1. OUR COMMITMENT
We value your trust in us and thank you for sharing your details with us via our website www.kinoa-shop.com (the “Website”). At Kinoa Limited, we are committed to safeguarding the privacy of individual with respect to personal data. We therefore make sure that our policies and practices in relation to the collection, use, retention transfer and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region (the “Ordinance”).
3. TYPES OF PERSONAL DATA COLLECTED
For the purpose of carrying on our business, we collect some information in order to operate effectively and provide you the best products and services we can.
In accessing or using our Website or any services provided through the Website, or viewing or accessing any information or content from this Website, you as our customer may be requested to provide personal data such as, but not limited to, the following:
i) contact details, including contact name, age, gender, telephone number and email address;
ii) correspondence address, and/or billing address;
iii) account details, including account numbers, service numbers, or user accounts;
iv) payment details, including credit card and banking information;
v) other information relevant to customers surveys and/or offers.
In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a service is dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data may sometimes include, but is not limited to:
i) hobbies and leisure activities;
ii) other related products and services subscribed to
iii) family and household demographics.
In support of the services offered by us, information may be automatically collected relating to those services so we may perform accurate reporting and administration of your accounts.
Our web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information so that we may better meet the demands and expectations of visitors to the Website, and take necessary actions in respect of any illegal or unlawful contents on any website visited through our web servers.
The types of data may include, but are not limited to:
i) the browser type and version;
ii) operating system;
iii) the IP address and/or domain name; and
Under certain circumstances, telephone calls made to and from our order and/or service hotlines and/or inquiry telephone numbers may be recorded solely for the purposes of quality control, appraisal, as well as staff management and development.
Unless expressly indicated otherwise at the time of calling, such recordings are NOT personal data of the caller and therefore, in respect of the caller, are not subject to the various provisions of the Ordinance and the caller has no rights and/or claims either statutory, contractual or tortious, over or to such data.
At all times, care is taken to protect such recordings from inadvertent and/or unauthorized access.
4. USE OF PERSONAL DATA
All the information we collect via the Website or through correspondence (including telephone calls) with you is used to operate and improve the service we offer you and to personalize our service.
We are committed to using your personal data only for:
• verifying your identity;
• processing of your application to subscribe to our services;
• provision of products and services to you;
• administration and management of those products and services which you have subscribed to;
• matching (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision of products and services to you; • marketing and advertising of any products and services to you by [KinoaLimited], related companies, agents, contractors and third party suppliers upon your consent in accordance with the prevailing requirements in the Ordinance (please refer to the section titled “Marketing” below);
• processing of any benefits in connection with the supply of products and services to you;
• analysing, verifying, enforcing contractual rights, and/or checking of your credit, payment and/or status in relation to supply of products and services to you;
• processing of any payment instructions, direct debit facilities and/or credit facilities in relation to supply of products and services to you;
• enabling the collection of amounts outstanding in your account with [KinoaLimited] including the use of debt collection agents;
• enabling [KInoa Limited] to comply with any obligations to interconnect, with other industry practices, or with obligations to third parties or government agencies in relation to the supply of products and services to you;
• maintaining and developing our business systems and infrastructure, including testing and upgrading of these systems;
• keeping you informed about products and services supplied to you and other products and services made available by [Kinoa Limited];
• prevention, detection or investigation of crime;
• disclosure as permitted or required by law; and/or
• any other purposes as may be agreed to between you and [KinoaLimited], including the purposes set out in any application or terms and conditions for the supply of specific products and services.
5. ACCURACY OF PERSONAL DATA
Where possible, [Kinoa Limited] will validate data provided using generally accepted practices and guidelines.
This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers.
In some instances, the data provided will be validated against preexisting data held by [Kinoa Limited].
We fully comply with the “rights of access and correction” obligations of the Ordinance.
Please refer to the section titled “Access and Correction of Personal Data” below for details on how you can obtain and correct any personal data relating to you that [Kinoa Limited] may hold.
Please note that the accuracy of such personal data we collect, use and disclose depends to a large extent on the information you provide.
You have a right to request correction of your personal data and we recommend that you:
• let us know if there are any errors in your personal data; and
• keep us up-to-date with changes to your personal data such as your name or email address.
6. RETENTION OF PERSONAL DATA
Kinoa Limited will destroy any personal data it may hold in accordance with its internal policy.
