1. General

This privacy policy aims to give you information on how Lee Kum Kee and its affiliates (referred to in this privacy policy as “we”, “us” or “our”) collect and process your personal data.

We respect your privacy and are committed to protecting your personal information. This privacy policy describes how we collect, use and disclose your personal information, and what rights you have with respect to the use of your information.

2. Purpose of this Policy

In line with our obligations under, in particular and where appropriate, the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong), European data protection laws and other applicable privacy laws, this privacy policy sets out how we will collect, hold and use your personal information where we are a data controller with respect to your personal information. In particular the table in the section “How we collect and use your personal information” below specifies the purposes for which we may use your personal information as a data controller. Where we refer to “you” and “your” in this privacy policy, we are talking to the individual whose personal information we use as a data controller.

3. Types of Personal Data Collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

For the purpose of carrying on our business, including registration and administration of our website and related products and services (including relevant online services), we may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

● Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

● Contact Data includes billing address, delivery address, email address and telephone numbers.

● Financial Data includes bank account and payment card details.

● Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

● Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

● Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, education and profession; hobbies and leisure activities; Other related products and services subscribed to; and Family and household demographics.

● Usage Data includes information about how you use our website, products and services.

● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

● Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• subscribe to our services or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us some feedback.

● Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

● Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:

ο analytics providers such as Google Analytics based outside the EU;

ο advertising networks such as Google AdWords based outside the EU; and

ο search information providers such as Google, Bing, Yahoo based outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• Identity and Contact Data from data brokers or aggregators.

• Identity and Contact Data from publicly available sources.

● Where we are a data controller in respect of your personal information, we are required by European data protection laws to be clear about the purposes for which we are processing that personal information and our lawful basis for doing so.

5. Why we use your data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communication	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communication	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communication	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communication (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

 

6. Marketing By Us and Third Parties

We want to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us where you have purchased products or services from us as an individual customer or if you have requested information from us and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by unsubscribing from each email sent to you as part of a campaign and by making a request to unsubscribe on the “Contact Us” page on our official website (https://www.lkk.com).

7. Retention of Personal Data

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see under Your Data Protection Rights for Further Information. In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Disclosure of Personal Data

We may share your personal data with the parties set out below to enable us to carry out the activities specified in the table above:

● Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control within the Lee Kum Kee Group;

● Any person or company who is acting for or on behalf of the Company, or jointly with the Company, such as our service providers including hosting providers, advertising and email service provider;

● Any party as ordered by court or competent authority. For example, if we were served with a court order demanding certain customer information then we would need to disclose the information to the duly appointed officer of the court or such other persons as the court orders.

In addition, if we choose to sell, transfer, or merge parts of our business or our assets or if we seek to acquire other businesses or merge with them, we may need to share your personal information with those other businesses. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

9. Transferring Your Information

The Lee Kum Kee Group is a global organisation. Personal information is stored on servers located in different international jurisdictions, and personal information may be processed outside of the European Economic Area.

Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it.

10. Security of Personal Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Your data protection rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. This may include the following rights:

● Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

● Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

● Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good rea son for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

● Object to processing of your personal information. This right applies where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

● Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

● Request the transfer of your personal information to another party (known as the “right to data portability”).

● Withdraw consent. This right applies only if we are relying on your consent to process any of your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact customer_service@lkk.com.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Changes to Privacy Policy

We reserve the right to modify this Policy at any time. If we make changes to this Privacy Policy, the updated Privacy Policy will be posted on our webpage in a timely manner and, if we make material changes, we will provide a prominent notice.

This Policy was written in English. To the extent a translated version conflicts with this Policy, the English version will take priority.

13. Getting in touch

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at customer_service@lkk.com.