This Privacy and Security Statement applies to this web site which is owned and operated by Orient Overseas (International) Limited ("OOIL") under the domain name www.ooilgroup.com ("OOIL Web site").

As part of the normal operation of our services we collect and, in some cases, disclose information about you. OOIL understands and appreciates that you, as a OOIL Web site user, are concerned about your privacy and about the confidentiality and security of information we may collect from you online. OOIL is committed to safeguarding your privacy. This OOIL Privacy and Security Statement explains how information collected from you will be treated as you access and interact with the OOIL Web site.

In addition to the provisions of this Privacy and Security Statement, there may also be specific and additional privacy provisions which apply to certain sections of the OOIL Web site. As those specific and additional provisions also relate to your privacy protection, you should review them wherever they are accessible by you on the OOIL Web site. In the event of any inconsistency between the provisions of this Privacy and Security Statement and those other specific and additional provisions, the specific and additional provisions will prevail.

1. Acceptance and changes to Privacy and Security Statement

This Privacy and Security Statement is incorporated into and subject to the Terms of Use, which together is intended to constitute a single binding agreement of terms and conditions for your use of the OOIL Web site ("the Agreement"). This Privacy and Security Statement shall supplement the Terms of Use and, for the avoidance of doubt, terms defined therein shall have the same meanings in this Privacy and Security Statement unless the context indicates or requires otherwise. In the event of a conflict, the provisions of the Terms of Use will prevail. You acknowledge and accept that your use of or access to the OOIL Web site indicate your acceptance to the Agreement. This is the current Privacy and Security Statement. It replaces any other Privacy and Security Statement for the OOIL Web site published on the OOIL Web site to date. As the OOIL Web site develops and as technology evolves, OOIL will continue to strive to provide you with better and more customized services and with a more effective web site. OOIL may at any time revise the Privacy and Security Statement by publishing the revised Privacy and Security Statement on the OOIL Web site. You accept that by doing this, OOIL has provided you with sufficient notice of the changes. OOIL nevertheless encourages you to review the Privacy and Security Statement periodically because the Privacy and Security Statement may change from time to time.

2. Information We Collect

(a) We collect information from you in order to provide you with a smooth, efficient, and customized service while enjoying services provided by OOIL. Some of this information may be of a form or format that identifies you or another person ("personally identifiable information").

(b) The more information you volunteer (and the more accurate it is), the better we are able to customize your experience. Please note that pursuant to Section 2.03(i) of the Terms of Use you have warranted the accuracy of any Data or Content which you may Post.

(c) If you visit the OOIL Web site to read, browse or download information, our system will record the date and time of your visit to the OOIL Web site, the pages viewed and any information downloaded.

(d) To use some of the services provided by OOIL, you may need to complete various online form(s) where you will be required to provide us with personally identifiable information, such as name and e-mail address.

(e) Whenever OOIL collects personally identifiable information, we make an effort to include a link to this Privacy and Security Statement.

(f) OOIL automatically tracks certain information about you based upon your behaviour on the OOIL Web site. OOIL may use this information to do internal research on users' preferences and behaviour to better understand and serve our users. This information is compiled and analyzed on an aggregated and cumulative basis.

3. Third Party Web sites

(a) The OOIL Web site also contains links to the web sites of third party providers of goods and services and web sites of OOIL's Affiliates (hereinafter collectively defined as "Third Party Web sites") who may collect personally identifiable information about you. If you have accessed Third Party Web sites through the OOIL Web site and if those third parties collect information about you, OOIL may also collect or have access to that information as part of our arrangements with those third parties.

(b) Third Party Web sites should contain their own privacy statements. Third Party Web sites are not covered by this Privacy and Security Statement or other provisions of the Agreement and are responsible for informing you about their own privacy practices.

