PERSONAL DATA (PRIVACY) ORDINANCE –
Ulferts of Sweden (Far East) Ltd.
Protecting your privacy
We are dedicated to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”),《中华人民共和国网络安全法》,《电信和互联网用户个人信息保护规定》 and other relevant regulations where applicable.
We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, and the billing and charging of our products and services (if applicable) (collectively, “Product(s) / Service(s)”)) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:
- the name, birth month and other details documented on your Hong Kong Identity Card (including first four alphanumeric characters) or other legal identity card and/or travel document;
- contact details including but not limited to name, address, phone number, mobile telephone number and/or email address , etc.;
- payment details including but not limited to credit card, debit card, other electronic banking Data, authorization number, security code, billing address, delivery address and expiry date;
- customer service information including but not limited to customer service inquiries, comments and repair history;
- purchase and transaction information;
- device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
- information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
- your credit and service history to enable us to assess your eligibility to our offers of Products / Services or to accommodate your request for transfer of Services or your account with us;
- all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
- any other Data as may be required by any members of the Group and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Products / Services.
- In some instances, where required by law to do so, we may seek your consent to process the following types of “Special Data” to us so that we may further improve our Products / Services and/or better tailor the type of information or content that we present to you:
- gender and ethnicity;
- marital status;
- Month of birth;
- education and profession;
- monthly income range;
- hobbies and leisure activities; and
- contact details, etc.
Provision of the Special Data mentioned immediately above is optional although, where the requested Service is a personalised Service or provision of a product is dependent upon your provision of all requested Data, failure to provide the requested Data may prevent us from providing those particular Services to you.
How we collect Data
We collect Data in a number of ways, including from:
- you directly, for example, when you provide Data by phone or via email, attend our functions, complete an application form or agreement for one of our Services, or when you submit your Data through our websites or mobile apps (if applicable); or when you contact us with a query or request; or during the ordinary course of the continuation of our business relationship with you; or when we are legally required to do so;
- third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;
- publicly available sources;
- our own records of how you use our Products / Services;
- your visits on our websites (see “Privacy Data” section below); and/or
- your participation in surveys or marketing promotions organised by us or on our behalf, etc.
Participation in Voting Activities or Activities with Prize Incentives
When participating in promotional activities organized by us or online media or co-organized by our business parties, users may not be required to be registered as our member but will be required to provide personal data for registration.
To better serve your needs and preferences, our web servers may collect Data relating to your website or device or app (if applicable) activity. We may also collect aggregated, anonymous, statistical data on the server’s usage so that we may better cater to the behaviour of users of our websites. This type of Data may include, but is not limited to:
- browser type, version and user agent;
- operating system;
- IP (Internet Protocol) address and/or domain name;
- connection data, statistics on page views and/or referral URLs;
- device ID, location and phone contacts;
- links or images clicked on;
- cookies and/or browser, app or web server log data; and
- device and software characteristics and/or configuration.
How we use your Data
We may collect, retain and use your Data for the following purposes:
- to verify your identity;
- to manage and fulfil purchase and repair orders, facilitate delivery and to provide after-sale services;
- manage our accounts and records;
- send service related communications, including announcements and administrative messages such as order confirmation;
- undertake credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our platforms and services secure;
- to carry out matching procedures, as defined under the Ordinance;
- to verify your eligibility to our offers and/or promotions or other events;
- to provide you with promotional benefits, updates, offers and invitation to events;
- to promote and market our Products / Services to you;
- to provide suitable advertisement and website contents to you;
- to provide suitable products or services to you;
- to tailor our products or services to your preferences;
- to provide anonymous report and to send member notice to us or our clients;
- to respond to complaints or compliments received;
- to conduct credit checks and detect fraudulent activities in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) or any other relevant regulations and in relation to other compliance purposes;
- to perform research or analyses so that we may improve and optimise the Products / Services that can be made available to you;
- to conduct surveys and marketing, promotional, behavioural scoring for business operations and/or planning purposes;
- to carry out market and product analyses in order to generate statistical or actuarial reports (containing aggregated data that does not relate to any identified or identifiable individual);
- to contact you regarding administrative notices and communications relevant to your use of our websites and to respond to your request. We may also use your information to match user information with third party data (i.e. to compare two sets of persona data collected for different purposes). By subscribing to our website or by logging-in, you consent to carry out this matching procedure when we deem it is necessary in order to provide our Products/Services;
- to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Products / Services to you;
- to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
- to maintain, enhance and develop our products and service offerings;
- to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products and customer base; performing data analystics; and performing accounting, auditing and other internal functions);
- to comply with applicable laws in or outside Hong Kong as may be required by applicable government authorities, courts, law enforcement, or regulatory or investigation bodies, in relation to the supply of Products / Services to you, including to assist in the prevention, detection of crime or possible criminal activities; and
- to distribute our Products collection brochures and/or promotional materials as well as those of our business partners and counterparties.
Our legal basis for using your Data including how we disclose your Data
We have a legitimate interest in properly administering the Products/Services. In addition, our use of your personal data may be necessary for the performance of the Products/Services that you have requested. In order to provide the Products / Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organisations or parties outside of the Group (which may be within or outside of Hong Kong) (collectively, “Organisations”). Your Data is disclosed to these Organisations for the strict purpose of enabling us to supply our Products / Services to you but is not applicable to any Organisations which are not owned by the Group or of which its company policies are not controlled by the Group as well as any persons employed or managed by the Group.
