Personal Information Collection Statement ("PICS")

1. Your Privacy
HCML Limited ("we", "our" or "us") respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this PICS explains our privacy practices.

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This policy may from time to time be revised.

If there is any inconsistency between the English and Chinese version of this Privacy Policy Statement, the English version shall prevail.

"Personal data" means any personally identifying information or sensitive data (such as names, occupations, addresses, contact details, ID Card or Passport numbers, credit card information, your age, your marital status, your employer, your income, demographic data) from which it is practicable for the identity of an individual to be ascertained.

 

2. Purposes for which we will use your Personal Data

Your personal data may be collected when you make a purchase or apply to be our member.

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 not be marked as “optional” in the Members Application Form and you MUST provide your personal data to us if you want us to provide the service for which you are applying. 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.

Purposes for which it is obligatory for you to provide your personal data are:

(a)    management of your order and management of your account and profile;
(b)    enrolment into and maintaining your membership as our member;
(c)    accumulating bonus points as our member;
(d)    communicating to you your entitlements and privileges as our member;
(e)    redemption of privileges as a member;
(f)    notification of any amendment to the membership program;
(g)    relationship building; and
(h)    data cleansing and customers profile updates.

Purposes for which it is only voluntary for you to provide your personal data are:
(a)    to enable us better to understand the demographics of our customers;
(b)    for internal research and analysis to enable us to provide rewards, services and product information or offerings better tailored to your needs;
(c)    market research;
(d)    to enable our customer service to follow up;
(e)    to distribute customer satisfaction survey; 
(f)    to send out VIP newsletters and VIP program updates; and
(g)    the provision of your personal data to third party platforms so that they may provide you with personalized ads when you use their services and identify other people with a similar profile to you so that they may send similar ads to those people.
(h)    We also intend to use your personal data for direct marketing, including:

communicating to you regarding new product launch and other promotional offers, including where applicable, skincare products, cosmetics products, make up products, body care products, hair care products, and make up services, facial services;

- communicating to you regarding our promotional events, including where applicable, makeup classes and/or demonstrations, skincare seminars, other beauty classes, PR events, VIP gatherings value sets, shop opening events, store announcement/events, exhibitions, fashion shows and news update;
- communicating on-counter or out of counter services and events related to skincare, makeup, body care, hair care, for promotion or reward purpose;
- marketing reward programs, birthday celebration offers, free sampling, digital campaigns, roadshow/outpost, promotion updates;
- communicating joint promotion or events with shopping malls, department stores, credit cards, banks, trades, celebrities, magazines, television, websites, mileage programs, cultural, art or musical societies/organizations, charities or non profit organizations; 
- cross brand joint promotions and/or events with brands within the HCML Group.
- Your personal data will be stored, processed, transferred and used within HCML Limited for the above purposes including managing the data, providing quality services and market analysis.

- Your personal data may also be processed on our behalf by our trusted third party providers.

- Our trusted third parties will perform a range of business operations on our behalf and assist us in the management of your orders. We only provide them with the information they need to perform the service, and we require that they do not use your personal data for any other purpose. We always use our best efforts to ensure that all third parties we work with keep your personal data secured. For instance, we may entrust services that require the processing of your personal data to:

(a)    third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;

(b)    advertising, marketing, digital and social media agencies to help us to deliver advertising, marketing, and campaigns, to analyse their effectiveness, and to manage your contact and questions;

(c)    third parties required to deliver a product to you e.g. postal/delivery services;

(d)    third parties that assist and help us in providing IT services, such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications that may contain data about you (such services could sometimes imply access to your data to perform the required tasks);

(e)    payment service providers in managing your orders and credit reference agencies for the purpose of assessing your credit score and verifying your details where this is a condition of entering into a contract with you; and

(f)    third parties that assist us for customer care and post-market surveillance purposes.

If at any other point of time you do not wish us to use your personal data for use in direct marketing as described above, you may exercise your opt-out rights by notifying us at the address set out in Clause 6 below.

 

3. Disclosure
In cases where we do collect personal data from you, we will:

(a)    tell you (by way of this PICS or by a separate notification) that we are doing so and the use that we will make of such personal data we collect;
(b)    where relevant, give you the opportunity to opt out; and
(c)    tell you how we will store your personal data and how you can review, change and delete the personal data we have stored.

We will take all practicable steps to keep your personal data confidential but we may transfer/assign such data to the following parties:

(a)    business partners , agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services to us in connection with the processing and storage of your data;
(b)    entities within the HCML Limited
(c)    if we decide to sell any relevant part of our business, to any actual or proposed assignee, transferee or successor; and
(d)    any person to whom we are under an obligation to make disclosure under the requirements of any law.

 

4. Security
Except as mentioned in paragraph 3 above, your personal data, however stored, will be accessed only by our employees or contractors who are authorised to do so. Where personal data is stored electronically, it will be kept on a separate server and will be password-protected (or under some equivalent form of protection) and accessible only by authorised personnel. Employees and contractors designated to handle personal data will be instructed to do so only in accordance with this PICS.

 

5. Your Right to Access and Correction

You may at any time request access to and to correct personal data relating to you in any of our records. You may also ask us to delete you or your personal data from any active mailing or distribution list. To exercise any of your rights, contact us at this email: hcml@hcmlhk.com, marking your communication "Confidential". In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days, but we may charge you a reasonable fee for doing so. 

In particular, to the extent permitted by applicable law, you have the following rights:   

(a)    The right to be informed: you have the right to obtain clear, transparent and easily understandable information about how we use your personal data, and your rights. You will find all this information in this Policy

(b)    The right of access: you have the right to access to the personal data we hold about you

(c)    The right of rectification: you have the right to have your personal data rectified if it is incorrect or outdated and / or completed if it is incomplete

(d)    The right to object to direct marketing: you can unsubscribe or opt out of our direct marketing communication at any time. 

(e)    The right to withdraw consent at any time for data processing based on consent: You can withdraw your consent to our processing of your data when such processing is based on consent.

6. Personal Data Privacy Officer

To exercise your rights or for any other questions relating to the collection and processing of your data by HCML Group, or for general information regarding our policies and practices with respect to personal data,  or for  general questions and complaints, you can contact us by sending an email.

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7. Retention of Data

We will keep your personal data only for as long as necessary to fulfill the purpose for which the data was collected. We may also retain archived personal data for statistical purposes.

Personal Data which is no longer required will be destroyed.

 

8. Acknowledgement
By signing the Members Application Form, you have indicated your understanding of and agreement to the above provisions.