4. Third Party Hosting Service

OOIL contracts with one or more third parties to maintain and host the OOIL Web site. Therefore, any information you submit, including personally identifiable information, will be placed and stored on a computer server maintained by such third party. Your use of the OOIL Web site and any provision of information, Content or Data to the OOIL Web site constitutes your acknowledgement that such information, Content or Data could pass through and may be stored in servers outside the control of OOIL and may be accessed by the administrator of such site and others that gain access to OOIL's server or stored files. You agree that OOIL has no liability or responsibility for any disclosure, authorized or unauthorized, resulting from or arising in connection with such pass through or storage of same.

5. Cookies

(a) OOIL use "cookies" as a fundamental part of our interaction with your Internet browser. The intention is to provide you with a better and more customized service and with a more effective web site.

(b) A "cookie" is a small text file placed on your computer by our web server. A cookie can later be retrieved by our web servers. Most cookies are "session cookies", meaning that they are automatically deleted at the end of a session.

(c) Most of the areas of the OOIL Web site use cookies. Accordingly, if you wish to make full use of the OOIL Web site, it is required that you accept cookies. If your browser is configured to reject all cookies you may be unable to use certain services on the OOIL Web site that require cookies in order to participate.

(d) Advertising networks that serve advertisements onto the OOIL Web site may also use their own cookies.

6. Use and disclosure of information

(a) Information collected from you that is not personally identifiable information may be used or shared as OOIL in its sole discretion deems appropriate. Personally identifiable information collected from you will generally be used by us or third parties or disclosed to third parties in ways set out in this Privacy and Security Statement. By using or accessing the OOIL Web site, you expressly consent to our use or disclosure of the information you provide to OOIL.

(b) Generally, OOIL uses personally identifiable information for marketing purposes and for its own benefit, for example,

(1) to remind us of who you are and to access your account information (stored on our computers) in order to deliver to you a better and more personalized service.

(2) to estimate our audience size and to statistically analyze the usage.

(3) to identify pages you have accessed and Third Party Web sites you have accessed.

(4) to improve our marketing and promotional efforts.

(5) to measure certain traffic patterns, which areas of the OOIL Web site you have visited, and your visiting patterns in the aggregate. We use this research to understand how our users' habits are similar to or different from one another so that we can make each new experience on the OOIL Web site a better one. OOIL may use this information to better personalize the content, banners, and promotions that you and other users will see on the OOIL Web site.

(6) to improve our service.

(7) to provide the service you require.

(8) for administrative and security purposes.

(c) OOIL may also use:

(1) personally identifiable information to deliver information to you that, in some cases, is targeted to your interests.

(2) your email address, your mailing address, and phone number to contact you regarding administrative notices, new features and communications relevant to your use of the OOIL Web site.

(3) information in the file that OOIL maintains about you, and other information OOIL obtains from your current and past activities on the OOIL Web site, to resolve disputes, troubleshoot problems and enforce the Agreement.

(d) OOIL will only disclose personally identifiable information collected from you when:

(1) You have authorized OOIL to do so (including as set forth below);

(2) OOIL has given you notification of the intended use or disclosure and you have not objected to that use or disclosure;

(3) OOIL believes that such disclosure is reasonably necessary to enforce the Agreement, or to respond to claims of violation of the rights of third parties or to protect the rights, property or personal safety of OOIL, its Affiliates (as defined in Section 1.06 of the Terms of Use), Web site users and the public.

(4) OOIL believes that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for national security in the performance of their functions; or

(5) OOIL is authorised, required or permitted by law, governmental or quasi government agencies to disclose the information.

(e) One exception is where you access Third Party Web sites from the OOIL Web site. In that case, information generated by cookies and information about your preferences or other information that you provide about yourself may be shared between that third party, the person hosting the Third Party Web sites, OOIL and/or its Affiliates. OOIL uses the information to provide you with information about products and services that may be of interest to you. It may also be used for the enhancement of services offered through the OOIL Web site and Third Party Web sites.

