It is hoped that the Ordinance can be reviewed as to its extra-territorial effect and applicability to persons operating abroad in light of the borderless internet world, sooner the better, with the assistance of the Respondent. 81. However , since the other grounds of appeal were raised by the Appellant and arguments were heard at the appeal hearing the Board will , discuss and gives its views on the other issues raised in the appeal briefly. H . Whether There Is Collection of Data in Hong Konti 82. On this question, the Board finds that for the reasons given above that the operations of Google LLC all take place outside of Hong Kong and that collection of data on the websites through the internet needs not be done physically in Hong Kong, there is no “collection of data" in Hong Kong. I . 83. Whether There Is Processing or Holding of Data in Hong Korm For the reasons given above, the Board also finds that there is no processing or holding of data in Hong Kong. J . 84, Whether Google LLC Is a User of Data Though Google LLC is not caught by the Ordinance by reason of the territorial limitation of the Ordinance as found hereinabove , subject to the above, Google LLC clearly otherwise falls within the definition of data user under section 2(1) of the Ordinance. That is because Google LLC 57