YOUR PERSONAL DATA AND HOW WE USE IT
Collection of your personal data
Different levels of your personal data may be collected by us, both on our Site and at our physical stores, boutiques and counter spaces.
- If you have not registered for our online newsletter, you will be browsing our Site as a guest. We will not collect or use any personal data from you.
- You will need to input certain of your personal data when registering for our online newsletter on our Site (such as your name and contact details), in order to receive various features and services that we offer to our subscribers, such as email updates, responses to your queries and invitations to participate in our private sales.
- You may from time to time provide us with your personal data at our physical stores, via your applications for or use of various services that we provide. For instance, you may be required to provide us with your personal data when you apply for or use our ICARD; to purchase from us or make enquiries at our stores or over the telephone; to provide feedback to us (such as via a survey); or to participate in our promotions and events (such as Private Sales).
Use of your personal data
We use the personal data you provide to us for the following purposes (and any purposes directly related to these purposes) (collectively, the Purposes):
- To provide our services to you (including assessing any application for and administration of such services). This includes responding to any questions you may have, providing you with recommendations on products in our stores, your applications with us for any of our services, providing our ICARD to you, allowing you to participate in our events and promotions when you so wish, and fulfilling any orders you may make with us (including verification and security checks of your details, and processing of your payments).
- Matching your personal data with information you provided to us via other means.
- To analyse trends, usage and shopping behaviour with us (whether on an individualized or aggregated basis), which helps us better understand how you and our collective customer base access and use our Site and services, for the purposes of improving our services and to respond to customer desires and preferences.
If you have provided us with your consent, we will also use your personal data for the following purpose:
- To provide you with direct marketing communications, in accordance with the Direct Marketing section below.
Other points of note regarding your personal data
Please also note that:
- Providing your personal data is optional. If you do not provide your personal data to us, we may not be able to provide some of our services and features to you.
- Subject to where otherwise required by law or permitted by law to protect our interests, we will (a) only retain your personal data for as long as it is necessary to fulfill the Purposes, and (b) erase any of your personal data that we have stored as soon as reasonably practicable, if you choose to delete your account with us.
Collection of anonymous data from you
Separately, we may collect certain anonymous data from you on our Site:
- We collect anonymous data relating to your online session to provide our services to you, 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. We may use analytics cookies for this purpose. You may opt-out of the collection of such data at any time.
- We may market to you our goods and services, and the goods and services of our: (a) our related companies (including our affiliate and subsidiary companies), (b) joint venture partners, and (c) other third party providers. Such marketing communications may be in various forms, including advertisements, special events notifications or newsletters, and delivered via various methods in accordance with the personal data that you provide to us, such as by postal mail, email or SMS and all other electronic means of communications.
- Such marketing communications may market or offer products or services (including special events and promotions) in the following categories: dining, food and beverages, sports, music, film, television and other entertainment, clothing and accessories, jewellery, luggage and bags, cosmetics, personal health and hygiene, electronics, home furnishings, and housewares, automobiles, transport and travel, hotels, financial services, loyalty and reward programs, media services, entertainment services, social networking services, payment services, on-line advertising services, other e-commerce, information and communications and services, concierge services, and other products and services that we think may be relevant to you based on information you provide to us (for instance, via your participation in our surveys).
- You may partially or entirely opt-out of receiving such direct marketing communications at any time by: (a) amending your preferences in accordance with "How to check and update your personal data" section below, (b) contacting our Privacy Officer at firstname.lastname@example.org, or (c) in the case of emails, by clicking the "unsubscribe" link at the bottom of such emails.
SECURITY AND PROTECTION OF YOUR INFORMATION
We protect the personal data that you provide to us by reasonable physical, electronic and managerial measures. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times.
To protect your personal data while you are on our Site, we will encrypt any personal data you transmit to us via our Site using Secure Socket Layer (SSL) — an industry standard for encryption over the Internet.
DISCLOSURE OF YOUR PERSONAL DATA
Your personal data held by us will be kept confidential, except we may disclose your personal data to the following parties (who may be located and use your personal data outside of your country of residence):
- Any financial institutions, charge or credit card issuing companies, credit information or reference bureau, or collection agencies where necessary to establish and support the payment of any products and services being requested by you; and
- Any other party where such disclosure is mandated by statutory or contractual obligations or as required by law or court of law, or where such disclosure is necessary to protect our interests (as permitted by law).
We do not provide your personal data to any other third parties unless your prior express consent is obtained. We may transfer anonymous and aggregated data to third parties from time to time, which may include your personal data in an anonymous format and which does not (and is not able to) identify you in any way.
HOW TO CHECK AND UPDATE YOUR PERSONAL DATA
You have the right to access, verify, update, or delete any of your personal data that we hold. You can do so:
- If you subscribe to our online newsletter, by clicking unsubscribe at any time to delete your personal data from our databases;
- Alternatively, where you have provided your personal data via means other than our Site you may by contacting our Privacy Officer (at the details as set out at Our Contact Details section below).
This policy outlines the policies and procedures regarding the use of CCTV in Imaginex stores undertaken to comply with the requirements of the Personal Data (Privacy) Ordinance (the Ordinance). CCTV is used to procure reasonable security and safety of the monitored area.
