A1. COLLECTION OF PERSONAL DATA
A.1.1 Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your account.
A.1.2 We may ask you to provide personal information (“Personal Data”) when you use our website and related services, or when you apply to join as a member of any rewards or loyalty programme(s) (“Programmes”) operated, from time to time, by us or our indirect or direct parent companies, or any of our direct or indirect subsidiaries or affiliates, or any other entity that controls, is controlled by or is under common control with us, Lovini Holding Company Limited (whether through direct or indirect ownership of fifty (50%) or more of the shareholding or voting rights, or the right to control the management of the entity or to appoint or remove a majority of the board of directors) (“Affiliates”). For the avoidance of doubt, Programmes include (without limitation) any Programmes that may or may not bear the words “Lovini” in their name, or any sub-club or ancillary program, or any Programmes operated under any Business Units or by our Affiliates of which you are a member or which you have applied to join at any time. The Personal Data that we may ask you to supply includes without limitation title, name, month of birth, telephone number, email address and residential address.
A.1.3 Please note that it is mandatory for you to provide certain categories of Personal Data (as specified at the time of collection). In the event that you do not provide any Personal Data marked as mandatory, we may not be able to provide you with our products or services (including registering you for any Programme or providing you with related offers and benefits).
A2. USE AND DISCLOSURE OF PERSONAL DATA
A.2.1 If you provide any Personal Data to us, you authorise us to collect, retain and use Personal Data about you for the following purposes:
a. processing your application for membership under any of the Programmes or for opening a user account with us;
b. operating, processing, maintaining, administering and/or managing your membership under any of the Programmes or any user account with us (where applicable);
c. verifying your identity;
d. verifying your eligibility to participate in any of the Programmes or for opening any user account with us;
e. providing you with rewards, birthday promotions, vouchers or services under any of the Programmes or lucky draws;
f. maintaining, updating, administering and processing a record of your activities in relation to the Programmes (including rewards and offers provided to you, and loyalty points accumulated and redeemed), and your purchases, orders, refunds and exchanges in relation to any products or services provided by Lovini Holding Company Limited, any other Business Unit and/or by any of our Affiliates;
g. communicating with you in relation to your queries, feedback, complaints or claims, your membership or user account with us, your activities under your membership or user account with us or under any of the Programmes;
h. providing you with a more personalised experience in respect of our website, mobile applications, products, services and/or your membership or user account with us or under any of the Programmes;
i. performing research, statistical analysis or data analytics in relation to the Personal Data collected by us trading as Lovini Holding Company Limited or under any Business Unit, or collected by or on behalf of any of our Affiliates: (i) in order to improve and/or assess the business, marketing or strategic operations and plans, and the products and/or services of Lovini Holding Company Limited, the Business Units or our Affiliates; and (ii) for marketing and promotional purposes pursuant to A.2.4;
j. providing you with a log-in ID for our website, mobile application and/or your membership with any Programmes;
k. in connection with establishing, maintaining, administering and/or running any Programmes;
m. enforcing our rights or our Affiliates’ rights against you in any legal proceedings, or to defend ourselves or our Affiliates against any claim in relation to you; and
n. making such disclosures as may be required for: (i) any of the above purposes; (ii) as required by law; (iii) as requested by any law enforcement or government or regulatory authority; or (iv) in respect of any queries, feedback, complaints or claims made by you, or any potential data breach or leakage.
A.2.2 You further agree that we may disclose and transfer (whether in Hong Kong, Macau or abroad) your Personal Data to our Affiliates, and/or to third party services providers engaged by us or our Affiliates to provide (a) data entry services, (b) customer database management services, (c) customer contact services (and service providers may contact you regarding promotions, products rewards, vouchers and redemption letters and customer service on behalf of us or our Affiliates), (d) secure data disposal services, (e) any assistance in relation to the provision of our products or services to you (including, without limitation, processing, effecting and verifying sales, orders, refunds and/or exchanges relating to products available for sale in our shops or through our website, and other customer service), or (f) any other front-end, back-end or ancillary services required directly or indirectly to enable us to carry out any of the purposes specified at A.2.1 (or a directly related purpose) (“Third Party Service Providers”). These Third Party Service Providers are under a duty of confidentiality to us and/or our Affiliates, and are only permitted to use your Personal Data in connection with the purposes specified at A.2.1 above, and not for their own purposes (including direct marketing).
