DUO Rewards Hong Kong

PRIVACY POLICY AND PERSONAL INFORMATION COLLECTION STATEMENT – HONG KONG

Motor Image (HK) Ltd. and the Tan Chong International Limited group of companies (hereinafter “we” or “us”) are committed to protecting and respecting your privacy. This Privacy Policy And Personal Information Collection Statement (“Statement”) describes how we gather, process, use, disclose and store Personal Data that you provide to us, through the DUO Rewards Membership Programme, our websites or otherwise.

This Statement provides information on our policies under the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong ("Ordinance"). Terms used in this Statement shall, unless otherwise specified, be construed in accordance with the Ordinance.

This Statement also provides information on the Tan Chong International Limited group of companies’ websites. Please take a moment to familiarize yourself with this Statement prior to using our websites.

By registering for the DUO Rewards Membership Programme or visiting our websites you are explicitly accepting and consenting to the collection and the usage of your Personal Data and to the practices described in this Statement. You may also see our DUO Rewards Membership Terms and Conditions, and Terms of Website Use which explains to you how you may make use of our websites.

This Statement was last updated on 01 December 2015. We may from time to time update this Statement to ensure that it is consistent with our future developments, industry trends and/or any changes in the legal requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Statement which may be updated from time to time, including on our websites. Please check back regularly for updated information on the handling of your Personal Data, and to see any updates or changes to this Statement.

For the purpose of the Ordinance, the individual responsible for ensuring that we comply with the Ordinance is the Data Protection Officer. The contact information for our Data Protection Officer is listed below.

PURPOSE OF COLLECTION OF PERSONAL DATA

In this Statement, "Personal Data" has the meaning defined under the Ordinance. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals in any forms which you may have provided and submitted to us, or via other forms of interaction with you.

The provision of any Personal Data by you or on your behalf to us shall be voluntary and shall be deemed to authorize us to collect, process, retain, update and use your Personal Data for the purposes stated in this Statement. The Personal Data provided by you or on your behalf to MIHK from time to time will be used for the following purposes:

Processing and administering your application to join DUO Rewards Programme, and your subsequent lifetime membership with DUO Rewards Programme;
Carrying out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
Providing you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
Providing goods, facilities, discounts, offers, rewards redemptions and other services to you, including additional goods, facilities, discounts, offers, rewards redemptions as may arise from time to time;
Notifying you about any changes to our service;
Fulfilling requests submitted by you, whether online, over the phone, through our service centres, or through other methods, such as DUO Points / rewards / gifts redemption;
Conducting statistics and market research for the purpose of providing products or services to you;
Marketing, promotional and customer relationship management purposes, such as sending you updates on the latest offers and promotions of any goods or services in connection with our businesses, DUO Rewards Programme and/or any co-branding / joint promotion business partners and for assessing eligibility for any marketing and/or promotional activities and/or offers from us, DUO Rewards Programme and any co-branding / joint promotion business partners;
Responding, handling and processing any enquires / feedback submitted by you;
Administering contests and other activities conducted by us or on our behalf, including disclosing the winner(s) and/or participants of any such contests / activities;
Updating and verifying your identity, Personal Data and other information in accordance with relevant laws, regulations and guidelines;
Ensuring that content from our website is presented in the most effective manner for you and for your computer;
Improving our security, such as in relation to the processing of payment by credit card to guard against the risk of fraud, including carrying out matching procedures against databases of known fraudulent transactions (maintained by us or third parties);
Comparing the Personal Data provided by you with your other information possessed by our other companies, from time to time and at any time, for consistency and verification purposes;
Making such disclosures as may be required for any of the above purposes or by law;
Achieving any other lawful purposes relating to any of the aforesaid purposes;
Enforcing any legal or other rights we may have against you; and
Conducting research and market surveys.

In the event that the Personal Data provided by you is insufficient or we are not satisfied that such data is true and accurate, we reserve the right to refuse, suspend or withhold processing of your application, your DUO Rewards Membership and/or provision of any service to you unless and until the Personal Data required by us is provided.

PERSONAL DATA WE MAY COLLECT FROM YOU

We may collect and process the following information you voluntarily chose to provide to us, which may include Personal Data:

Information you give us. You may give us Personal Data when filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website, subscribe to our service, search for our products, place an order on our website, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number, personal description and photograph and other personal information. In the event that you provide us with any Personal Data relating to a third party (E.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with this Personal Data for the respective purposes.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you, via that website, when we collected that data that it may be shared internally, processed and/or combined with data collected on this website. Additionally, we may receive information about you from third parties (including, but not limited to business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

USE OF YOUR PERSONAL DATA IN DIRECT MARKETING

Other than as stated in the Statement of Purpose above, we shall not use your personal data in direct marketing unless we receive your consent (which includes an indication of no objection) to such intended use. In this connection, please note that: -

(i) your name, contact details, products and services portfolio information, transaction pattern and behaviour, consumption preference, financial background and demographic data held by us from time to time may be used by us in direct marketing;
(ii) the following classes of goods, facilities, services, and other marketing subjects may be marketed by us, namely:

DUO Rewards Programme activities, members' offers, gifts redemption, online shop, club news & updates;
reward, loyalty or privileges programs and related services and products;
services and products offered by us and/or our co-branding / joint promotion business partners who provide the following classes of products, facilities or services (whether through direct mailing, email or SMS): sales & aftersales services of motor vehicles, traveling, hotel & catering, food & beverage, publications & media, sports, auction, group buying, transportation & logistics, insurance, entertainment, art & culture, agricultural products, telecommunications, electronic & electrical products, health & beauty, medical, personal care, wedding, finance & banking, credit card service, information technology, home furnishing, pets related, household, apparel & accessories, education, social networking, engineering, manufacturing, property/ real estate management, private club, professional service, shopping malls, energy, fuel & lubricant, baby & child caring, planning & design, lab & R&D, jewelry & watches, environmental protection; and
donations and contributions for charitable and/or non-profit making purposes.

