1. Our Commitment
This Policy applies to all products and services provided by us to our customers and business partners, including but not limited to products or services offered through our apps, our Web site, our store locations, or any program or software creating any rewards or loyalty program (including “Friends of Found”). We are committed to protecting your personal data and your privacy and pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance“) in Hong Kong and any other applicable legislation in respect of that information. In order to do that, we will protect and handle your personal information in accordance with the terms and conditions set out in this Policy.
2. Collection of Personal Data
2.1 Your privacy is important to us and we will not collect excessive personal information from you.
2.2. When you provide personal data to us, including through our app, our Web site, our store locations, or in connection with Friends of Found, we may ask you to provide certain personal information, including without limitation your name, date of birth, gender, phone number, email address, contact/delivery address, membership number and credits, and your payment information (collectively, “Customer Data“). Please note that it is necessary for you to provide certain fields of Customer Data to us, as specified at the time of collection, in order for us to provide you with our products and services.
2.3 In addition to Customer Data, we may also collect from you information concerning the products or services you purchase, including your preferences and your interaction with our apps, our Web site, our store locations and information from your phone or device, including cookies, log files, and Web beacons that provide information on your use of our apps or Web site (collectively, the “Consumer Data” and, together with your Customer Data, the “Personal Data”).
2.4 We will collect most Personal Data from you directly, although we may also collect Personal Data about you from authorized third parties.
3. Use and Transfer of Personal Data
3.1. We may collect and process your Personal Data. By providing your Personal Data to us you authorise us to collect, retain, and use your Personal Data for the following purposes: (a) operating or managing your account on our apps, our Web site, our store locations, or in connection with Friends of Found; (b) verifying your identity; (c) providing you with rewards, promotions, vouchers, or services under Friends of Found; (d) updating you on our latest products or services; (e) providing you with customer services and responding to your queries; (f) collecting statistics and performing analysis in order to develop or improve our services; (g) for marketing and promotional purposes; (h) for making such disclosures as may be required for any of the above purposes or as required by law; (i) in respect of any feedback or claims made by you; and (j) for administrative purposes.
3.2 You further agree that we may disclose and transfer (in Hong Kong or overseas) your Personal Data to third-party service providers (“Service Providers“) engaged by us to provide
(a) data entry and analysis, (b) customer database management, (c) customer contact services, (d) secure data disposal services, and (e) data storage services. The Service Providers are under a duty of confidentiality to us and are permitted to use your Personal Data only in connection with the purposes specified above and not for their own purposes (including direct marketing).
3.3. When necessary we may also disclose and transfer (in Hong Kong or overseas) your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations (collectively, the “Other Interested Parties”) for the purposes specified in clause 3.1(h) above.
3.4. We may share unidentified aggregate data 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 our products and services.
3.5. Any Personal Data supplied by you will be retained by us and will be accessible by our employees, the Service Providers, and Other Interested Parties, for or in relation to any of the purposes specified above.
3.6. We will retain your Personal Data for as long as necessary for the purpose for which it was collected or for any other permitted purpose. Personal Data which is no longer needed will be irreversibly anonymised or destroyed.
4. Safety of Personal Data
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 authorised employees, authorised Service Providers, or Other Interested Parties. Notwithstanding the foregoing, no system is completely secure and no information provided over apps or the Internet can be guaranteed to be completely secured. Thus, we cannot guarantee the security of any information that you transmit to us or receive from us by any relevant apps or the Internet.
5. Use by Third Parties
6. Access or Amend Personal Data
6.1. Under the Ordinance, you have the right of access to Personal Data held by us about you and to request correction of your Personal Data.
6.3. In accordance with the Ordinance, we reserve the right to charge you a reasonable fee for the processing of any Personal Data access or correction request.