Generally speaking, our policies cover the following principles:
• personal data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
• personal data are purged based on the above criteria from [Kinoa Limited]’s electronic, manual, and other filing systems in accordance with [Kinoa Limited]’s internal procedures.
7. DISCLOSURE OF PERSONAL DATA
All personal data held by Kinoa Limited will be kept confidential but Kinoa Limited may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties in accordance with the Ordinance:
i) any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with [Kinoa Limited];
ii) any person or company who is acting for or on behalf of (KinoaLimited], or jointly with [Kinoa Limited] in respect of the purpose or a directly related purpose for which the data was provided;
iii) any other person or company who is under a duty of confidentiality to [Kinoa Limited] and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
iv) [Kinoa Limited]’s agents, contractors, suppliers, information service providers and content providers; its professional advisers, including its accountants, auditors and lawyers;
v) government and regulatory authorities and law enforcement agencies and other organisations, as required or authorised by law;
vi) any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureau, or collection agencies, security agencies, necessary to establish and support the payment of any services being requested;
vii) your authorized representatives or your legal advisers when requested by you to do so; and
viii) any proposed or actual participant, assignee or transferee of all or any part of [Kinoa Limited]’s operation or business.
Personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right/authority to access such information.
8. SECURITY OF PERSONAL DATA
We take every precaution to protect your personal data.
To this end, all personal data are stored on secure computer systems and storage media to which access is strictly controlled and/or are located within restricted areas.
Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a “need to know” basis that is commensurate with Kinoa Limited’s policy.
Where Kinoa Limited holds, uses and/or transmits the customers’ personal data it will be adequately protected from accidental and/or unauthorized disclosure, change and/or destruction.
Notwithstanding our security measures for protecting your personal data, you acknowledge that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the internet.
We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.
9. COOKIES POLICY
We use “cookies”, which are small text files stored on your device, to help operate the Website and to analyze information about online activity.
10. LINKS TO THIRD PARTY WEBSITES
Our Website may contain links to other sites and pages which are operated by third parties.
We have no control over the content of the linked websites or the way in which the operators of those websites deal with your personal data.
11. ACCESS AND CORRECTION OF PERSONAL DATA
Under the Ordinance, you have the right to request access to or correction of the personal data provided.
Such requests should be made in writing and sent to us at the following address firstname.lastname@example.org.
Kinoa Limited will, upon satisfying itself of the authenticity and validity of the access or correction request, make every endeavour to comply with and respond to the request within the period set by the Ordinance.
In accordance with the terms of the Ordinance, Kinoa Limited has the right to charge a reasonable fee for the processing of any data request.
Personal data supplied by you may be used for direct marketing activities (as defined in the Ordinance).
In accordance with the requirements of the Ordinance, you will be:
i) informed that your personal data will be used for direct marketing activities;
ii) informed that your personal data will not be used for direct marketing activities unless we have received your written consent;
iii) informed of, with specific information, the kinds of personal data to be used and the classes of marketing subjects in relation to which the personal data is to be used;
iv) given opportunity to communicate your consent at no extra charge from us;
v) provided, in case your consent to the use of personal data for direct marketing activities is given orally, a written confirmation within 14 days after receiving your oral consent;
vi) notified the first time your personal data is used for direct marketing activities and that we will cease to use your personal data for direct marketing activities if you wish; and
vii) given the liberty, at any time, to require cessation of the use of your personal data for direct marketing activities at no extra charge from us.
Personal data supplied by you may be provided to third parties for direct marketing activities (i.e. cross-marketing).
In accordance with the requirements of the Ordinance, you will be:
i) informed in writing of our intention to provide your personal data to third parties for direct marketing activities;
ii) informed in writing that your personal data will not be provided to third parties for direct marketing activities unless we have received your written consent;
iii) informed in writing that provision of your personal data to third parties for direct marketing activities will be for gain (if that is the case);
iv) informed of, with specific information, the kinds of personal data to be provided, the classes of marketing subjects and the class of persons in relation to which the personal data is to be provided;
v) given opportunity to communicate your consent at no extra charge from us; and
vi) given the liberty, at any time, to require cessation of our provision of personal data to third parties for direct marketing activities and notify the third party to cease the use of your personal data in direct marketing activities at no extra charge from us.
13. CHANGES AND UPDATES