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Privacy statement on use of personal data in direct marketing

Our Group respects your legal rights under the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) and is committed to protect your personal data. In view of the recent amendments introduced to the Ordinance in respect of direct marketing activities and as a user of such data, we provide this privacy statement on the policies of our Group for your information.

1. General

1.1    This privacy statement serves to explain the use of personal data in direct marketing activities undertaken by our Group, and the term “we”, “our” and “us” may refer to anyone within the Group.
1.2    If there is any inconsistency or difference between English and Chinese versions of this privacy statement, the English version shall prevail.
1.3    This privacy statement may be amended from time to time and you may refer to the updated version on our website at http://www.dksh.hk/DMprivacystatement.
1.4    In this privacy statement, “Direct Marketing” may include: (i) communicating with you in relation to our products, services, offers and/or events; (ii) marketing, advertising, offering, sales, distribution, logistics and after-sales services; (iii) cross brand joint promotions, events and/or offers with other brands; (iv) reward, loyalty or privilege programs and related services and products; and (v) donations and contributions for charitable and/or non-profit making purposes, all of the above relating to baby/infant foods & products, cereals, confectionaries, cosmetics, fashion & accessories, foods, general merchandise, groceries, hair care, healthcare, households, leather goods, lighting, nutrition, personal care, skin care, snacks, stationery, timepieces & accessories, toys and weight management.
1.5    In this privacy statement, “Group” shall mean DKSH Hong Kong Limited, its holding companies, subsidiaries, affiliates; associated companies and any other company(ies) within the DKSH group of companies.
1.6    In this privacy statement, “Personal Data” shall mean any accessible or processable data relating directly or indirectly to a living individual and from which it is practicable for the individual to be directly or indirectly ascertained, including but not limited to name, gender, date of birth, contact particulars (including telephone numbers, fax numbers, addresses, email addresses), ID card and passport numbers, age, marital status, occupation, information related to work, income and financial background and other demographic data, products and services portfolio information, transaction pattern and behavior.

2. Collection of personal data for direct marketing

2.1    We confirm that only necessary, adequate but not excessive personal data will be collected from you for direct marketing purposes.
2.2    The purposes for which we may use your personal data are divided into obligatory purposes and voluntary purposes. If personal data is to be used for an obligatory purpose, these personal data will be marked as “Must be filled” and you must provide your personal data to us if you want us to provide the service for which you request.  If personal data is only to be used for a voluntary purpose, it is entirely up to you to decide whether you want to provide such information to us or not.
2.3    Purposes for which it is obligatory for you to provide your personal data are: (i) communicating to you in relation to your entitlements and privileges as our customer; (ii) redemption of privileges and receipt of news as our customer; (iii) for our own marketing, promotional and customer relationship management; (iv) handling and following up of services, enquiries and complaints; and (v) verification of your identity, data cleansing and customers profile updates.
2.4    Purposes for which it is only voluntary for you to provide your personal data are: (i) to enable us better to understand the demographics of our customers; (ii) for internal research and analysis to enable us to provide rewards, services and product information or offerings better tailored to your needs; and (iii) market research.
 

3. Use of personal data for direct marketing

3.1    We intend to use your personal data for direct marketing purposes.
3.2    We may not so use your personal data unless we have received your consent (which includes an indication of no objection), whether orally or in writing.
3.3    If you do not wish us to use your personal data in direct marketing, you may exercise your opt-out right by contacting us at any time and we confirm that we will not charge you any fee for this purpose.
 

4. Disclosure

4.1    We will take all practicable steps to keep your personal data confidential but we may transfer for gain or not for gain your personal data to brand owners or external service providers (including but not limited to printing houses, mailing houses, telecommunication companies, public relation companies, advertising agency, telemarketing companies, data processing companies, data storage companies, call centers, market research firms and information technology companies), for them to use for direct marketing purposes, whether undertaken on their own or jointly with us or others.
4.2    We may not so transfer your personal data unless we have received your written consent (which includes an indication of no objection).
4.3    If you do not wish us to transfer your personal data, you may exercise your opt-out right by contacting us at any time and we confirm that we will not charge you any fee for this purpose.
 

5. Security

Save and except as mentioned in paragraph 4 above or otherwise exempted under the law, your personal data, however stored, will be accessed only by our employees who are authorized to do so.  We shall implement appropriate measures to ensure the safety and security of your Personal and shall further exercise reasonable endeavors to ensure the integrity, prudence and competence of our authorized employees.

6. Your right to access and correction

You may at any time request access to and to correct personal data relating to you in any of our records.  You may also ask us to delete you or your personal data from any active mailing or distribution list.  To exercise any of your rights, you may contact us by any of the means stated in paragraph 7 below.

7. Personal data privacy contact method

You may at any time request access to and to correct personal data relating to you in any of our records.  You may also ask us to delete you or your personal data from any active mailing or distribution list.  To exercise any of your rights, you may contact us by any of the means stated in paragraph 7 below.
 

8. Retention of data

We will keep your personal data only for as long as necessary to fulfill the purpose for which the data was collected.  Personal data which is no longer required will be destroyed.