Privacy Policy
Personal Data (Privacy) Policy and Statement
1 Introduction
- This Privacy Policy describes the privacy policies and practices of Hong Kong Trading Company Limited, a limited liability company duly incorporated in Hong Kong Special Administrative Region ("Hong Kong"), with its address at Unit GH, 20th Floor, King Plaza, 55 King Yip Street, Kwun Tong, Kowloon, Hong Kong, and other companies directly or indirectly held by Hong Kong Trading Enterprises Limited (collectively, "Hong Kong Trading", "we", "our") regarding the collection, use, retention, disclosure, transfer, security and access to personal data. Certain information about you is collected when you browse or visit our website (www.harbourmark.com) (“Website”) and/or our mobile App (“App”), purchase products through our Website and/or App or in-store, or register as a member of our loyalty program (collectively, the “Services”). We have tried our best to present this Privacy Policy in a way that is easy to understand and read. Please review this Privacy Policy carefully before using our services.
- If you are under the age of 18 or 21 (depending on your jurisdiction), you must review this Privacy Policy with your parent or legal guardian to ensure they have read and agreed to this Privacy Policy on your behalf. By using our services, you represent that you are over the age of 18 or 21 (depending on your jurisdiction), or that your parent or legal guardian has read and agreed to this Privacy Policy on your behalf. You understand and agree that we are based on this representation when providing our services to you.
- Protecting your personal data and using your personal data appropriately and legally to serve you better has always been our top priority. We respect your rights with respect to your personal data and only collect from you personal data that is sufficient but not excessive for legitimate purposes directly related to our functions, activities or services.
- We will do our best to protect your personal data and keep your personal data accurate and up to date. If we have reasonable grounds to believe that your personal information is inaccurate, we will stop using such information or delete such information.
- We are committed to handling your personal data in a responsible, open and transparent manner. We will honor and update your request to access, correct or stop using your personal data in a professional manner and in a timely manner in accordance with applicable laws.
- We may, from time to time, update our Privacy Policy at our sole discretion and without notice, if necessary. Any changes or modifications to the Privacy Policy will be effective when posted on our website and/or App. Therefore, please review this Privacy Policy (www.harbourmark.com/privacy-policy) regularly. Your continued use of this website and/or App and/or our services and/or providing us with your personal data constitutes your acceptance of our then-current Privacy Policy.
2. Personal data we collect
a) In order for us to provide services to you, you must provide us with your personal data. Some of the information is necessary, for example, we will ask for basic personal information so that we can accept you as our member. If you are unable or unwilling to provide us with the complete and correct personal data or other information requested, we may not be able to accept you as our member or provide or continue to provide our services to you. The information we request includes:
(i) your name, delivery or delivery address, email address, user name, password, date of birth, contact number and other registration information;
(ii) information about your preferences and interests;
(iii) transaction-related information, such as your past order records, credit card information, delivery address, etc.;
(iv) information that you voluntarily provide to us, for example when you contact us with inquiries or feedback; and
(v) other information about your use of the services we provide.
b) We, our agents, suppliers, consultants and other service providers ("Service Providers") may automatically receive or collect certain information about you when you access our Services using internal analytics technology or other automated tracking and analysis technology (see below). This information includes but is not limited to the following information:
(i) Your connection to our website and/or App, including the equipment you use, browser information, operating system, name of Internet service provider, wireless operator, Internet address (IP), geographic location, etc.;
(ii) Your interaction with our website and/or App, including your browsing time, number of clicks, clicks on links in our website and/or App, pages viewed, methods of your access to our website and/or App, etc.;
(iii) information collected by us or data (cookies) stored on the user's local terminal by a third party (see below);
(iv) your personal data.
c) Any questions, feedback, suggestions or data (except personal data) sent or posted on this website and/or App or any part of this website and/or App by you are deemed to be non-confidential and non-proprietary information voluntarily provided to Hongkong Trade. You hereby grant Hong Kong Trade the right to use, reproduce, edit, disclose, transmit, publish, broadcast and/or send the information (part or all) in other places completely and free of charge, including but not limited to providing the information to any affiliated company to develop, produce and promote products and services and meet customer needs.
