2. Definitions and interpretation
Collectively all device information and personal information that you submit to KAMKWAT LIMITED via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws
Any applicable law relating to the processing of Personal Data, including but not limited to the Personal Data (Privacy) Ordinance, and any national implementing laws, regulations and secondary legislation in the Hong Kong;
KAMKWAT LIMITED, we or us
KAMKWAT LIMITED, a company incorporated in Hong Kong with company number 1581116 whose registered office is at Unit 1603, Westin Centre, 26 Hung To Road, Kwun Tong, Hong Kong;
Hong Kong Cookie Law
The Personal Data (Privacy) Ordinance;
User or you
Any third party that accesses the Website and is not either (i) employed by KAMKWAT LIMITED and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to KAMKWAT LIMITED and accessing the Website in connection with the provision of such services; and
The website that you are currently using, which is located on the Internet at www.kamkwat.com, excluding any other sub-domain of the parent domain at www.kamkwat.com.
a) the singular includes the plural and vice versa;
c) a reference to a person includes firms, companies, government entities, trusts and partnerships;
d) "including" is understood to mean "including without limitation";
e) reference to any statutory provision includes any modification or amendment of it;
3.2. For purposes of the applicable Data Protection Laws. KAMKWAT LIMITED is the “data controller”. This means that KAMKWAT LIMITED determines the purposes for which, and the manner in which, your Data is processed.
4. Data collected
4.1. When you visit our Website, we will automatically collect certain information about the device you are using to access it. This will include information about the website browser you are using, the operating system or your computer, and the IP address of your internet connection. We may also identify your device with a unique, randomly generated, identifier.
4.2. As you browse our Website we will continue to collect information about the Website pages that you look at during your visit, how long you visit them, and what links you click on each page. We may also record what keywords you used to locate our Website and what third-party website referred you to our Website.
4.3. The information we collect about you is referred to as "Device Data". It's not personally identifiable to you (for example, we do not collect or associate your name or address with this Device Data) and it's not stored on our systems for any longer than we need to store it in order to allow you to use our Website for the purposes in which it is intended.
4.4. We may, from time to time, collect information about your actions on the website and record those actions in log files. This Data will include your IP address and may include the device that you are using, the browser that you are using, your internet service provider and be attached to date and time stamps. We'll only include this information for as long as necessary.
4.5. You may be asked to provide certain information about you that is personally identifiable to you. We call this information "Personal Data". We may collect your Personal Data in a number of ways, for example:
a) when you use our Website to make a purchase;
b) when you register for an account on our Website;
c) when you elect to receive marketing communications from us using our Website;
d) when you contact us using our Website or by email.
4.6. Such Personal Data we collect may include:
b) date of birth;
d) job title;
f) contact information such as email addresses and telephone numbers;
g) demographic information such as postcode, preferences and interests,
5. How we use your Personal Data and Device Data
5.1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a) to fulfil any order that you place and to communicate with you as one of our customers;
b) to improve and optimise our website (by generating data about how our customers browse and interact with our website);
c) to analyse the success of our marketing and other advertising campaigns;
d) to help us screen for potential risk and fraud;
e) with your consent, to provide you with information or advertising relating to the products and services that we provide;
f) internal record keeping;
g) to provide customer support; and
h) recovery of claims and the exercise of our rights (for example in the case of a lawsuit concerning our services),
5.2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
5.3. For the delivery of direct marketing to you via email, we’ll need your consent, whether via an opt-in or soft opt-in:
a) soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
b) for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
c) if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
5.4. We may use your Data to show you our adverts and other content on other websites. If you do not want us to use your data to show you our adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).
7. Who we share Data with
7.1. We will share Personal Data and Device Data with third parties in their capacity as a data processor on our behalf. We will only share your information with third parties in so far as they assist us with using your information and as long as they meet the standards on the processing of data and security.
7.2. We engage with the following types of third-party service providers:
a) site usage analytics providers, who provide the tools for us to analyse Website visitor behaviour;
b) business intelligence analytics providers, who enable us to measure and assess important metrics such as sales performance and the effectiveness of our marketing campaigns so we can stock the right products, send the relevant marketing campaigns and understand our business and customers better;
c) email providers, who enable us to deploy our email campaigns such as newsletters to inform you of our latest offers;
d) customer support providers, who enable us to manage customer enquiries effectively;
e) where relevant, our professional advisers, such as lawyers and consultants.
7.3. If you use the services provided by other providers to interact with us, such as a virtual assistant or a social media platform, your Data is also subject to the privacy policies of these companies.
7.4. We may also share your Personal Data in order to comply with applicable laws and regulations or to respond to any lawful request for information we receive, or to otherwise protect our rights.
8. Changes of business ownership and control
8.2. We may also disclose Data to a prospective purchaser of our business or any part of it.
8.3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
9. Keeping Data secure
9.1. We will use technical and organisational measures to safeguard your Data, for example:
a) access to your account is controlled by a password and a user name that is unique to you.
b) we store your Data on secure servers.
c) payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).
9.2. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: firstname.lastname@example.org.
9.3. If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit Get Safe Online at www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
10. Data retention
10.2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
11. Your rights
11.1. You have the following rights in relation to your Data:
a) Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b) Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c) Right to erase - the right to request that we delete or remove your Data from our systems.
d) Right to restrict our use of your Data - the right to “block” us from using your Data or limit the way in which we can use it.
e) Right to data portability - the right to request that we move, copy or transfer your Data.
f) Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
11.2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: email@example.com.
11.3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For Hong Kong, this is the Office of the Privacy Commissioner for Personal Data (PCPD). The PCPD’s contact details can be found on their website at https://www.pcpd.org.hk.
11.4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
12. Links to other websites
13.3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
13.4. This Agreement will be governed by and interpreted according to the law of Hong Kong. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Hong Kong courts.
14.2. You may contact KAMKWAT LIMITED by email at firstname.lastname@example.org.