Privacy Policy

Personal Information Collection Statement

This personal information collection statement (“PICS”) is to inform you, in compliance with the Personal Data (Privacy) Ordinance:

  1. of the purpose for which your personal data collected by us will be used following collection in connection with your use of this website (“Website”) or your purchase of products sold through this Website (“Products”);
  1. to whom your personal data may be transferred; and
  1. to whom you may address data access or correction requests.

We may revise this PICS by amending this page. You should check this page from time to time to take notice of any changes we make.

1. Data user

1.1 (“we”, “us”, “our”) is the data user.

2. Data subjects

This PICS applies to personal data from (“you” or “your”):

(a) Visitors: individuals who visit our Website;

(b) Users: individuals who purchase, request, or receive Products;

(c) Contacts: individuals who contact us through our Website, by email or other means.

3. What we collect

3.1 We may collect, hold, process, transfer and use the following types of personal data:

(a) from Visitors: IP address or other unique device identifiers;*

(b) from Users:

  1. username;
  2. account password;

iii. full name; *

  1. email address; *
  2. billing address; *
  3. shipping address;*

vii. payment information; *

viii. phone number;

(c) from Contacts:

  1. full name; *
  2. email address; *

iii. any other personal data which you provide to us.

* denotes mandatory personal data

3.2 If you do not provide us with mandatory personal data, we may not be able to provide you access to our Website, supply our Products to you, or respond to your communications with us.

4. Purpose and use

4.1 We may collect, hold, process, transfer and use your personal data for any of the following purposes:

(a) to provide our Products to you such as:

  1. to manage and fulfil your orders;
  2. if you choose to register an account on our Website, to create and update your account registered with us; and

iii. to process and facilitate billing and payment for your orders;

(b) to monitor and analyse use of our Website, and to compile aggregate statistics about that usage;

(c) to personalise your experience on our Website, including identifying your preferences and behaviour to better respond to your individual needs;

(d) to improve our Website and our Products based on information and feedback we receive from you and on our analysis of use of our Website and purchase of Products;

(e) for research and development, and by using your personal data to test, research, analyse, and assist with product development (including with machine learning);

(f) for customer service and to help us to more effectively respond to your service requests, to receive feedback and for support needs;

(g) for non-marketing communications relating your orders such as order confirmation and shipment notices;

(h) for technical purposes and for project management needs;

(i) to help maintain the safety, security and integrity of personal data collected through our Website;

(j) to prevent fraud;

(k) for legal proceedings or as required by regulators, government entities and official enquiries;

(l) for direct marketing, but only if we receive your consent (see paragraph 11 below); and

(m) for other purposes directly relating to the above.

4.2 Personal data collected by us may not be used for other purposes, unless:

(a) you have expressly given your consent to the use for the relevant other purposes;

(b) the purpose is directly related to the purpose for which the personal data was collected; or

(c) we are permitted to use the personal data for other purposes arising from an exemption or otherwise in accordance with applicable law and regulation.

5. Transferees

5.1 We may transfer your personal data to the following persons:

(a) our employees and officers;

(b) our subsidiaries, and their employees and officers;

(c) Shopify Inc., an IT service provider engaged by us to manage and maintain the Website and to process your orders made through the Website, and its subsidiaries and parent companies;

(d) Paypal Holdings Inc. and its subsidiaries, and other payment processors or facilitators (“Payment Processors”) whom we may engage to perform payment processes for us in respect of our Products or in the course of our business;

(e) suppliers of our Products (“Suppliers”), to enable shipment of our Products to you;

(f) other service providers and data processors engaged by us such as:

  1. administrative service providers;
  2. IT services and software suppliers;

iii. data analytics providers;

  1. data entry and processing service providers;
  2. cloud service providers; and
  3. credit reference agencies.

(g) our insurers and bankers;

(h) our legal, financial and accounting professional advisors;

(i) other companies, organisations or persons to the extent required by applicable law, regulation, legal process, governmental request or where the disclosure is appropriate due to safety concerns. This includes exchanging your personal data with other companies, organisations or persons for the purposes of fraud protection and prevention; and

(j) other companies, organisations or persons as part of negotiations of any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into that other company.

