Privacy Statement
This Privacy Policy Statement provides information on the policy of DKSH under the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong (the “Ordinance”). DKSH respects your privacy and is committed to comply with applicable data protection laws and to safeguard your personal data. This Privacy Statement describes the way in which we use and share personal data about you, how we safeguard your personal data and interact with third parties that may have access to your personal data and finally, how you can contact us in case of questions or requests.
Personal data we collect about you
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.
As part of your interactions with us, we may collect personal data about you as far as it is necessary to conduct our legitimate business interests, to comply with a legal obligation or as agreed by you. The types of personal data we collect depend on the interactions you have with us and the goods and services you use.
How we use your personal data
We will only collect and use personal data about you as described in this Privacy Statement and as necessary for the following Purposes:
- to provide you with our goods and services;
- to process your order, request or application;
- to comply with relevant laws in connection with the provision of goods and services;
- to manage our business relationship with you;
- to provide you access to specific information in relation to our provision of goods and services;
- to provide you with our media and investor relations information;
- to invite you to register for an event or to participate in a survey;
- to provide employment benefits and other employment related purposes and activities;
- to fulfill other relevant terms of our contract with you;
- to maintain security;
- to protect your, our, or others’ rights, property or safety;
- to prevent offenses, crimes, fraud or other illegal activities;
- to establish or preserve a legal claim or defense or to support any legal or criminal investigation or if such disclosure is otherwise necessary in support of any legal or criminal investigation or legal proceeding;
- to comply with applicable laws, court or other governmental regulations;
- for Direct Marketing purposes, with your consent;
- For other legal purposes that is disclosed to you at the time of collection of your personal data; and
- otherwise to the extent as permitted or required by applicable laws.
Subject to your specific permission that we may collect separately and to your full control to opt out at any time, we may also use your personal data to send you promotional material or newsletters that we think may be of interest to you.
Who we share your personal data with
We may share, or otherwise disclose your personal data to our affiliated companies or other trusted business partners providing services on our behalf such as for technical support or logistical, administrative or transportation support to DKSH, in and outside of Hong Kong, to fulfill the Purposes indicated above. We have contracts in place with these parties to ensure that personal data is processed based on our instructions and in compliance with this Privacy Statement and any other appropriate confidentiality and security measures.
We may also share, or otherwise disclose your personal data to our principals, clients or suppliers, in and outside of Hong Kong, who have authorized us to provide you with their goods and/or services, so that we may fulfill the Purposes indicated above.
We may also share, or otherwise disclose, your personal data to financial and legal advisers of DKSH in and outside of Hong Kong, and to government entities if so required to fulfill the Purposes.
We only share your personal data with the parties mentioned above as far as this is necessary to fulfill the Purposes, or authorized by accepting the terms of this Privacy Statement, or with your consent.
Please note that DKSH affiliated companies, as well as authorities, clients, principals, suppliers and trusted business parties to whom we may disclose your personal data, may be located outside your territory of domicile, including territories in Asia and potentially the United States of America, whose data protection laws may differ from those in the territory in which you are located. In such cases, we will ensure that appropriate safeguards are in place to protect your personal data by implementing appropriate legal mechanisms, such as EU Standard Contractual Clauses. For more information about the safeguards we take, please send us an email via a form here:
Online Communications
We require your personal data in order to fulfill the Purposes above. If you do not to provide us with your personal data, DKSH will not able to provide you with goods and services, access to information, access to locations and other related matters. Moreover, if the personal data provided is incorrect, insufficient or inaccurate, DKSH reserves the right to suspend or refuse the provision of goods, services, access to information, access to locations or other related matters.
How we secure your personal data
DKSH has implemented technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access to personal data we store. This includes training of our personnel who may have access to your personal data.
How long we store your personal data
We will store your personal data as long as required to fulfill the Purposes outlined in this Privacy Statement, unless a longer or shorter retention period is required or permitted by law.
Your rights in respect to your personal data
You have the right to request to be notified about what personal data we hold from you and to request the correction or deletion of your personal data that is held by us or by a third party with whom we conduct business. In addition, where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Please be aware that the withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal. Under certain circumstances, you have further the right to object to or to request the restriction of the processing of your personal data and, you may lodge a complaint to the applicable data protection authority if you consider that the processing of your personal data infringes applicable laws.
If you would like to make such request, please contact us as described in the section below After providing proof of identity, we will respond within a reasonable time.
Attention:
Data Privacy Coordinator
DKSH Hong Kong Ltd.
23/F Tower A, Southmark
11 Yip Hing Street, Wong Chuk Hang
Hong Kong
E-mail: hongkong_privacy[at]dksh.com
Use of personal data in direct marketing
In respect of direct marketing activities and as a user of personal data,
1. “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.
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 may not so use your personal data for Direct Marketing 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 and transfer for Direct Marketing
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 for Direct Marketing 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 for 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.
If there is any inconsistency or difference between English and Chinese versions of this Privacy Statement, the English version shall prevail.
