Respecting and protecting the privacy of its customers (“you”) is important to Chow Sang Sang Holdings International Limited (“CHOW SANG SANG”) and its subsidiaries (together “the Group”). This policy is, unless otherwise stated, applicable to the Group in general. References to “we”, “us” and “the Company” shall mean the relevant company(ies) within the Group that control the collection, holding or use of your personal data. We hope the following policy will help you understand how we collect, use and safeguard your personal data.
Please note that this policy does not apply to Chow Sang Sang Securities Limited or its website 338.net, the privacy statement of which is available in the said website.
This policy is prepared with reference to the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong (the “Ordinance”) and the Personal Data Protection Act (Law 8/2005) applicable in Macau (the “Act”). Throughout this policy, the meanings of the terms “personal data” and “direct marketing” are the same as defined in the Ordinance unless otherwise specified. To the extent that the Act is applicable, references to “personal data” shall also include personal data as defined in the Act and references to “direct marketing” shall also include direct marketing as defined in the Act.
1. How We Collect and Use Personal Data
1.1 The Company collects your personal data to ensure we can fulfil our service promises and offer you a personal experience online and in our stores.
1.2 Different levels of personal data may be gathered depending on your usage of our services:
- If you are not a registered user, you are browsing the Sites anonymously as a guest. We will not collect any personal data from you but you may not be able to use all services and features that we offer to registered users.
- You need to input your personal data to register in order for us to process some features and services that we offer to our registered users, such as email updates or requesting information from customer service. We may store some of the data provided for these features and services for such purpose. You have the right to refuse to provide your personal data to us. However, certain services and functions may not be available to you if you do not supply us with data marked with an asterisk (*) on the data collection form.
- You can place an order with us to purchase our products as a registered user on the Sites. We will only collect information necessary to fulfil the relevant order (such as your name, contact details and payment information)
- You may from time to time provide us with your personal data at our physical stores, at certain Sites and/or at third party eCommerce websites designated by us from time to time. For instance, you may be required to provide us with your personal data when you apply to be a Star Shopper; to purchase from us or make enquiries at our stores or over the telephone; to use our concierge services; to provide feedback to us (such as via a survey); or to participate in our promotions and events.
- You can also log into the Sites using sign in services that bridge your social media log in information with the Sites. These services will authenticate your identity and provide you with the option to share certain personal data with us such as your name and email address to pre-populate the sign up form for the Sites. These services give you the option to post information about your activities on the Site to your profile page to share with others within your personal network.
1.3 We may use your personal data for the following purposes:
- Responding to your enquiries;
- Matching personal data with information you provided in one of our stores;
- Sending you direct marketing communications or otherwise marketing products and/or services to you by direct marketing means. Please refer to the section "Direct Marketing" for more information;
- Marketing, other than by direct marketing means, products and services of the Group and/or third parties;
- Communicating with you based on the personal data that you provide to us, such as by phone, email, SMS, smartphone app push notifications or postal mail;
- Processing features such as sharing a product with a friend, making a store appointment, maintaining your wish list, maintaining your shopping bag on the Sites, and fulfilling any orders you may make with us (including verification and security checks of your details, and processing of your payments);
- Conducting surveys;
- Analysing trends and behaviour as well as conducting customer surveys to continuously improve our offerings and services;
- Enabling us to meet the requirements to make disclosure under the requirements of any law, regulation or court order binding on us; and
- All purposes directly related to the above.
1.5 We automatically collect anonymous data relating to your online session to gather statistical information on our server's usage and to help us better meet your demands and expectations. This may include but is not limited to your browser type and version, your operating system and your IP address and/or domain name.
2. Third parties
2.1 This policy applies to the Sites, but not to websites maintained by other companies or organizations, websites to which we may link nor third parties with which we engage in joint promotions (save for third party eCommerce websites designated by us from time to time which expressly collects personal data on our behalf).
2.2 If you follow a link on the Sites to any third party websites or submit personal data to third parties via the Sites or any third party websites, please check and read the personal information collection statements of such third parties before submitting your personal data. Note that we do not accept any responsibility or liability for such statements or the acts or omissions of such third parties.
3 Security and Protection of Your Personal Data
3.1 Access to your personal data collected by us is protected by physical, electronic and managerial measures and we therefore limit the access to your personal data to our employees and agents who need it to do their jobs.
3.2 To protect your personal data when you use the Sites, we will encrypt any personal data you transmit to us using Secure Socket Layer (SSL) — an industry standard for encryption over the Internet to protect the data you send us.
