1. Sanmei Wellness Limited (collectively “we”, “us”, the “Company”) respect the privacy rights of individuals who visit the Company’s website located at URL https://www.sanmeihealth.com (collectively as the “Online Shop”) and, access, sign up for membership or purchase any of the Company’s services, products or online content (collectively referred to as the “Services”). We endeavour to ensure that all our collection, transfer, storage and usage of personal data are carried out in compliance with the Personal Data (Privacy) Ordinance, Cap 486 of the laws of the Hong Kong Special Administrative Region (the “PDPO”). By providing your personal data to us, you are consenting to the Policy and the collection, transfer, storage and usage of your personal data as described in the Policy.
2. The term “personal data” shall have the meaning ascribed to it in the PDPO.
3. If you are under the age of 18, you must have a legal representative such as a parent or guardian accepting the Policy on your behalf before providing any personal data to us.
4. If there is any inconsistency between the English and Chinese version of the Policy, the English version shall prevail.
PURPOSE OF COLLECTION AND USE OF PERSONAL DATA
5. You need not supply any personal data in order to access the Online Shop. When you participate in, access, sign up for membership or purchase any of the Services, personal data may be collected from you to enable us to provide the Services. If you fail to supply the personal data required, we may be unable to provide the Services in full to you.
6. Personal data collected from you may be used by the Company for, including but not limited to, the following purposes:-
a. identifying you and any accounts you hold with us;
b. enabling the provision of the Services to you;
c. processing of payment instructions or collection of amounts outstanding from you in relation to the provision of the Services;
d. order processing, billing and fulfilment;
e. enabling us to store your personal data for the ease of your future transactions;
f. direct marketing of the Services (see section “Direct Marketing” below);
g. conducting research, statistical analysis and behavioural analysis;
h. customer profiling and analysing your purchasing preferences;
i. making suggestions and recommendations to you and other users of the Services or goods and services that may interest you or them;
j. customising the Online Shop and its content to your particular preferences;
k. provisioning of customer services;
l. handling your complaints and account enquiries, and handling any claim, action and/or proceedings against the Company or any party;
m. fraud prevention and detection;
n. auditing purposes;
o. making such disclosures as required by applicable laws, rules and regulations; and
p. any other purposes directly related to the purpose for which the personal data were originally collected.
TYPES OF PERSONAL DATA COLLECTED
7. Types of personal data collected by the Company may include, without limitation:-
a. your personal information and contact information such as your name, your company name (if applicable), telephone number, email address, residential address, mailing address, and billing address; and
b. your account details, including last 4 digits of credit card account numbers, or user accounts.
CONFIDENTIALITY, DISCLOSURE AND SECURITY OF PERSONAL DATA
8. The Company does not trade your personal information and contact information for gain without your written consent. All personal data collected and held by the Company will be kept confidential, but when disclosure is necessary for the Company to comply with any statutory obligations or requirements, or for the Company to provide the Services to you or to carry out the original or directly related purpose for which the personal data was collected, those data may be provided to the following parties (whether within or outside of Hong Kong):-
a. competent court of law, law enforcement agencies, or other governmental or statutory authorities, institutions or organisations;
b. the Company’s associated companies, business partners, contractors, agents, sellers or suppliers of the goods/services, or other service operators, who are involved in the sales and marketing, administration or provision of the Services;
c. any other person under a duty of confidentiality to the Company including but not limited to a member of its group of companies, IT consultants, data processors, auditors, accountants, or lawyers, who has undertaken to keep such information confidential; and
d. banks, financial institutions, insurance companies, credit card issuing companies or debt collection agencies.
9. Any questions, comments, suggestions or information other than personal data sent or posted to the Online Shop by you will be considered as voluntarily provided to the Company on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development and marketing of services and to meet user needs.
10. All reasonable efforts are made to ensure that any personal data held by the Company is stored in a secure and safe place.
11. All personal data which we collect is kept confidential to the best of our ability.
TRANSFER OF PERSONAL DATA OUTSIDE HONG KONG
12. If necessary, the Company may transfer the personal data to places outside the Hong Kong Special Administrative Region for carrying out the original or the directly related purposes for which the personal data was collected. All transfer of those personal data will be carried out in compliance with the requirements of the PDPO.
RETENTION OF PERSONAL DATA
13. If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party. This is important to ensure that your account information will not be accessed by a third party who may have acquired the right to use your discarded mobile number. You are solely responsible for securing your account in this particular way. We shall have no liability to you for any loss or damage in this regard.
14. Unless there is a mandatory legal requirement for us to keep your personal data for a specified period, we will only retain your personal data for as long as is necessary to fulfil the purpose for which the personal data were originally collected. Once the personal data fulfils such purposes (and directly-related purposes), they are then destroyed within a reasonable time unless their retention is required to satisfy legal, regulatory or accounting requirements or to protect the Company’s interests.
SECURITY AND STORAGE
15. Except as mentioned in the paragraph ‘TRANSFER OF PERSONAL DATA OUTSIDE HONG KONG’ above, your personal data, however stored, will be accessed only by our employees or contractors who are authorised to do so. Where personal data is stored electronically, it will be kept on a secured server and will be encrypted and/or password-protected (or under some equivalent form of protection) and accessible only by authorised personnel of the Company or its contractors. The network transmission of personal data will also be protected by using the SSL protocol. Personal Data are treated as confidential information by the Company and all employees and contractors designated to handle personal data will be instructed to do so only in accordance with the Policy.
16. From time to time, the Company may use your personal data to send you news, offers, promotions and joint marketing offers and the Company requires your consent for that purpose. We may contact you by email, in-app notifications, SMS, text/picture/video message, telephone, or by post.
17. Your name, telephone number, email address, contact address, products and services portfolio information, transaction patterns and behaviours, browsing records, content viewing habits and personal interests held by the Company may be used by the Company for direct marketing of the Services.
18. If you prefer not to receive any direct marketing communications from us or our marketing partners, you can opt out at any time by updating your preferences through your registered account or a unsubscribe link provided. Upon receipt of your request, we shall cease to so use your personal data as soon as possible without charge to you.
a. recognise you whenever you visit the Online Shop;
b. obtain information about your preferences, viewing and browsing behaviour, online movements and use of the Internet;
c. keep track of the items stored in your shopping basket and take you through the checkout process;
d. carry out research and statistical analysis to help improve our Services and to help us better understand our visitor and customer requirements and interests;
e. target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests;
f. make your online experience more efficient and enjoyable; and
g. enable tighter security.
23. If it becomes necessary that we have to take commence legal action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and taking legal action against you.
DATA ACCESS AND CORRECTION
24. If you have any query in relation to the Policy or you wish to access or correct your personal data held by us, you may contact us by writing to the following address:
To : Sanmei Wellness Limited
Unit E1, 5/F., Block A, Tung Chun Industrial Building, 9-11 Cheung Wing Road,Kwai Chung, Hong Kong
Personal Data Policy Officer
25. The Company reserves the right to charge you a reasonable fee for complying with a PDPO permitted data access request.
26. The Policy is subject to change and any changes will be posted on this page. Your continued use of the Online Shop after the posting of such changes indicates your acceptance to the same.
Last Updated: January 2021