5.2 By making payments to us through Payment Processors, you will directly enter into an agreement with the Payment Processor and become subject to its terms of use and privacy policy. You should review and, if applicable and at your discretion, indicate your consent to the privacy policy of the Payment Processor, which will not be governed by this PICS or by our privacy policy.

5.3 If we transfer your personal data to other persons, we will ensure the confidentiality of your personal data by including confidentiality or other contractual clauses in the agreements with third parties with whom we share your personal data.

5.4 We may share your personal data with anyone other than as described in paragraph 5.1 above if we notify you and receive your consent beforehand.

6. Cookies

6.1 Our Cookies Policy forms part of this Privacy Policy on which you may access and use our Website.

6.1 A cookie is a small data file that a web site can send to your computer or device when you visit our Website.

6.2 Cookies are used to make websites work in a better, more efficient way, usually by enabling them to recognise you and remember important information that will make your use of a website more convenient (e.g. by remembering your user preferences).

6.3 We use cookies to:

(a) store technical data to ensure that our Website is correctly and efficiently loaded and displayed when you visit our Website;

(b) remember choices you have made or information you have provided (such as your username, language, or the region you are in) so that your preferences are kept for your future visits to our Website, and you do not have to re-authenticate your identity on your future visits;

(c) analyse how you navigate our Website to help us optimise its design; and

(d) track your behaviour and preferences so we can assess the kind of information and products you may be interested in from us.

6.4 We use:

(a) session cookies which are unique to each visit you make to our Website; and

(b) persistent cookies which will not be deleted when you close your browser window and will be activated every time you visit our Website.

6.5 The cookies we use are either:

(a) necessary cookies which are essential to our Website to help you to move from page to page and use our Website’s features;

(b) functionality cookies which allow our Website to remember choices you make, and provide more personal features; or

(c) performance cookies which collect information about your use of our Website and help us to improve the way it works.

6.6 We use a limited number of third party cookies, please find them in our Cookies Policy.

6.7 By continuing to use our Website without notifying us of your refusal to use cookies or withdrawing your consent, you are agreeing to our use of cookies.

6.8 You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser. These settings are usually found in the “options” or “preferences” menu of your internet browser, or by clicking “help” on your browser menu. Removal of cookies may affect your use and experience of our Website.

6.9 We only retain cookies for the duration needed for the function they are used. This function varies according to the cookie.

7. Retention

7.1 We will retain your personal data for the period reasonably necessary to fulfil the purposes for which it was collected. We may also retain your personal data for a longer period if it is necessary for us to do so to comply with our contractual or legal obligations.

7.2 Personal data you have provided to us will be destroyed on expiry of this retention period.

9. Access and correction

9.1 You have the right under the PDPO to:

(a) request a copy of your personal data held by us, unless we are exempted from complying with a data access request; and

(b) request for us to make necessary corrections in respect of any personal data that you consider inaccurate after we have fulfilled a data access request from you. We may refuse a data correction request if we believe the personal data is accurate, an expression of opinion or the proposed correction is inaccurate.

9.2 If you wish to access or correct your personal data, please contact us.

9.3 We reserve the right to charge a reasonable fee to process any personal data access or correction request.

10. Direct marketing

10.1 We may use your personal data collected to directly market our Products to you.

10.2 The type of personal data we use for direct marketing purposes are:

□ your full name;

□ your email address;

□ I do not object to the use of these types of personal data for direct marketing.

□ I object to the use of the types of personal data in the ticked boxes for direct marketing services (but not to the other types).

10.3 The direct marketing activities we intend to conduct using your personal data are:

□ information and promotional material about: our products, products similar to those you previously purchased, discounts and other promotions, and information about us which we believe you may find useful;

□ updates in respect of our Website or Products; and

□ festive greetings.

□ I do not object to receiving these types of direct marketing activities.

□ I object to receiving the types of direct marketing activities in the ticked boxes (but not to the other types).

10.4 If you do not expressly indicate your consent, then we may not use the types of personal data for the direct marketing activities described in this paragraph 11.

10.5 If we receive your consent for direct marketing, we may transfer your personal data for direct marketing purposes to the persons stated in paragraph 5.1 above.

10.6 You may request us to cease using your personal data for direct marketing purposes at any time by emailing us or by replying with the heading “unsubscribe” to any direct marketing communication from us.