3.3 We will never ask you for your personal password either in writing or on the phone. Please take reasonable care in protecting the access to your password and computer from any unauthorized use.
5. Disclosure of Your Personal Data
5.1 Your personal data held by the Company will be kept confidential but we may disclose or transfer your personal data to the following parties in Hong Kong, Macau, Taiwan, Mainland China or elsewhere, where such disclosure or transfer is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected (save that we will not disclose or provide your personal data to third parties for their use in direct marketing):
- Any subsidiaries of the Company, or affiliates of, or companies controlled by, or under common control with, the Company;
- Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided by you; and
- Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such data confidential, provided such person or company has a legitimate right to such data.
5.2 Your personal data may also be disclosed by us to any person or persons pursuant to any legal obligations or as required by court of law. In addition, your personal data may be disclosed by us under any of the exemptions described in Part VIII of the Ordinance or (if Macau law is applicable) under any of the exemptions prescribed by Macau law including without limitation the Act.
6. Direct Marketing
6.1 We intend to use your personal data provided to us for direct marketing purpose. We may not use your personal data for such purpose unless we have received your consent to such use. In this connection, please note that:
6.1.1 Your name, salutation, email address, phone number, city of residence, address, postal code, date of birth, language preference, transaction pattern and behaviour and demographic data held by us from time to time may be used by us in direct marketing.
6.1.2 The following classes of goods and services may be marketed by us using your personal data:
- (a) Jewellery products, watches and accessories;
- (b) Customer services in relation to (a) above;
- (c) Social networking services;
- (d) Customer reward, loyalty or privilege programs, (including Star Shopper and Star Dollars) and related services, products and facilities;
- (e) Dining services, food and beverages, sporting equipment, music, films, television and other entertainment, clothing and accessories, luggage and bags, beauty products and cosmetics, personal health and hygiene products, beauty and health services, computers, computer software and mobile applications, toys, household goods, printed matters including books, newspapers and magazines, electronics, home furnishings, housewares, flowers and plants, automobiles, transport and travel services, holiday and leisure services, advertising services, professional services, concerts, sporting and special events, hotel and accommodation services, payment services and instruments;
- (f) Online shopping services relating to the matters above;
- (g) Promotional/social events relating to the above matters; and
- (h) Products and services offered by our co-branding partners
6.2 We will use your personal data in direct marketing only in accordance with the Ordinance and (if applicable) the Act and, in all cases, subject to your consent.
6.3 If you do not wish us to use your personal data in direct marketing, you may exercise your opt out right (upon which we must cease to use your personal data in direct marketing) at any time via email or phone at no charge by us.
Our relevant email and phone for such purpose can be found in paragraph 8.2.1 below.
6.4 If you do not wish us to use or provide to our Associated Companies your personal data for use in direct marketing, you may exercise your opt out right at any time via email, phone or our website at no charge by us.
7. Our Corporate Policy
7.1 The Company will endeavour to fully comply with the obligations and requirements of the Ordinance. Our officers, management and staff members will, at all times, respect the confidentiality of and endeavour to keep safe any and all personal data collected and / or stored and / or transmitted and / or used for, or on behalf of, the Company.
7.2 The Company will endeavour to ensure all its collection, storage, transmission and other handling of usage of personal data will be done in accordance with the Ordinance.
8. Your data access rights
8.1 Under the Ordinance and (if applicable) the Act, you have the right to:
- check whether we hold data about you;
- request access to such data; and
- request correction of such data and (if the Act is applicable) deletion of such data.
8.2 You may make the above requests by:
8.2.1 Contacting our Data Protection Officer
Chow Sang Sang Holdings International Limited
27/F, 9 Wing Hong Street,
Cheung Sha Wan, Kowloon
Tel: (852) 2192 3123
Email: email@example.com ;
8.2.2 Using your Online Account you established on our websites; or
8.2.3 Completing and submitting our relevant prescribed form at one of our stores.
8.3 In accordance with the Ordinance and (if applicable) the Act, we have the right to charge a reasonable fee for processing any data access request.
We reserve the right to amend this policy at any time and will place any such amendments on this page. To the extent permitted by the Ordinance and (if applicable) the Act, this policy is not intended to, nor does it, create any obligations on the Company. Nothing in this policy shall limit the rights of data subjects under the Ordinance or the Act.
Updated 1 January 2017