Respecting and protecting our customers’ privacy and personal data is important to LCJG Limited and its related companies (including all holding, subsidiary and affiliate companies) (collectively, we or us). This policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the section What rights do I have?
We collect and process personal data about you when you:
2.1 visit and/or register on any websites owned and operated by us (including www.imaginex.com) (collectively, our Site);
2.2 place an order with us as a guest or as a registered user on our Site;
2.3 use a third-party service offered by service providers such as analytics companies, advertising networks and cooperatives, demographic companies, and any other third party service providers that we choose to collaborate or work with, and we obtain your personal data from those third parties;
2.4 provide us with your personal data via: our physical stores, Wi-Fi, mobile devices, social media platforms/networks or telephone enquiries, your application for or use of our services or loyalty programmes (such as our Privilege Cards or Private Sales);
2.5 visit our physical stores or any other of our locations and your image is captured by our security CCTV (please refer to our Security CCTV Policy in Section 12 below); and
2.6 visit our physical stores or any other of our locations, and our data analytics cameras carry out real-time data analyses based on your image for statistical research purposes on an anonymous and aggregated basis as set out in our Data Analytics Policy (see Section 13 below). The only personal data that will be collected and processed and used to analyse pathways throughout the store will be your facial biometric template derived from your facial image (i.e. numeric information describing different facial features).
We process personal data for the following purposes:
3.1 to conduct our business and pursue legitimate interests, in particular:
3.2 when you give us consent (if required):
3.3 for purposes which are required by law:
We have carried out an assessment on all the data processing activities described above in order to weigh up any privacy implications against our legitimate business interests. You can obtain information on any of our assessments by contacting us using the details set out later in this policy.
Wherever we require your consent under applicable law, you will always be able to withdraw any consent provided to us. We shall cease to use your personal data for the purpose in respect of which you have withdrawn your consent, but we may still use, process, store and transfer your data for other purposes, such as those set out above. Specifically, in the case of customers from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) amending your preferences in the logged-in area of this Site, (b) contacting our Privacy Officer at firstname.lastname@example.org or sending your request by post to; Privacy Officer, ImagineX, 23F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong, (c) in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.
We will share your personal data with the related companies of LCJG Limited for the purposes set out in Clauses 3.1 and 3.2 above.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes set out in Clause 3.3 above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified in Clause 3 above. In particular, we use the following third party providers:
Your data, in an anonymous form such that your identity cannot be ascertained, may also be sold to third parties for their own purposes.
In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
If you are located in the EEA, where information is transferred outside the EEA, and where this is to a business partner or third party service provider in a country that is not subject to an adequacy decision by the EU Commission, data will be adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or third party or business partner’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to the contact mentioned in the section "How do I get in touch with you" below. Your personal data may be transferred to Hong Kong and Macao Special Administrative Regions, Mainland China, Taiwan Region, Indonesia, Singapore, Australia, United States, and Japan.
Where permitted by law, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, if you are located in the EEA you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests assessment, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are located in the EEA: If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.)
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at email@example.com or by writing to Privacy Officer, ImagineX, 23/F, One Island South, 2 Heung Yip Road, Wong Chuk Hang, Hong Kong. You may also access, verify or update your personal data by logging into the Site or completing the “Customer Information Renewal Form” at one of our stores.
The data controllers are LCJG Limited, and its related companies; contact details can be found in the section How do I get in touch with you above.
Where we process registration data, we do this for as long as you are an active user of our Site and it is required for business and legitimate interests or legal requirement.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.
(Applicable if you are located in the EEA only) Where we process personal data for site security purposes, we retain it for 7 years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for 7 years from your last interaction with us.
We will not keep the images captured by our analytics cameras for more than 1 day, and such images will be anonymized and aggregated before any use of the same for the purposes stated in Clause 3.1 above.
We place conspicuous notices in our stores to inform customers we prohibit unauthorised photography, sound and/or video recording for commercial use, private gain, use in press or media, or for promotional purposes in our stores. We reserve the right to remove offenders from our premises.
