at TREE, your privacy is important to us. we are committed to safeguarding the privacy, confidentiality and security of your Personal Data (as defined below) by complying with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (“Ordinance”) and the European Union’s General Data Protection Regulation.
PERSONAL INFORMATION COLLECTION STATEMENT
1. when you visit our Website or our other social media, shop in our stores, subscribe to our mailing list, call our stores, utilise our services, participate in any of our promotional activities, or interact with us in any way, you may choose to provide us with your personal data (“Personal Data”), including but not limited to your:
(b) mailing address;
(c) billing address;
(d) delivery address(es);
(e) email address;
(f) postal code (for customers outside of Hong Kong);
(g) phone number;
(h) credit card numbers and other payment information;
(i) shopping preferences;
(j) shopping cart and purchase records;
(k) social media information;
(l) profession (if you are an interior design professional); and
(m) any other personal data you provide to us.
2. you agree that all the Personal Data provided by you to us may be used and retained by us for the following purposes and for such other purposes as may be agreed between you and us or required by any applicable laws and regulations from time to time:
(a) to provide you with our services;
(b) to deliver the goods purchased by you;
(c) to process the transactions between you and us;
(d) to analyse, verify and/or check your credit, payment and/or status in relation to the transactions between you and us;
(e) to carry out data sorting and analysis to enable us to better understand your preference and buying behaviour and to provide services and goods better tailored to your needs, and assist us in selecting goods and services that are likely to be of interest to you;
(f) to carry out our normal management, operation and maintenance of the performance of the services;
(g) to design new, or improve existing, services provided by us or our affiliates to you, and to research for service improvement;
(h) to design marketing strategies;
(i) to carry out investigations of complaints and suspected suspicious transactions;
(j) to prevent or detect crime;
(k) to make relevant disclosures as required by any applicable laws and regulations;
(l) to carry out aggregated behavioral analysis;
(m) to discharge our duties under any applicable laws and regulations;
(n) to carry out any internal control analysis or internal policy-making; and
(o) to satisfy the relevant requirements in our fund raising activities or other commercial transactions.
3. the decision to provide us with your Personal Data is optional. however, if you choose not to provide the requested Personal Data, you may not be able to use some or all of the features of our Website or our services.
4. we implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which it was collected. the retention period applied to various types of personal data that we hold varies dependent on the respective data collection/usage purpose and relevant legal requirements.
5. likewise, other companies also may, with your prior consent, forward to us additional Personal Data (such as, for example, names, mailing addresses and email addresses, as well as demographic and other usage information). unless we have received your prior express consent, we will only use such additional Personal Data for the purposes for which they have been collected or for other directly related purposes.
DISCLOSURE TO THIRD PARTIES
6. we may disclose and transfer your Personal Data (whether in Hong Kong or abroad) to:-
(i) our employees and officers;
(ii) any other business entity that is controlling us, controlled by us, or under common control with us, and their employees and officers;
(iii) any agent, third party contractors or vendors (“Service Providers”) who are under a duty of confidentiality to us, and who provide administrative, data processing, research and marketing, distribution, telecommunications, IT, shipping, financial, insurance, consultancy, professional or other similar services to us, to enable us to carry on our business and to better fulfill customer orders, manage, store and enhance customer data, and comply with postal regulations;
(iv) any of our actual or proposed assignees or transferees of our business in connection with a merger, sale or transfer (whether of assets or shares), and their professional advisors; and
(v) any enforcement authority to whom we are required or we believe it appropriate to make disclosure.
8. 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 will share your Personal Data.
9. we may share your Personal Data with anyone other than as described in section 6 above if we notify you and receive your consent beforehand.
10. some persons to whom we transfer your Personal Data may be located outside Hong Kong, in locations that may not have in place data protection laws which are substantially similar to Hong Kong, and this may mean your personal data may not be protected to the same or similar level as that in Hong Kong.
11. when you visit our Website, we may collect more information, whether or not within the scope of Personal Data, including but not limited to your Internet Protocol address (and domain name), the name of the Website directing you, the type and configuration of your browser, your language settings, your geo-location, your operating system, the time/duration of your visit and the pages visited, as well as your clicks, activities and other usage information on our Website. we use such information for understanding how to make our Website more available and user-friendly to our customers.
13. we may directly or through a Service Provider send emails that you have agreed to receive. web cookies are used in those email messages and on our Website to help us measure the effectiveness of those emails and for other analytical purposes. you can "opt out" of this email cookie at any time by deleting your name from the email mailing list.
UPDATING YOUR PERSONAL DATA
14. updating your contact information is quick and easy. just contact us - include your previous and current full name, mailing address, email address and phone number. please understand that updates may take a little time to process.
LINKS TO WEBSITES AND SERVICES
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
16. we cooperate with government and law-enforcement officials and private parties to enforce and comply with the applicable laws and regulations. we may disclose your Personal Data and any other information about you to government or law-enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas); to protect the safety, property or rights of us or of any third party; to prevent or stop any illegal, unethical or legally actionable activity; or to comply with the applicable laws and regulations.
17. all processing of Personal Data shall be conducted according to the Data Protection Principles under the Ordinance, including:
(a) personal data must be processed lawfully, fairly and transparently;
(b) personal data must be accurate and kept up to date with every effort to erase or correct;
(c) personal data must be processed in a manner that ensures the appropriate security.
USE OF PERSONAL DATA FOR DIRECT MARKETING
18. with your consent, we may use your Personal Data collected for direct marketing.
19. the type of Personal Data we use for direct marketing purposes are:
- mailing address (including postal code for customers outside of Hong Kong);
- shopping preferences;
- shopping cart and purchase records;
- email address;
- phone number;
- social media information;
- profession (if you are an interior design professional); and
- any other personal information for which we have obtained your consent to use for direct marketing.
20. the direct marketing activities we intend to conduct using your Personal Data are:
(a) information and promotional material about: our Website, goods and services similar to those you previously purchased, discounts and other promotions, and information about TREE which we believe you may find useful;
(b) updates in respect of our Website, goods or services;
(c) festive greetings;
(d) newsletters about our Website, goods or services;
(e) invitations to join our events; and
(f) abandoned cart prompts should you have a purchase yet to be completed on our Website
21. we will only use the types of Personal Data described in section 19 for the direct marketing activities described in section 20 if we have received your consent. if you do not expressly indicate your consent, then we may not use the types of Personal Data for the direct marketing activities.
22. if we receive your consent for direct marketing, we may transfer your Personal Data for direct marketing purposes to the persons stated in section 6 above.
23. you may request us to cease using your Personal Data for direct marketing purposes at any time by emailing us at: firstname.lastname@example.org, or by clicking the “unsubscribe” link included in any direct marketing communication from us.
RIGHT OF ACCESS AND CORRECTION
25. you have the right to know whether TREE holds your Personal Data and to request access to and/or correct any inaccuracies of your Personal Data held by us. if you wish to access or correct your Personal Data, or make any related complaint or request, please contact our Data Protection Officer at email@example.com. we may charge a reasonable fee to process any personal data access request.