Privacy Policy 2025

PRIVACY POLICY

 

1.           INTRODUCTION

1.1                        Galxboy takes its responsibilities in relation to protecting your Personal Data and compliance with Applicable Laws very seriously. We are committed to properly managing, protecting and processing your Personal Data in accordance with this Privacy Policy, which shall apply to all Personal Data we collect from you through our Website.

1.2                        Please read and review this Privacy Policy, which will inform you how we collect, use, process and disclose your Personal Data. We may also collect and process your Personal Data under any exceptions to Applicable Laws, which are not set out in this Privacy Policy. We trust that it will assist you in making an informed decision whether to provide us with any of your Personal Data.

1.3                        If you reside in the European Economic Area, United Kingdom, the United States of America or Mainland China, additional country-specific notices apply in addition to the main body of this Privacy Policy. Please see the relevant notices at the end of this Privacy Policy.

1.4                        For the purposes of understanding Galxboy's Privacy Policy ("Privacy Policy"), capitalised terms used in this Privacy Policy shall have the following meanings:

1.4.1                                   "Applicable Laws" means Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) and its subsidiary legislations and regulations as amended from time to time;

1.4.2                                   "Personal Data" means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as "personal data" or "personal information" under any Applicable Laws.

1.4.3                                   "Retail Goods and Services" means sales of goods or provision of services in relation to any of the following (whether through physical or online channels or in any other media now known or available in the future): food and beverages, restaurants, catering, groceries and household products, general merchandise, health and beauty, pharmaceutical products, fragrance and cosmetics, wine and liquor, cigarette and cigar, stationary, books and paper products, confectionary and toys, clothing, shoes, baby products, pets products, fashion accessories, bags and luggage, jewellery, watches, furniture, plants and accessories, sports and leisure equipment, phones and mobile devices, electronics and electrical appliances, computer software and games, fuel, tutoring, mentoring, home cleaning, janitor services, landscape and plant maintenance services, agricultural services, part time house keeping, plumbing services, locksmiths, barber and salon services, gym and fitness services, laundry services, florists, catering services, vehicle towing, and motor vehicle services, building maintenance, business information services, business support services, brokerage services, conference and exhibition management services, consultancy and marketing research services, supply chain management, event and project management services, gaming services, advertising and public relations services, media production services, recreational services, banking, lending, investment and financial services, debt collection agencies, trust services, valuation services, secretarial services, data storage and management services, courier services, shipping services, graphic and interior design services, legal services, medical and pharmaceutical services, therapists, accounting. auditing, bookkeeping and taxation services, engineering services, architectural services, surveying services, equipment rental services, hospitality services, insurance services, internet services, telecommunication services, testing services, photography services, printing and publishing services, property management services, real estate agencies and management, security services, home inspection services, storage and warehousing services, utilities services, oil and gas distribution, remittance services, travel agencies and tourism services, airlines, boat, limousine, taxi, truck and other transportation services, hospitals and nursing homes, childcare services, funeral services, casino services, investigative services, retail solutions, retail services and wholesales;

1.4.4                                   "Social Media" means Galxboy’s pages and accounts on third party social media platforms such as Instagram, Facebook, Tik Tok, X, Threads, Pinterest and YouTube';

1.4.5                                   "Website" means the Galxboy website accessed at the following address [   ]; and

1.4.6                                   "Galxboy, we, us, or our" means [   ] (Registration no. [    ]).

1.5                        During our relationship with you, we may collect Personal Data from you. Examples of the types of Personal Data we may collect include your name, contact details, mailing and delivery addresses, email address, birthday, network and device data, your shopping or browsing behaviours, facial image, voice recording (for customer service calls) and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us. We will notify you when you must provide such Personal Data. Where it is mandatory to provide such Personal Data, please note that if you do not provide such Personal Data to us, then we may not be able to provide our services to you. We may also request other Personal Data from which is not marked as "mandatory" where it is entirely voluntary for you to provide such Personal Data (though please note that such personal data are used for the purpose of improving our understanding of our Platforms' and users and providing better products and/or services).