We permit photography, sound and/or video recording where the images/recordings are solely for personal use and are not published or reproduced in print or electronically for commercial use, private gain, use in press or media, or for promotional purposes.
Permitted photography, sound and/or video recording are subject to the following conditions:
(1) no photographs or video and/or sound footage is taken of staff members or other customers without express permission of the staff member or customer;
(2) flash and tripods are not used without written permission;
(3) customers refrain from taking photographs, and recording sound and/or video footage and/or leave the premises if;
If a customer has queries in relation to the photography policy, he/she may contact the Store Manager.
This policy outlines the policies and procedures regarding the use of CCTV in our 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.
In accordance with the Ordinance and relevant guidelines issued by the Office of the Privacy Commissioner for Personal Data (PCPD):
(a) 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.
(b) 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 pf the CCTV footage/images shall delete such copy once any reported incident is closed or is no longer active.
(c) 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.
(d) 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:
(e) Proper records of the staff members taking charge of and keeping the recorded images are maintained by authorized users.
(f) Transfer and movements of the recorded images are clearly documented and only made in accordance with clause I(d)(3).
(g) 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.
(a) Personal data is only used for the purposes for which it was collected or a directly related purpose (see Clause 3 above), unless the data subject has given their express voluntary consent for any other purpose or when any applicable exemptions under the Ordinance apply.
(b) Disclosure of CCTV records to any third party shall only be in accordance with Clause 6 or in accordance with the Ordinance.
(c) 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 and if we reasonably believe that an exemption under the Ordinance applies.
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;Telephone:+852 2118 2280).
IV. Compliance checks and audits are carried out annually to review the effectiveness of the safeguards and procedures of the CCTV system.
I. If a customer has queries in relation to the operation of the CCTV and the purpose or in relation to privacy issues of his/her personal data, he/she may contact our Privacy Officer at email@example.com or by post to: Privacy Officer, ImagineX, 23F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.
II. We do not accept requests from customers to view of CCTV footage because CCTV footage may contain personal data of other third parties and we may not be 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 a formal written request, and subject to the application of an exemption under the Ordinance.
This section outlines the policies and procedures regarding the use of data analytics cameras in our stores. Data analytics cameras are used in our stores to generate anonymous and aggregated data for statistical research purposes, such as demographics analysis and traffic flow analysis within our stores. The anonymised and aggregated data will be used by us to help improve our services.
The only personal data we may collect is facial biometric templates derived from a facial image captured by the analytics camera (i.e. numeric information describing different facial features), which will be collected and used and processed by the analytics camera for the purposes stated above (namely, to analyse traffic flow within our stores for statistical research purposes). No video footage, images or other personally identifiable data shall be stored. All analysis conducted by the data analytics cameras based on the footage will be done in real time. Security measures are in place to prevent unauthorized access to the data analytics system.
The facial biometric templates collected using the analytics camera will be securely deleted within 24 hours of being collected, and only the aggregated and anonymised data will be retained.
Data subjects are explicitly informed that the data analytics cameras are in operation in applicable areas by notices reading “analytics cameras in operation”. We place conspicuous notices at the entrance to any monitored area and fix further notices inside the area. Notices are also posted to alert customers if the analytics cameras themselves are very discreetly located. No analytics cameras are installed in places where people have a reason to expect privacy.
The facial biometric templates collected using the analytics camera will only be disclosed to our third party service providers who operate the analytics cameras for the purposes stated above (namely, to analyse traffic flow within our stores in order to generate anonymous and aggregated data for statistical research purposes). All use or transfer of data derived from the analytics cameras will be on an anonymised and aggregated basis, such that you cannot be identified or re-identified.
If a customer has queries in relation to the operation of the data analytics cameras or in relation to privacy issues of his/her personal data, he/she may contact our Privacy Officer at firstname.lastname@example.org or by post to: Privacy Officer, ImagineX, 23F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.