1. Policy Statement
In accordance with the Ordinance and relevant guidelines issued by the Office of the Privacy Commissioner for Personal Data (PCPD):
- Data subjects are explicitly informed they are subject to CCTV surveillance by notices reading CCTV in operation in areas of surveillance.
We place conspicuous notices at the entrance to any monitored area and fix further notices inside the area.
- Notices are also posted if the CCTV cameras themselves are very discreetly located, or in places where a data subject may not expect to be subject to surveillance.
- CCTV cameras are not installed in places where people have a reason to expect privacy.
Closed-Circuit Television (CCTV) at our stores
We employ Closed-Circuit Television (CCTV) in our stores. Store premises are subject to CCTV surveillance and activities are recorded by video camera to procure reasonable security and safety of the monitored area.
Information obtained through CCTV monitoring will be used exclusively for safety, security, and law enforcement purposes. Recorded images will be stored in a secure location with access by authorized staff only and will be securely deleted as soon as practicable once the purpose of collection is fulfilled.
If you wish to contact us in relation to privacy of your personal data, please contact our Privacy Officer at email@example.com or mail to: Privacy Officer, Imaginex Group, 23rd – 25th Floors, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.”
2. General Procedures
I. Proper Handling of the Recorded Images
- The personal data collected is securely deleted from the CCTV as soon as practicable once the purpose of collection is fulfilled. If no incident is reported, the footage will be securely deleted regularly accordingly.
- Upon expiry of the applicable retention period, we permanently destroy all personal data: (i) if in hard copy form, by first shredding and then securely disposing of the personal data; and (ii) if in electronic form, by permanently erasing the personal data from our systems. The CCTV footage/images are removed automatically from the system regularly. All authorized users having access to any copy of the CCTV footage/images delete such copy once the incident being reported is closed or is no longer active.
- If an incident occurs in the store, CCTV footage is preserved in a secure way until such time as the incident is fully investigated and the matter is closed. Usual deletion policies in relation to CCTV footage are suspended for the relevant footage during that period.
- Security measures are in place to prevent unauthorized access to the CCTV system. Recorded images are kept in safe custody, subject to and in accordance with the following measures:
- A login account and password for access to and storage of footages is available only to authorized users
- Access to locations where the images recorded by the CCTV cameras are viewed, stored or handled are secured and restricted to authorized users only. The authorized users can only view the CCTV footage only when the incident is reported. Please refer to Appendix 1 for detail.
- CCTV footage is not transferred in digital format through email, mobile or any other device other than to the Legal Department or to authorized users provided that the footage is encrypted and then only as strictly necessary for valid reason and subject to and in accordance with this clause and clause II below.
- Proper records of the staff members taking charge of and keeping the recorded images are maintained by authorized users.
- Transfer and movements of the recorded images are clearly documented and only made in accordance with clause 2I(d) (3).
- The hard disks or any devices storing the recorded images are securely protected from unauthorized access (e.g. an encryption function is used) and only viewed, retrieved or handled upon proper authorization for the intended purpose (e.g. police investigation). Once there is no valid reason to retain the recorded images, they are securely deleted. Safeguards are in place to protect wireless transmission systems from interception should they be used for transmission of data recorded by CCTV.
II. Transfer of CCTV Records to Third Parties
- Personal data is only used for the purposes for which it was collected or a directly related purpose, unless the data subject has given express voluntary consent or when any applicable exemptions under the Ordinance apply.
- Disclosure of CCTV records to any third party (e.g. a customer) subject to provisions of the Ordinance is generally prohibited to protect the privacy of personal data.
- If we are requested to provide CCTV records to a law enforcement agency e.g. the Police for criminal investigation purposes, we will cooperate only with a written request provided by the relevant law enforcement agency.
- Please refer to clause 3 for detail of handling.
III. Misuse or abuse of CCTV system or the recorded images is reported to Natalie Da Gama-Rose, General Counsel of the Group Legal Department (email: firstname.lastname@example.org; Tel: 2118 2280).
IV. Compliance checks and audits are carried out annually to review the effectiveness of the safeguards and procedures of the CCTV system.
3. Customers Enquiries/Law Enforcement Agencies (e.g Police)
I. If a customer has queries in relation to the operation of the CCTV and the purpose of or in relation to privacy issues of his/her personal data, he/she may contact our Privacy Officer at email@example.com or mail to: Privacy Officer, Imaginex Group, 23rd – 25th Floors, One Island South, 2 Heung Yip RoadWong Chuk Hang, Hong Kong.”
II. We do not accept requests from customers to view of CCTV footage because CCTV footage contains personal data and we are not allowed to share it with third parties by law.
III. We will accept requests from the police or other enforcement agent to view the CCTV footage and/or have a copy of the same upon receipt of formal written application.
We place conspicuous notices in our stores to inform customers we prohibit any photography, sound and/or video recording in our stores.
If our staff reasonably suspect that a customer is taking photography, sound and/or video recording in our stores, we will ask the customer to refrain from doing so. If a customer continues taking photographs, and recording sound and/or video footage, following our reasonable request, we reserve the right to require that customer to leave our premises.
If a customer has queries in relation to the photography policy, he/she may contact the Store Manager.
OUR CONTACT DETAILS
Address: 23rd – 25th Floors, One Island South, 2 Heung Yip Road, Wong Chuk Hang, Hong Kong