In some circumstances as mentioned above, we may need to ask for your consent to use your Special Data where required by law to do so.
These Organisations provide support services to our businesses and operations including without limitation:
- customer enquiries;
- mailing operations;
- billing and debt-recovery functions;
- information technology services;
- installation, maintenance and repair services;
- marketing, advertising and telemarketing services;
- market research;
- customer usage and behavioural analysis;
- process management;
- surveys; and
- website usage analysis, etc.
We take the required steps to ensure that these Organisations are bound by appropriate confidentiality and privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing).
In addition, we may disclose your Data:
- to your authorised representatives and/or your legal advisers when requested by you to do so;
- for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties:
- telecommunications network operators;
- our affiliates, overseas offices, assignees, transferees and representatives;
- our professional advisers, including our accountants, auditors, lawyers and insurers;
- to banks, hotels, insurance companies and billing agents;
- to any third party that purchases, or to which we transfer, all or substantially all of our assets and business sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information;
- to government and regulatory authorities and other organisations, as required or authorised by law;
- to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business; and/or
- to charities or non-profit organisations, etc.
Direct Marketing (if applicable)
We may, in compliance with applicable laws, rules, regulations and licence requirements, use your Data (including without limitation name, contact information, phone number, residential/office address and email address), for us (including the Group and its respective subsidiaries, affiliates and associated companies) and our respective dealers, suppliers, licensors, providers, advertising clients and/or business partners (collectively, “Service Providers”) to provide you with direct marketing content (pursuant to which we may or may not receive remuneration in return), including sending to you notices and/or updates about gifts, discounts, privileged offers, benefits and promotions related to Products / Services offered by us and/or the Service Providers, including without limitation: entertainment, device accessories, mobile applications and software, lifestyle, networking events, travelling, sports, music, gaming, transportation, household products, food and beverages, hotel, banking, finance, insurance, wealth management services, investments, health and wellness, beauty and cosmetics products and services, entertainment, films, cinemas, fashion and accessories, computers and electronics, social networking, technology, e-commerce, logistics, retail, real estates and shopping malls, home and décor, media and high-end consumer products and services. Marketing may be carried out in a variety of ways (such as in the form of a letter, bill insert/message, email, digital SMS, MMS, instant message, by telephone, social media or advertisements on websites or other means).
We will honour each individual’s request to not use his/her Data for the purposes of direct marketing. You may opt-out from receiving direct marketing material and/or communications from the relevant Service and/or any notices from us. At the same time, you may resume receiving the same (if you have previously opted-out of receiving such material and/or communications from the relevant Service) by making a written request to our Data Protection Officer together with your registered name and service account number, registered telephone number or login name (as applicable).
Transfer of Data outside Hong Kong
At times it may be necessary and/or prudent for us to transfer and/or store your Data to places outside of Hong Kong, for instance, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data were collected. In the event that we do transfer your Data outside of Hong Kong, we will do so in compliance with the prevailing requirements of the Ordinance, other relevant regulations and the GDPR where applicable.
The safety of your Data is important to us
When we pass your Data to third party Organisations for them to process, we seek to ensure that they have appropriate security measures in place to keep your Data safe, to the extent necessary for them to provide their services and to comply with applicable principles in relation to data protection. Some of the people we share your Data with may process it overseas. You can contact us for more information about the safeguards we use to ensure that your Data is adequately protected in these circumstances.
Retention of your Data
We will retain your Data in accordance with our internal policies. Our policies are in compliance with the Ordinance, the GDPR and other relevant laws where applicable, and cover the following principles:
(a) Data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
(b) Data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.
Your right to access, correct and delete Data
We take all reasonable precautions to ensure that the Data we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that Data depends to a large extent on the Data you provide. You have a right to request access to, and correction of, your Data and we recommend that you:
(a) let us know if there are any errors in your Data; and
(b) keep us up-to-date with changes to your Data.
If you wish to access or amend any of your Data we hold, or request that we delete any of your information that is no longer necessary for the provision of our Services, you may contact us in the manner as set forth under the “How to Contact Us” section.
You may exercise your right of access and correction by writing to our Data Protection Officer at the details stated in the “How to contact us” section below.
You may decline to share Data with us and/or withdraw any consents which you may have provided, in which case, we may not be able to provide you with some of our Services.
At any time, you may object to us holding or processing your Data, on legitimate grounds, save and except as otherwise permitted by the applicable law.
Unless specially required or requested by us, please do not send or publish any personal sensitive data (e.g. contents in relations to race, political views, religious or other beliefs, health record, criminal record or chamber membership, etc.) to us or through our websites or social media platforms. If we specially required or requested your provision of sensitive data, we must obtain your prior express consent.
How to contact us
For all issues and enquiries regarding our compliance with our obligations under the Ordinance, the GDPR and other relevant laws where applicable, and any request for access to, correction or deletion of your Data, please contact our Data Protection Officer in writing at:
Ulferts of Sweden (Far East) Limited
Room 1905-1907, 19/F., Emperor Group Centre, 288 Hennessy Road, Wanchai, Hong Kong
or via email to: email@example.com
To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.