Arredamenti Company Limited (Kelvin Giormani)
This policy statement provides information on the obligations and policies of Arredamenti Company Limited, its subsidiaries, affiliates, and associated companies (the “Company”), under the Hong Kong SAR Personal Data (Privacy) Ordinance – Cap.486 (the “Ordinance”).This policy specifically addresses the Company’s obligations in respect of the data privacy laws of the Hong Kong SAR. Throughout this policy, the meaning of the term “personal data” is as defined in the Ordinance.
COMPANY CORPORATE POLICY
The Company shall fully comply with the obligations and requirements of the Ordinance. The Company’s officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company. The Company shall endeavor to ensure all collection, storage, transmission and other handling or usage of personal data by the Company shall be done in accordance with the obligations and requirements of the Ordinance. Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in accordance with the time and manner stipulated within the Ordinance.
PURPOSE OF COLLECTION
For the purpose of carrying on the Company’s businesses, including sale, provision, membership and administration of the Company’s sofa product and related products and services (including relevant sales operations and maintenance services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
(a) Your name;
(b) Service installation address, correspondence address, and/or billing address;
(c) Membership details, including membership numbers, correspondence address and telephone numbers;
(d) Payment details, including credit card and banking information;
(e) Contact details, including contact name and telephone number or email address. In some instances, you may also be requested to provide certain data that may be used to further improve the Company’s 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 personalized service, or provision of a product is dependent on your providing all requested data, failure to provide the requested data may prevent the Company from providing the service to you. This type of data includes, but is not limited to:
(a) Your age;
(c) Other related products and services subscribed to; and
(d) Family and household demographics. The Company’s web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server’s usage so that the Company may better meet the demands and expectations of visitors to its sites. This type of data may include, but is not limited to:
(a) The browser type and version;
(b) Operating system; and
(c) The IP address and/or domain name. Some of the Company’s web sites may place a “cookie” in your computer; for example to provide personalized services and/or maintain your identity across multiple pages within or across one or more sessions. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across the Company’s web sites.Under certain circumstances, telephone calls made to the Company’s order and/or service hotlines and/or inquiry telephone numbers will be recorded 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, every care is taken to protect such recordings from inadvertent and/or unauthorized access.
USE OF PERSONAL DATA
Your personal data may be used for:
(a) verifying your identity;
(b) provision of goods and services to you;
(c) 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 goods and services to you;
(d) marketing and advertising of any goods and/or services to you by the Company, related companies, agents, contractors and third party suppliers;
(e) business planning and improving goods and/or services for supply to you, by the Company, related companies, agents, contractors and third party suppliers;
(f) processing of any benefits in connection with the supply of goods and services to you;
(g) analyzing, verifying and/or checking of your credit, payment and/or status in relation to supply of goods and services to you;
(h) processing of any payment instructions, direct debit facilities and/or credit facilities in relation to supply of goods and services to you;
(i) enabling the daily operation of your account and/or the collection of amounts outstanding in your account with the Company including the use of debt collection agents;
(j) enabling the Company 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 goods and services to you;
(k) keeping you informed about goods and services supplied to you and other goods and services made available by the Company;
(l) prevention or detection of crime; disclosure as permitted or required by law; and
The Company intends to use a customer’s data in direct marketing and the Company requires the customer’s consent for that purpose. In this connection, please note that: The Company will use customers’ personal data for direct marketing of latest offer and promotion activities which collected before 1 April, 2013, to let you know more our news, including but not limited to providing product and service information, promotional activities and membership offers etc. The Company intends to use customers’ personal data, such as name, membership no., phone no., email and delivery address for the above direct marketing purpose. Unless we receive customers’ instruction to remove their names from our database, the Company will continue to send your information as usual.If you do not wish to receive any future marketing and promotional information from us, please indicate your objection by return email to firstname.lastname@example.org together with your personal data, especially your membership number and invoice number for further arrangement or making a request of “stop to receive email” from our electronic direct mail. If you have any further enquiry, please contact our Customer Service Department during office hour from Mon to Fri 9:30am to 1:00pm and 2:00pm to 6:00pm at Tel: 2688 2072.
ACCURACY OF PERSONAL DATA
Where possible, the Company will validate data provided using invoice numbers, names and phone numbers. In some instances, the data provided will be validated against pre-existing data held by the Company. In some cases, as per the requirements of the Ordinance, the Company is required to check your invoice numbers or phone numbers before the personal data may be used, such as membership numbers, delivery address. The Company fully complies 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 the Company may hold.
RETENTION OF PERSONAL DATA
The Company will destroy any personal data it may hold in accordance with its internal policy.
Generally speaking, the Company’s policies cover the following principles:
(a) Personal data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
(b) Personal data are purged from the Company’s manual, in accordance with specific schedules based on the above criteria and the Company’s internal procedures.
DISCLOSURE OF PERSONAL DATA
All personal data held by the Company will be kept confidential but the Company 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:
(a) Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;
(b) Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided;
(c) Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
(d) the Company’s dealers, agents, contractors, suppliers and other telecommunication, information service providers and content providers; its professional advisers, including its accountants, auditors and lawyers;
(e) Government and regulatory authorities and law enforcement agencies and other organizations, as required or authorized by law; and
(f) Any financial institutions, charge or credit card issuing companies, credit information or reference bureau, or collection agencies, necessary to establish and support the payment of any services being requested. 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. We may transfer your Personal Information in connection with a transaction with another company which affects the control, governance, structure and/or management of all or a sustainable part of our business, or if required to satisfy applicable legal or regulatory requirements.
SECURITY OF PERSONAL DATA
Physical records containing personal data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled. 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 an individual’s Company responsibilities and their training. Where the Company holds, uses and/or transmits the Customers’ personal data it will be adequately protected from accidental and/or unauthorized disclosure, change and/or destruction.
ACCESS AND CORRECTION OF PERSONAL DATA
User the Personal Data (Privacy) Ordinance (the “Ordinance”), you have the right to request access to and correction of any Personal Information that you provide to us. You may make such a request by writing to our Customer Service Officer at
Address: 6/F., Yan Hing Centre, 9-13 Wong Chuk Yeung Street, Fotan, N.T., Hong Kong.
Tel: 2688 2072 (Office hours: Mon-Fri, 9:30am to 1:00pm, and 2:00pm – 6:00pm)