1.6                        If you provide us with Personal Data relating to a third party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

1.7                        By (a) clicking "Yes" on our Privacy Policy pop-up or any web form referring to this Privacy Policy, (b) submitting your Personal Data to us when signing up for an account on the Website, (c) browsing our Website, or (d) ordering any of our products and services, you are agreeing to the terms of this Privacy Policy, (e) submitting your Personal Data to us when participating in any competitions hosted on the Website. We may update this Privacy Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Privacy Policy.

 

2.           HOW DO WE COLLECT YOUR PERSONAL DATA?

2.1                        We collect Personal Data from you when:

2.1.1                                   you register an account on the Website;

2.1.2                                   you sign up to receive our newsletter(s) or update(s);

2.1.3                                   you make a transaction regarding the products available on our Website;

2.1.4                                   you activate or use any payment-related functions available on our Website or provided by our third party service providers;

2.1.5                                   you browse our products and services or otherwise interact with our Website;

2.1.6                                   you accept our cookies on your device;

2.1.7                                   you interact with our Customer Service Team or other representatives, for example, via our chatbot, chat apps, messaging platforms, webform, emails, telephone calls, video calls, letters, or face-to-face meetings;

2.1.8                                   you interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;

2.1.9                                   you participate in our promotions, competitions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;

2.1.10                                we receive references from business partners and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;

2.1.11                                you or your authorised representative submits your Personal Data to us for any purpose reasonably authorized by you, for example if such representative is purchasing our product or service to be delivered to you or as a gift;

2.1.12                                our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or

2.1.13                                when you voluntarily submit your Personal Data to us for any reason.

2.2                        During the course of your use of our Website and our provision of the products and services, you agree that you have provided your consent to the transfer of your Personal Data from us to the third parties for the purposes set out in this Privacy Policy or any other terms provided by our third parties and/or affiliates. Your credit card details may be collected, processed and stored directly by our third-party payment service providers pursuant to their terms of use and privacy policies. We may collect your bank account details to process refunds. Please also take note of our Cookies Privacy Policy [MS1] below in respect of the data collected and used by third-party cookies and trackers on our Website.

2.3                        We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.

2.4                        Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the products and services you have requested.

 

3.           HOW WILL YOUR PERSONAL DATA BE USED?

3.1                        We may, via various mediums and modes of communications (where applicable), use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:

3.1.1                                   register and maintain your user account and to verify your identity or age;

3.1.2                                   process your order for our products or services, process or collect your payment for the order;

3.1.3                                   deliver or perform the products or services you purchased, including our couriers calling or messaging you to obtain your delivery instructions;

3.1.4                                   verify and carry out payment transactions (including any credit card payments, bank transfers, remittances, or e-wallet transactions) in relation to payments related to you and/or services used by you. In order to verify and carry out such payment transactions, payment information, which may include Personal Data, will be transferred to relevant third parties such as our payment service providers;

3.1.5                                   facilitate your use of payment-related services;

3.1.6                                   process your returns or refunds in accordance with our Terms and Conditions;

3.1.7                                   provide you with supporting services and functions related to our Website activity and/or user account, or which you have subscribed to, such as saved items in cart, wish list, brand or product notifications;

3.1.8                                   administering any competitions and communicating with you in relation to matters relating to such competitions, such as communicating competition terms and conditions, additional requirements, and winner announcements;

3.1.9                                   communicate with you in relation to (i) your queries, requests and feedback, (ii) material changes to our Website, Privacy Policy or other terms and conditions, and (iii) matters relating to the operation of your account;

3.1.10                                personalise and improve your customer experience when you visit the Website, for example by prioritizing products and services appearing in your search results or feed;

3.1.11                                monitor and enforce compliance with our Terms and Conditions, including dispute resolution;

3.1.12                                comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law; and

3.1.13                                ensure our Website function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Website.

