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PRIVACY POLICY



1. General

Respecting and protecting our customers’ privacy and personal data is important to ImagineX Group, 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?

In the event of any discrepancy between the English language version of this Privacy Policy and a translation of the Privacy Policy, the English language version will prevail.


2. What information do we collect?

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) (our Site);

2.2 place an order with us as a guest or as a registered user on our Site.

2.3 provide us with your personal data via: our physical stores or telephone enquiries number, your application for or use of our services (such as our ICARD);


3. How do we use this information,and what is the legal basis for this use?

We process personal data for the following purposes:

3.1 to conduct our business and pursue legitimate interests, in particular:

  • 3.1.1 To provide our services to you, including: responding to any questions you may have, providing you with recommendations on products in our stores or on our Site; maintaining your shopping cart on our Site; assessing your applications with us for any of our services; providing our ICARD to you; fulfilling any orders you may make with us (including verification and security checks of your details, processing of your payments, shipping products that you have ordered to you, and processing return or exchanges of products you have purchased) and providing the ImagineX Mobile App services to you; and

  • 3.1.2 We monitor use of our Site and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;


3.2 when you give us consent (if required):

  • 3.2.1 To provide you with direct marketing communications in relation to our relevant products and services, or other products and services provided by us, our related companies and brand partners:

    We may market to you our goods and services, and the goods and services of: (a) our related companies (including our affiliate and subsidiary companies), (b) business 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 email, SMS, WeChat messages, smartphone app push notifications, notifications on your social media pages, in –app messaging or postal mail.

    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).

  • 3.2.2 To allow you to register for and participate in our events and promotions, including verifying your identity at those events and promotions; and

  • 3.2.3 To analyse trends, usage and browsing 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. For these purposes, we will use personal data about your gender, age, interests, geographical location, Site usage (including browsing behaviour / activities), shopping behaviour and other personal data.


3.3 for purposes which are required by law:

  • 3.3.1 In response to requests by government or law enforcement authorities conducting an investigation.


4. Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our business and legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Policy.


5. Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing 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 direct marketing subscription preferences in the “Update Profile” section of the Site, (b) contacting our Privacy Officer at privacyofficer@imaginex.com or mailing to; Privacy Officer, ImagineX, 23F One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong, or (c) in the case of emails, by clicking the unsubscribe link at the bottom of such emails.


6. Who will we share this data with, where and when?

We will share your personal data with the related companies of ImagineX Group and LCJG Limited.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes 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 above. In particular, we use third party providers of courier services, e-mail/SMS/MMS/WeChat blasting services, data storage and cloud service providers (for storage of your personal data and hosting of applications that process your personal data for the purposes identified in this Policy), Google and Facebook (for matching of your personal data with their database in order to send you our direct marketing materials through your Google and/or Facebook account(s)), digital marketing and website analytic agencies (for display of advertising materials on our Site and other websites that you may visit, and analysis of your online behaviour and usage of our Site – these agencies use cookies; please refer to our separate Cookies Policy for details).

In the event that our business 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 from the EEA, where information is transferred outside the EEA, and where this is to a stakeholder or vendor 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 a vendor'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 and Singapore.


7. What rights do I have?

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 from 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 balancing test, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are from 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.)


8. How do I get in touch with you?

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 privacyofficer@imaginex.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 using the “Update Profile” section of the Site, the ImagineX Mobile App or completing the “Customer Information Form” at one of our stores.


9. Who is the data controller?

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.


10. How long will my data be kept?

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 [(applicable if you are from the EEA only for 7 years after any business and legitimate interests or legal requirements no longer exist)].

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 requests). 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 future.(Applicable if you are from 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.


11. Photography Policy

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.


12. Closed-Circuit Television (CCTV) Policy


Policy Statement

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):

  • - 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 fixes 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.

Our Privacy Policy reflects the usage of CCTV in our stores and reads:

  • 1. 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.

  • 2. 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.

  • 3. If you wish to contact us in relation to privacy of your personal data, please contact our Privacy Officer at privacyofficer@imaginex.com or mail to: Privacy Officer, ImagineX, 23F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.


General Procedures


I. Proper Handling of the Recorded Images

(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 accordingly.

(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 delete such copy once the incident being reported is closed or is no long 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:

  • (1) A login account and password for access to and storage of footages is available only to authorized users.

  • (2) 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.

  • (3) 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.

(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.


II. Transfer of CCTV Records to Third Parties

(a) 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.

(b) 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.

(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.

(d) 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: natalie.dagamarose@lcjgroup.com;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.


Customers Enquiries/Law Enforcement Agencies (Eg Police)

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 privacyofficer@imaginex.com or mail 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 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.