activity. A targeting cookie tracks what you click on whilst on our Website, and may share details of what you click on with other organisations such as advertisers. These cookies can also help us to measure the effectiveness of an advertising campaign.

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Third party cookies may be used on our Website by approved organisations to provide services on our Website.

 

How we use Cookies and other tracking technologies

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We use a combination of our own cookies, third party cookies and other tracking technologies to enhance your browsing experience and to enable our Website and app to function efficiently. In particular, we use cookies to:

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• enable you to set up an account, place orders and make payments;

• remember items you place into your shopping basket;

• remember items you have been looking at so that you can quickly and easily go back to an item you looked at previously;

• enhance and personalise your shopping experience.

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The default setting on your web browser is to prohibit cookies, but you may have changed this during the installation process. You can also choose which cookies MORE CHAOS (MoreChaos Ltd) places on your computer when you access our Website and can manage this in our preference centre. Further information on cookies, including instructions on how to amend your browser settings to turn off cookies, is available widely online. However, if you disable or delete certain cookies you may not be able to shop or access important parts of our Website.

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Data Protection Officer

 

We have appointed a Data Protection Officer whose responsibilities include the following:

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(1) To inform and advise MORE CHAOS (MoreChaos Ltd) and its employees of their obligations pursuant to the applicable privacy and other laws and regulations (collectively “Privacy Laws”);

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(2) To monitor MORE CHAOS’ (MoreChaos Ltd’s) compliance with such Privacy Laws;

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(3) To co-operate with the supervisory authority (eg. privacy commissioner or equivalent bodies); and

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(4) To act as the contact point for the supervisory authority on issues regarding the data processing and related matters.

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Data Access / Correction and Other Inquiries

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You have the right to know whether MORE CHAOS (MoreChaos Ltd) 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 MoreChaos’ 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 MoreChaos’ 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), MORE CHAOS (MoreChaos Ltd) will stop providing such services to you which applicable laws requires specific consent.

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All of the above requests should be made in writing to our Data Protection Officer at info@MoreChaos.com

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A reasonable fee may be charged in light of the administrative costs that MORE CHAOS (MoreChaos Ltd) 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. This Notice was last updated on 18 September 2018.