(collectively, the "Purposes")

3.2                        In addition, we may, via various mediums and modes of communications (where applicable), use and disclose your Personal Data for the following purposes, to:

3.2.1                                       send you marketing communications in relation to our Retail Goods and Services (as applicable), any promotions in relation thereto, or the Website, including notifying you of our marketing event, initiatives and promotions, competitions, lucky draws, loyalty or point redemption programs and other promotions;

3.2.2                                       send you marketing communications in relation to the Retail Goods and Services (as applicable) or promotions in relation thereto of business partners who provide such Retails Goods and Services (as applicable), including promotional mail together with your order;

3.2.3                                       deliver ads which are related to our Retail Goods and Services (as applicable) which may be of interest to you on the Website;

3.2.4                                       enable businesses to deliver ads which are related to their Retail Goods and Services (as applicable) which may be of interest to you;

3.2.5                                       invite you to our private customer events;

3.2.6                                       process your participation in our promotions, competitions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;

3.2.7                                       conduct market and customer research, analysis or tracking;

3.2.8                                       promote our products and services on our Website;

3.2.9                                       manage the administrative and business operations of Galxboy and complying with internal policies and procedures;

3.2.10                                    improve your customer experience across all touchpoints and training our Customer Service Team, such as by recording and monitoring phone calls; and

3.2.11                                    any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page;

(collectively, the "Additional Purposes")

3.3                        We may also use your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws.

3.4                        We cannot use your Personal Data to send you any marketing communications without your consent. If you have given us your consent, you may withdraw your consent in accordance with paragraph 7 (Request to Withdraw Consent) below. If you withdraw your consent for us to use and process your Personal Data the Purposes or the Additional Purposes (except relating to sending you marketing communications), we may no longer be able to provide you with the related products, services or benefits associated with our promotion.

 

4.           WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

4.1                        In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:

4.1.1                                   Galxboy’s affiliated entities;

4.1.2                                   employees, consultants, temporary workers;

4.1.3                                   payment processors, who process your payment on the Website;

4.1.4                                   third party payment service providers in order for them to offer payment-related services to you;

4.1.5                                   third party logistics providers, such as courier services which will deliver your order to you;

4.1.6                                   business partners or vendors in connection with the processing and administering of any promotion, competition, event, service, loyalty or point redemption programme organised by us;

4.1.7                                   professional advisers and consultants who provide legal and other advisory and consultancy services;

4.1.8                                   agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and

4.1.9                                   any other party whom you authorize us to disclose your Personal Data to.

4.2                        We may also disclose your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws.

4.3                        We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.

 

5.           DISCLOSURE OF YOUR PERSONAL DATA OUTSIDE OF GALXBOY

5.1                        We will only disclosure Personal Data outside of Galxboy without your consent if we have a good-faith belief that disclosure of the Personal Data is reasonably necessary to:

5.1.1                                   meet any applicable law, regulation, legal process, or enforceable governmental request.

5.1.2                                   enforce applicable Galxboy Terms and Conditions, including investigation of potential violations.

5.1.3                                   detect, prevent, investigate or otherwise address any actual or suspected fraud, harmful or illegal activity, security, or technical issues.

5.1.4                                   protect against harm to the rights, property or safety of Galxboy, our users, a third party or the public as required or permitted by law.

5.2                        We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.

 

6.           HOW CAN I ACCESS OR CORRECT MY PERSONAL DATA?

6.1                        You may access or correct your name, e-mail address, shipping and billing addresses, contact numbers and other Personal Data by logging in to your user account on the Website under "Account Information" and clicking the "Edit" button under each relevant field.

6.2                        For Personal Data that cannot be corrected by you by logging in to your user account on the Website, you may request to access and correct such Personal Data by submitting a written request to us via our customer service feedback form (available on [   ] ) or by emailing our Data Protection Officer at [   ]. We may need to request additional information from you to confirm your identity before providing the access or making the correction.

6.3                        We will do our best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws.

6.4                        Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.

6.5                        We will send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by Galxboy within the year before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose or unless you and we agree that

6.6                        Subject to obtaining your consent, we may send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.

 

7.           REQUEST TO WITHDRAW PROCESSING

7.1                        If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please inform us as follows:

7.1.1                                   to withdraw consent from receiving marketing or promotional communications via SMS and/or other modes of telecommunications: please unsubscribe by following the instructions provided there in; or

7.1.2                                   to withdraw consent from marketing or promotional emails: please click on the Unsubscribe link in the marketing or promotional emails or submit a written request via email to [   ]; or

7.1.3                                   updating your settings in your account.

7.2                        Depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of our products or services.

7.3                        Once we receive notification that you wish to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials or communications during this period.