3. Use of personal data
a) All personal data you provide to us may be used for all or any of the following purposes:
(i) processing your application for membership;
(ii) to provide you with services under the membership scheme;
(iii) promotion of goods and/or gifts and/or services by us and/or any member of HKEX;
(iv) to provide you with selected rewards, promotions and privileges from us and/or any member of HKEX;
(v) communicate with you on all matters relating to membership;
(vi) management, operation and maintenance of membership schemes;
(vii) designing new merchandise and/or gifts and/or services for us and/or any member of Hong Kong Trade, or improving existing merchandise and/or gifts and/or services;
(viii) process your order through our website and/or App or in-store;
(ix) provide you with necessary information about our products and/or services;
(x) arrange for the delivery, collection or collection of products ordered or purchased by you;
(xi) make suggestions for other products that we think will be of interest to you;
(xii) to respond to and evaluate your inquiries, comments and feedback;
(xiii) understand how our website and/or apps and services are used;
(xiv) provide targeted advertisements on the Website and/or App that are relevant to your interests;
(xv) for direct marketing with your consent;
(xvi) investigate complaints or suspicious transactions;
(xvii) preventing or detecting criminal activity;
(xviii) any disclosure required under applicable laws and/or rules;
(xix) for statistical analysis and/or research to improve our services and for internal staff training and assessment purposes; and
(xx) Other related or incidental uses to all or any of the above purposes.
b) For the purposes in subparagraph (a) and subject to paragraph 4, we may share your data with:
(i) service providers (whether based in Hong Kong or overseas) who provide relevant services on our behalf;
(ii) other companies under HKEX;
(iii) our assignors or assigns in the event of a change of ownership; and
(iv) other law enforcement agencies or government agencies so that they comply with applicable laws or valid court orders.
Service providers may include, but are not limited to, third-party rewards program, loyalty or benefit program providers, co-branded or cross-marketing retail partners or charitable or non-profit organizations, external service providers (including but not limited to our agents, contractors, sub-contractors, telecommunications carriers, mailing providers, direct marketing agents, telemarketing providers, call centers, data processing providers and information technology providers), and any third parties who owe us a duty of confidentiality. Service providers are contractually obligated to collect, use, store, and process your personal data only in accordance with our instructions and only for our purposes and not for other purposes.
4. Use of personal data for direct marketing
a) We intend to use your data for direct marketing purposes. We will not use your personal data unless we have your consent.
b) Subject to your consent to use your personal data for direct marketing purposes, we intend to use the following personal data to promote products and/or promote services and/or for the purposes described in subparagraph (d) below:
(i) your name;
(ii) your address;
(iii) your telephone number;
(iv) your email address;
(v) your consumption patterns for goods and services; and
(vi) Other information provided by you in the membership application form (if applicable).
c) Your personal data may be used to promote goods and/or promote services and/or for the following purposes;
(i) electrical and electronic products and related goods, accessories and services;
(ii) telecommunications products and related goods, accessories and services;
(iii) computers and related goods, accessories and services;
(iv) cameras and related goods, accessories and services;
(v) watches and related goods, accessories and services;
(vi) other merchandise sold by stores operated by Hong Kong Trade;
(vii) rewards, loyalty or privileges programs and related goods and services; or
(viii) Donations or grants for charitable and/or non-profit making purposes.
d) In addition to promoting goods, promoting services and the above purposes, we also intend to provide your personal data mentioned in the above subparagraph (b) to any member of Hongkong Trade for their use in promoting goods, promoting services and the above purposes. Unless we have your consent, we will not provide your personal data to any member of Hongkong Trade.
e) If you do not want us to use or provide to others to use all or part of your personal data for direct marketing of all or part of the above-mentioned goods, services and purposes, you can write to the address stated at the end of this privacy policy or call our customer service hotline to exercise your withdrawal right to refuse direct marketing. Please note that you may give optional consent to (i) the types of personal data that we may use; (ii) the types of promotional objectives; and (iii) the types of data transferees (but you acknowledge and understand that if such data transfer is necessary for us to provide services, we may not provide our services to you).
5. Links to third parties
This website and/or App may include or contain links to other websites and webpages. Each time you activate any such linked webpage, for example by clicking on any advertiser link on our website and/or app, you will leave our website and/or app. Any personal data or any other information that you provide to any other organization after leaving this website and/or App is not within the control of HKEX. Hong Kong Trade's Privacy Policy does not apply to other organizations or websites.
6. Your rights
a) You have the right to:
(i) check whether we hold any personal data about you;
(ii) access your personal data held by us;
(iii) request us to correct any inaccurate personal data about you or delete your personal data;
(iv) identify our policies and practices (from time to time) in relation to personal data and the categories of personal data we hold;
(v) object to us or others using your personal data for direct marketing, please read paragraph 4 above for details.
