4.15 The question may arise as to whether the requirements under this Part applies to the situation where personal data is provided to another person due to a merger or business amalgamation involving a sale of business or shares. The short answer is that the requirements under this Part do not apply if the personal data provided is not for use in direct marketing.
Otherwise, consent has to be obtained from the data subject. Data users should be mindful that if the provision is for use in direct marketing under the guise of a merger or acquisition, they are still liable under the Ordinance.
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