7.4                        If you withdraw your consent to receive marketing or promotional materials through a specific communication mode (e.g. SMS), we may still contact you for other purposes in relation to the products and services via other communication modes you have subscribed to (e.g. email).

7.5                        You may (a) withdraw your consent for the collection, use and/or disclosure of any of your Personal Data or (b) make a request to delete your Personal Data in our possession or under our control by submitting a written request via email to [   ]. We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent and it may take up to thirty (30) days for this to be reflected in our systems. Once this is complete, we will no longer collect, use and/or disclose your Personal Data, except for compliance, regulatory or other legal purposes.

 

8.           ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

8.1                        We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.

8.2                        We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized or accidental access, collection, use, disclosure, copying, modification, leakage, loss, damage, erasure, or alteration of your Personal Data. However, we will not be responsible for any unauthorized or accidental access, collection, use, disclosure, copying, modification, leakage, loss, damage, erasure, or alteration of Personal Data by third parties which is attributable to factors beyond our control.

8.3                        When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised.

8.4                        If Personal Data is transferred out of Hong Kong, we will comply with Applicable Laws in doing so. This includes: (i) obtaining your consent, unless an exception exists under Applicable Laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.

 

9.           INFORMATION COLLECTED BY THIRD PARTIES

9.1                        Galxboy uses the services of third party vendors, who may implement cookies on the Website. Advertisements on the Website may be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including Personal Data, collected by such third party cookies are subject to the privacy and data protections policies of the third party vendors and are not under our control.

9.2                        You may reject third party cookies through the settings on your browser. Note that this may result in the loss of Website functionality, restrict your use of the Website, or delay or affect the way in which the Website operates.

 

 

10.        DISCLAIMER REGARDING THIRD PARTY SITES AND ITS SECURITY

We do not guarantee the security of Personal Data and/or other information that you provide on third party sites. As part of our ongoing efforts to provide value to you, we may choose various third party websites or applications to link to, and frame within our Website and services. Your acceptance and use of the third party service provider’s platform and/or services shall be subject to terms and conditions as may be agreed between you and the third party service provider and at your own risk. Upon your acceptance of the third party service provider’s offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider) shall be subject to the applicable privacy policy of the third party service provider, who shall be the data controller of such data. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. Any queries or complaints relating to your acceptance or use of the third party service provider’s platform and/or services shall accordingly be directed to the relevant third party service provider.

 

11.            CONTACTING US

For any questions relating to your Personal Data or about this Privacy Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Data Protection Officer via one of the following methods: Email address -           [   ]. Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.

 

12.        GOVERNING LAW

This Privacy Policy and your use of this Website shall be governed in all respects by the laws of Hong Kong, and the parties hereto irrevocably submit to the non-exclusive jurisdiction of the Hong Kong courts.

 

13.        UPDATES ON DATA PROTECTION POLICY

13.1                     As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, Galxboy may update this Privacy Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Privacy Policy at our absolute discretion.

13.2                     Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Website. Any amended Privacy Policy will be posted on our website and can be viewed at [   ] By continuing to use our Website and/or services after the Privacy Policy has been amended, you hereby agree to be bound by the terms of such amended Privacy Policy.

13.3                     You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.

 

14.        MISCELLANEOUS

14.1                     Nothing in this Privacy Policy shall limit your rights under Applicable Laws.

14.2                     The provisions of this Privacy Policy shall be severable, and if any provision, or part-provision, of this Privacy Policy shall be held or declared to be illegal, invalid, or unenforceable, such illegality, invalidity, or unenforceability shall not affect any other provision, or part-provision, of this Privacy Policy, and the remainder of this Privacy Policy, disregarding such illegal, invalid or unenforceable provision, or part-provision, shall continue in full force and effect as through such illegal, invalid, or unenforceable provision, or part-provision, had not been contained in this Privacy Policy.

14.3                     This Privacy Policy will be in the English language and the Chinese language. In the event of any inconsistency between the English version and the Chinese version, the English version shall prevail.