(iii) the above goods, facilities, services and marketing subjects may be provided or solicited by us and/or the following permitted classes of persons:

any subsidiaries, affiliates or associated companies of Tan Chong International Limited Group;
any third party goods and/or services providers;
any third party rewards, loyalties, co-branding or privileges programme providers; and
any charitable organizations.

(iv) in addition to marketing the above goods, facilities, services and other marketing subjects by itself, we also intend to provide the above personal data to all or any of the persons described in sub-paragraph (iii) above for use by it or them in marketing such goods, facilities, services and other marketing subjects, and we may not so provide the data unless we have received your consent (which includes an indication of no objection) to the intended provision.
(v) If you do not wish for us to use or provide to any other persons your personal data for use in direct marketing as described above, you may exercise your opt-out right by notifying us, in which event we must, without charge to you, cease to use or provide to other persons your personal data for use in direct marketing.
(vi) You may provide your consent to us using or providing to other persons your personal data for use in direct marketing as described above by notifying our Data Protection Officer, whose contact details are set out below, or through other channel(s) which you may be advised of when providing personal data to us.

DISCLOSURE OF YOUR PERSONAL DATA

We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of the applicable law, your Personal Data may be disclosed, for the purposes listed in this Statement, to the following entities or parties:

Any member of our group, which means any of our subsidiaries, related corporations and affiliates and with our ultimate holding company and its subsidiaries, within as well as outside Hong Kong SAR.
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, within as well as outside Hong Kong SAR.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose Personal Data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may make use of the Personal Data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Analytics and search engine providers, within as well as outside Hong Kong SAR, that assist us in the improvement and optimisation of our website.
Credit reference agencies for the purpose of assessing your credit score or providing finance to you where this is a condition of us entering into a contract with you.
In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Our professional advisers such as consultants, auditors and lawyers, within as well as outside Hong Kong SAR;
Companies, within as well as outside Hong Kong SAR, providing insurance and warranty services for our automotive customers; and
Any other party to whom you authorise us to disclose your Personal Data to.

OVERSEAS TRANSFER OF PERSONAL DATA

The Personal Data you provide may be transferred to another country that may not have similar protections in place regarding your Personal Data and restrictions on its use as set out in this Statement. However, we will take steps to ensure adequate protections are in place to ensure the security of the information. By submitting your Personal Data, you consent to these transfers for the purposes specified in this Statement.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by staff operating outside Hong Kong who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Statement.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We request that you do not share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

COLLECTION AND USE OF NON-PERSONAL DATA

With regard to each of your visits to our website, we may automatically collect the following information which does not identify you personally:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We do not link IP addresses to your Personal Data.

We will use this information:

to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our website to ensure that content is presented in the most effective manner, and to make our website more responsive to the needs and preferences of our users.
as part of our efforts to keep our website safe and secure;
to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising our customers; and
to make suggestions and recommendations to the users of our website about goods or services that may interest them.

COOKIES

Our website may use cookies and/or other similar technologies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. The information which we obtain from our use of cookies will not usually contain your Personal Data.

Using cookies enables us to provide you with a good experience when you browse our website and also allows us to improve our website. If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this Statement. If you change your mind in the future about letting us use cookies, you can modify the settings of your computer to reject cookies or disable cookies completely.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

RETENTION OF PERSONAL DATA

We will retain your Personal Data for as long as you use our products or services and it is required or relevant for business or legal purposes.

YOUR RIGHTS

You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes. If you do not want your information to be processed for marketing purposes, you may inform us at the time you provide the information by checking certain boxes on the forms we use to collect your data (if available), or by informing us at any time using the telephone number, email address or postal address listed below.

Note: Users who no longer wish to receive promotional newsletters or promotional emails can unsubscribe by clicking on the hyperlink named "Unsubscribe" which will be embedded in every promotional email sent out.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

ACCESS TO AND CORRECTION OF INFORMATION

The Ordinance gives you the right to access information held about you. Your right of access can be exercised in accordance with the Ordinance. Any access request may be subject to a fee of [HK$100] to meet our costs in providing you with details of the information we hold about you.

If there is an error or omission in the information we hold about you, you may notify us . We will correct the information unless we have reasonable grounds to believe that the correction should not be made.

If we have provided information that needs to be corrected about you to a third party within a year prior to when the correction was made, then we will provide the third party of the corrected information with your consent.

CONTACT

If you have any questions, comments or requests regarding this Statement, or would like to withdraw your consent to any use of your Personal Data, or would like to obtain access and make corrections your Personal Data records, please contact:

Data Protection Officer
Email: dpo@tanchong.com

Write to our Data Protection Officer at:

Attn: Data Protection Officer
Shop 4, G/F, Billion Centre, No.1 Wang Kwong Road, Kowloon Bay, Hong Kong