(f) You hereby consent that OOIL is authorized to disclose personally identifiable information to the following entities, organizations and persons for so long and to the extent, you have not notified OOIL otherwise in writing, or OOIL may be otherwise authorized to share such personally identifiable information pursuant to the immediately preceding subsections 6(d)(1) through (5) (including by subsequent consent):

• OOIL and its affiliates;

• outsourced hosting service providers who manage the services we provide to you (if any);

• your representatives (e.g. your authorised representatives or legal advisers);

• credit-reporting and fraud-checking agencies;

• our professional advisers, including our accountants, auditors and lawyers;

• government and regulatory authorities and other organisations, as required or authorised by law;

• telecommunication and information service providers;

• third party licensors

(g) Except as otherwise expressly discussed herein, this Privacy and Security Statement only addresses the use and disclosure in the first instance of information we collect from you. Personally identifiable information about you provided by another party will for the purposes of this Privacy and Security Statement be deemed to be personally identifiable information collected from such other party, not you, whether such other party originally received the information from you or another source.

7. How we handle E-mails

We may preserve the content of any e-mail that you send us. Any personally identifiable information contained in your e-mail, including your e-mail address, will be used or disclosed in ways set out in this Privacy and Security Statement. Your e-mail message content may be monitored by OOIL's employees and/or agent for trouble shooting and maintenance purposes or where e-mail abuse is suspected.

8. Choice/Opt-out

You have the right to request OOIL not to use or retain personally identifiable information collected from you. However, we may retain in our files some information you have requested to be removed in some circumstances, such as to resolve disputes, troubleshoot problems and/or enforce the Agreement. Further, such prior information is never completely removed from our databases due to technical constraints and the fact that we back up our systems. Therefore, you should not expect that all of your personally identifiable information would be completely removed from our databases in response to your requests.

9. Reviewing and Changing Your Personally Identifiable Information

(a) You can review and change the information you submitted including but not limited to the following:

(1) Your email address.

(2) Your address, city, state, zip code, country, phone number and fax number.

(b) You must promptly update us of any changes to your information.

10. Security of Information

OOIL takes reasonable steps to preserve the security of cookies which it has placed and personally identifiable information that it has collected in accordance with this Privacy and Security Statement. OOIL will use standard industry efforts to safeguard the confidentiality of your personally identifiable information, such as firewalls and secure socket layers. You acknowledge that notwithstanding the steps OOIL takes to ensure security, there can be no guarantee of security on the Internet and that the risk of interception of and tampering with any communication in relation to the OOIL Web site is your own.

11. Important Reminders

(a) This is to remind you that in the Terms of Use you have provided OOIL with all such necessary consents, licenses, permits and authorizations as may be required by any applicable law or otherwise (including all privacy and other data protection regulations and legislation) as shall be necessary for the transfer of personal data to OOIL, its Affiliates and/or third parties wherever they may be situated, and for the use and processing of such data by OOIL, its Affiliates and/or third parties.

(b) Once OOIL receives data transmitted by you, we take reasonable steps to preserve the security of the information in our own systems. We remind you that different means exist and are being developed for deployment in the context of the Internet which will enable you to improve the protection of your data. Therefore, we encourage you to use all available means to protect your data and communications such as access codes to your own personal computer.

(c) Also remember to close your browser window when you have finished your work. This is to ensure that others cannot access your personally identifiable information and correspondence if you share a computer with someone else or are using a computer in a public place.

(d) We also remind you that you may be legally responsible for the processing of data, for example, if you illicitly upload or download and that everything may be traced back to you even if you use a pseudonym.

12. Contacting Us

Should you have any questions about this Privacy and Security Statement, the practice of the OOIL Web site, or your dealings with the OOIL Web site, you can contact:

Orient Overseas (International) Limited

Address : 33/F, Harbour Centre
25 Harbour Road
Wanchai
Hong Kong
Phone: (852) 2833 3167
Fax: (852) 2531 8221
E-mail: webmaster@ooilgroup.com