 

15.        EU GDPR AND UK GDPR: NOTICE FOR RESIDENTS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

15.1                     In addition to the main body of the Privacy Policy, this notice applies solely to customers who reside in the European Economic Area (“EEA”) or United Kingdom (“UK”) and is presented in compliance with the European Union General Data Protection Regulation (“EU GDPR”) and United Kingdom General Data Protection Regulation (“UK GDPR”).

15.2                     Relying on our legitimate interests: We have carried out an assessment on all the data processing activities described in this Privacy Policy in order to balance any privacy implications of them with our legitimate business interests. You can obtain information on any of our assessments by contacting us at [    ].

15.3                     Withdrawing consent or otherwise objecting to direct marketing: Applicable laws permit us to send you direct marketing without your consent where we rely on our business or legitimate interests. However, regardless of the type of legal basis on which we rely to send you direct marketing, you have an absolute right to opt out at any time from direct marketing by us or from any profiling we carry out for that direct marketing.

15.4                     Who will we share this data with, where and when: If we transfer your Personal Data outside the EEA or UK (as applicable) to a business partner or third-party service provider in a country that is not subject to an adequacy decision by the EU Commission or Information Commissioner’s Office (as applicable), the Personal Data will be adequately protected by EU Commission/ICO approved standard contractual clauses, an appropriate Privacy Shield certification or the third party or business partner’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request by contacting us at [    ].

15.5                     Your Personal Data may be transferred to the Hong Kong Special Administrative Region.

15.6                     What rights do I have in relation to the processing of my Personal Data: You can object to our processing of your Personal Data where we do not need to process the data for business interests, other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements. You have the right to complain about any unresolved data privacy concerns to an EU data protection authority where you live, work or where you believe a breach may have occurred.

15.7                     How long will my data be kept: Where we process personal data for our Website security purposes, we retain it for seven years after any business and legitimate interests no longer exist. Where we process Personal Data in connection with performing a contract or for a competition, event or promotion, we keep the data for seven years from your last interaction with us.

 

16.        US PRIVACY NOTICE: NOTICE FOR RESIDENTS IN THE UNITED STATES OF AMERICA

16.1                     In addition to the main body of the Privacy Policy, this notice applies solely to customers who reside in the United States of America including California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia (collectively, the “Applicable States”). For residents of states that are not Applicable States, please consult the main body of the Privacy Policy.

16.2                     This notice applies to the processing of Personal Data under Applicable State privacy laws, including the California Consumer Privacy Act (“CCPA”); Colorado Privacy Act; Connecticut Data Privacy Act; Delaware Personal Data Privacy Act; Iowa Consumer Data Protection Act; Montana Consumer Privacy Act; Nebraska Data Privacy Act; New Hampshire Expectation of Privacy Act; New Jersey Online Services, Consumers, and Personal Data Act; Oregon Consumer Privacy Act; Texas Data Privacy and Security Act; Utah Consumer Privacy Act; Virginia Consumer Data Protection Act; and other applicable laws as they come into effect (collectively “Applicable State Privacy Laws”). If you are not a resident of an Applicable State, please refer to the main body of the Privacy Policy for information about how you can exercise your choices regarding your Personal Data.

16.3                     Information we collect: We are required to disclose to you the categories and sources of Personal Data we have collected from you within the last 12 months. Please refer to the paragraphs 2 and 3 above, for details on the Personal Data we collect.

16.4                     Sharing personal data/Do not sell my Personal Data: We may disclose your Personal Data to third parties for certain business purposes. Please refer to paragraph 4 section above for details. We do not sell your Personal Data to third parties for their own marketing, advertising or other business purposes, unless permitted by the Applicable State Privacy Laws.

16.5                     Your Privacy Rights: You have the right to request us to disclose to you certain information about our collection of your Personal Data over the past 12 months. Upon receipt and confirmation of your verifiable request, we will disclose to you the following information in respect of that period:

16.5.1                                the categories of Personal Data we collected about you;

16.5.2                                the categories of sources from which we collected Personal Data about you;

16.5.3                                our business or commercial purpose for collecting or selling such Personal Data;

16.5.4                                the categories of third parties with whom we share such Personal Data;

16.5.5                                the specific pieces of Personal Data we collected about you;

16.5.6                                if we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing the categories of Personal Information involved in: sales, and the category third party to whom the data was sold;

16.5.7                                disclosures for a business purpose, and the category of third party to whom the data was disclosed.