A.2.3 You agree that we may disclose, transfer and share (whether in Hong Kong, Macau or abroad) your Personal Data amongst the Business Units and/or our Affiliates for the purposes specified at A.2.1, including (without limitation) storing, processing and enabling access to your Personal Data under a single customer database used by us (across Lovini Holding Company Limited and all Business Units) and our Affiliates. When necessary we may also disclose and transfer (whether in Hong Kong, Macau or abroad) your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations for purposes specified at A.2.1(n) above.
A.2.4 We may only use your name, phone number, residential/other address, email address, personal preferences, profile, previous purchase history and/or information regarding your spending habits, whether or not each of such data was collected by us (trading as Lovini Holding Company Limited or under any of the other Business Units) or by our Affiliates (“Marketing Data”), with your consent or with your indication of no objection, in order to provide targeted advertising and/or to send promotional or marketing materials to you relating to: (i) any Programme (including the offers, rewards or good or services that may be redeemed in relation to any Programme); or (ii) any offers, promotions, competitions, goods or services provided or offered by our retail stores, Business Units, Affiliates or partners (“Marketing Materials”). Such goods and services for each of the foregoing shall include the following classes: retail, cosmetics and beauty, health, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, betting (lucky draw), dining, travel, transportation, banking, electronics, home, household, textile, tele-communication, food and beverage, grocery, office and business supplies, technology, outdoor, furniture, lighting, décor, media (including digital), e-commerce platform and facilitator (including online trading, payment and auctions), and publications.
You have the right to choose not to receive any Marketing Materials at any time, by sending your request in writing to the address in F.2 (no fee will be charged).
A.2.5 We may share aggregate data that does not allow you to be identified with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services.
A.2.6 Any Personal Data supplied by you to us or our Affiliates will be retained by us and will be accessible by our authorised employees, any Third Party Service Providers engaged by us, our Affiliates and third parties referred to at A.2.3 above, for or in relation to any of the purposes stated in A.2.1 herein.
B.2 Any questions, comments, suggestions or information other than Personal Data sent or posted to the site, or any part of the site, by visitors will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any Affiliates for example, in connection with the development, manufacture and marketing of products and services and to meet customer needs.
C. SAFETY OF PERSONAL DATA
C.1 All reasonable efforts are made to ensure that any Personal Data held by us is stored in a secure and safe place, and accessed only by our Affiliates, authorised employees or authorised Third Party Service Providers.
C.2 You should be aware that no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet.
E. INFORMATION COLLECTED WHEN YOU USE OUR WEBSITE
We may use ‘cookies’ on this site in order to:
* enable tighter security
* enable online customers to keep browsing
* personalise sites for customers
* build online customer or visitor profiles
Cookies are pieces of information stored in your hard-drive about your preferences on our site, which enable the site to be tailored to you in future visits. Customers who want to disallow cookies can do so on their web browser. However, by disabling cookies you may not be able to access all parts of our website.
F. RIGHT TO ACCESS/ CORRECT PERSONAL DATA
F.1 Under the HK Privacy Ordinance, you have the right of access to Personal Data held by us about you and to request correction of your Personal Data.
Address: Unit 402, 4/F, Albion Plaza, 2-6 Granville Road, Tsim Sha Tsui, Hong Kong
F.3 In accordance with the HK Privacy Ordinance Privacy Act, we reserve the right to charge you a reasonable fee for the processing of any data access request.
G. RIGHTS OF THIRD PARTIES
I. PREVAILING LANGUAGE