7. Security of Personal Data
a) Hong Kong Trade will use all reasonable efforts to ensure that all personal data held by us is stored in a secure and protected environment and prevented from unauthorized or accidental access, processing, deletion or other use.
b) We will keep your personal data for no longer than is necessary to fulfill the purpose for which it was originally collected.
8. "Cookies" and third-party tracking
a) The data (cookies) (“cookies”) files stored on the user’s local terminal are text files stored on computers or mobile devices. "Cookies" allow us to facilitate and improve your use of our website and/or App and services by saving your preferences, making your web browsing process easier. For example, "cookies" will record the items in the shopping cart so that the items in the shopping cart will not be removed when you browse our website and/or App. Among them, Hong Kong Trade may use "cookies" on the website and/or App to:
(i) enhanced security measures;
(ii) allow website and/or App visitors to continue browsing the website and/or App;
(iii) Personalize the use of the Website and/or the App according to the needs of individual customers, such as storing user preferences, storing and retrieving login information on your computer, and personalizing content and offers based on your interests;
(iv) Build data about website and/or App visitor profiles.
b) If you do not allow the use of "cookies", please make appropriate adjustments in the browser on your computer to disable "cookies". You may also refer to https://www.allaboutcookies.org/manage-cookies/index.html. However, when you disable "cookies", you may not be able to use certain functions of the website and/or App or our services, and may not receive advertisements or other offers from us that are relevant to your interests and needs.
c) Third-party service providers may use their tracking technology to obtain your information.
(i) Google Tag Manager (“GTM”) – a tag management system used to manage JavaScript and HTML tags used by our website and/or App for tracking and analysis. Tags are small code components that perform actions such as measuring traffic and visitor behavior, understanding the results of online advertising and social channels, and remarketing to targeted users. More information on GTM's privacy practices can be found at http://www.google.com/intl/de/policies/privacy/.
(ii) Google Marketing Platform (Google Marketing Platform) – enables us to place advertisements on our website and/or App, and it uses "cookies" to show where you browse within the website and/or App to facilitate behavioral targeting. You may visit the above link for more information.
(iii) Addthis – a bookmarking service provider. Addthis collects data when you share pages on our website. You may permanently prevent Addthis from installing cookies on your browser by downloading and installing an "opt-out cookie" at the following link: http://www.addthis.com/privacy/opt-out. Please note, however, that if you install an "opt-out cookie", you may not be able to use all the features on our website. You can view Addthis's Privacy Policy at http://www.addthis.com/privacy/privacy-policy.
(iv) Facebook pixels – collect data about what you do after seeing or clicking on a Facebook ad. Facebook may also associate this data with your Facebook account and use it for advertising purposes. You can view Facebook's privacy policy at https://www.facebook.com/about/privacy/.
(v) Hotjar – Hotjar is a technology service to help us better understand user experience (for example, how much time they spend on which pages, which links they choose to click, what users like and dislike, etc.), which allows us to build and maintain our services based on user feedback. Hotjar uses "cookies" and other technologies to collect data about our users' behavior and their devices. This includes your device's IP address (which is extracted at the time of your use and stored de-identified), device screen size, device type (unique device identifier), browser information, geographic location and the preferred language in which our website is displayed. Hotjar stores this information for us in an anonymous user profile.
(vi) Queue-it - a waiting room system used to control network traffic, which uses "cookies" to provide queue services. You can view Queue-it's Privacy Policy at https://queue-it.com/privacy-policy-customer/.
(vii) Emarsys – We also use the services of Emarsys to track and collect certain information on this website and/or App to help us better understand the needs of our visitors for our website and/or App and/or services. You can read Emarsys' privacy policy at https://www.emarsys.com/en-hk/privacy-policy.
(viii) New Relic – We use performance tracking "cookies" to improve the performance of our website by collecting data on the number of users who visit our website. For information on how New Relic collects and processes your data, please see: https://newrelic.com/termsandconditions/applicant-privacy-policy.
d) Gangmao sets up its official pages on various social media platforms, and these pages can be accessed by clicking links on our website and/or App. The providers of social media platforms may track your browser or device and we are not responsible for the privacy, information or other practices of any third parties, including any third party operators or providers of links to social media platforms. Inclusion of such links on the Site and/or App does not imply endorsement by us or the Linked Site or Service.