6.6                        Right to Request Deletion: You have the right to request us to delete Personal Data we have collected from you. Upon receipt and confirmation of your verifiable request, we will delete such Personal Data from our records, unless it is necessary to be retained in order for us or our service providers to:

6.6.1                                   complete the transaction for which such Personal Data was collected, fulfil the terms of a written warranty or product recall conducted in accordance with applicable law, provide a product or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

6.6.2                                   detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

6.6.3                                   de-bug products to identify and repair errors that impair existing intended functionality;

6.6.4                                   exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

6.6.5                                   comply with the CCPA;

6.6.6                                   engage in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent;

6.6.7                                   enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

6.6.8                                   comply with a legal obligation; or

6.6.9                                   use such Personal Data, internally, in a lawful manner that is compatible with the context in which you provided such Personal Data.

6.7                        Right to access Personal Data: You may submit requests to exercise your rights in relation to your Personal Data to the email address at [    ]. We will seek to disclose and deliver to you the required information in accordance with the Applicable State Privacy Laws.

6.8                        Right not to be discriminated against: We will not discriminate against you because you exercise your California privacy rights, and we will not deny you goods or services, charge you a different price or rates for goods or services or provide a lower quality of goods or services to you due to your exercise of any of those rights.

 

7             PERSONAL INFORMATION PROTECTION LAW: NOTICE FOR RESIDENTS OF MAINLAND CHINA

7.6                        In addition to the main body of the Privacy Policy, this notice applies solely to customers and other individuals who reside in Mainland China and use our services, and to our processing within Mainland China of those individuals’ Personal Data.

7.7                        The data controller for the purposes of this notice is [   ], whose registered address is at [   ]. For questions or concerns related to your Personal Data, please contact us at [   ].

7.8                        Purpose: Refer to the purpose of processing described in the main body of the Privacy Policy.

7.9                        Consent: We will obtain your consent (and, where applicable, your separate consent) to process your Personal Data if and to the extent required by Applicable Laws.

7.10                     Disclosure of Personal Data to Third Party Data Controllers: With your separate consent, we may disclose your Personal Data to our third party data controllers located within Mainland China for the purposes described in the Privacy Policy. You may contact us via [   ] if you would like to further details about the disclosures.

7.11                     Overseas Transfer of Personal Data: With your separate consent, we may transfer, access or store your Personal Data outside Mainland China, provided that either we are satisfied that adequate levels of protection are in place to protect the integrity and security of your Personal Data or we have adopted adequate security measures in compliance with applicable laws, such as appropriate contractual arrangements. Where required by applicable laws, we will put in place appropriate measures to ensure that all processing of your Personal Data outside of Mainland China is safeguarded by the equivalent level of data protection as in Mainland China. You may contact us via [    ] if you would like to further details about these overseas transfers.

7.12                     Security: We have implemented reasonable and appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access and other unlawful or unauthorised forms of processing, in accordance with applicable laws.

7.13                     Your Rights: In addition to the rights already set out in the Privacy Policy, you also have the following rights:

7.13.1                                the right to withdraw your consent to our processing of your Personal Data;

7.13.2                                the right to request de-registration of your account with us (if any); and

7.13.3                                the right to refuse decisions that materially impact you, where those decisions have been based solely on automated decision-making technology.

7.14                     Children’s Personal Data: We will not knowingly collect or process the Personal Data of any child under the age of 14 (“Child”), unless with the consent of the Child’s parent or guardian. If we become aware that we hold Personal Data of a Child, we will take steps to delete the Personal Data of the Child as soon as possible. Parents or guardians can also contact us to request such deletion.

7.15                     Changes to the Mainland China Notice: We may change this Mainland China Notice in order to comply with the evolving regulatory environment or, provided that this Mainland China Notice continue to comply with applicable law, the needs of our business. Subject to any applicable legal requirements to provide additional notice, any changes to this Mainland China Notice will be communicated through our Website. We will obtain your consent to such changes where required to do so by applicable laws.

7.16                     Contact us: If you have any concerns about how we process your Personal Data, please contact us at [    ].

 

 

 

COOKIE POLICY

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