WLS Limited (“we”, “our” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this PPS explains our privacy practices.
Types of Personal Data Collected
You may need to provide your personal data from time to time, including but not limited to your name, gender, age, identity card number, date of birth, phone number, facsimile number, address, email address, credit card details, education level, occupation, household income, hobbies or preferred activities. Failure to provide such data and/or provision of incomplete or inaccurate data may prevent us from providing certain services to you. If you are under 18, you must obtain the consent from parents or guardians before disclosing any of your personal data to us.
Purposes for which we will collect and use your Personal Data
Your personal data may be collected when you make a purchase, participate in promotional activities or apply to be a member of any of the brands operated by us from time to time, including but not limited to [WLS Limited].
Certain personal data is required to be provided on an obligatory basis if you wish to receive certain services from us. These data will be marked as “mandatory” in the Member Record Form and you MUST provide your personal data to us if you want us to provide the service for which you are applying. If personal data is only required on a voluntary basis, it will not be marked “mandatory” and it is entirely up to you to decide whether you want to provide such information to us or not.
Your supply of personal data is mandatory if you wish to receive one or more of the following services:
|(a)||Enrolment into and maintaining your membership as our member;|
|(b)||Accumulating bonus points as our member;|
|(c)||Communicating to you your entitlements and privileges as our member;|
|(d)||Redemption of privileges as a member;|
|(e)||Notification of any amendment to the membership program;|
|(f)||Data cleansing and customers profile updates; and|
|(g)||Other continuous customer support services in relation to your membership.|
We may use any personal data provided by you (whether on an obligatory and/or voluntary basis) to enable us to provide the following additional services to you and/or carry out the following activities:
|(a)||To enable us better to understand the demographics of our customers;|
|(b)||For internal research and analysis to enable us to provide rewards, services and product information or offerings better tailored to your needs;|
|(d)||To enable our beauty ambassador/consultant to follow up;|
|(e)||To distribute customer satisfaction survey; and|
|(f)||To send our VIP newsletters and VIP program updates.|
|(g)||To undertake targeted advertising.|
Disclosure of Personal Data
In cases where we do collect personal data from you, we will:
|(a)||Inform you (by way of this PPS or by a separate notification) that we are doing so and the purpose(s) for which we will use the personal data collected;|
|(b)||Where relevant, give you the opportunity to opt out; and|
|(c)||Tell you how we will store your personal data and how you can review, change and delete the personal data we have stored.|
All personal data collected and held by us will be kept confidential but we may provide and/or disclose such information to the following parties (whether within or outside Hong Kong (China) for the purposes set out in paragraph 3:
|(a)||Any member companies, subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with WLS Limited;|
|(b)||Any agent, contractor or third party service provider service provider (“Third Party Service Providers”) who provides administrative, telecommunications, computer, targeted advertising and other services to us in connection with the processing and storage of your data;|
|(c)||Any actual or proposed assignee, transferee or successor of WLS Limited; and|
|(d)||Government or regulatory authorities, law enforcement agencies or other organizations as required or authorized by law.|
Our Third Party Service Providers are under a duty of confidentiality and are contractually bound to use your personal data in connection with the purposes specified in paragraph 3 above and not for their own purposes (including direct marketing).
Use of Data in Direct Marketing
We may also use your personal data including name, telephone number, address and email for direct marketing. By law, we may not use your personal data for this purpose unless we have received your consent.
Upon your consent, your personal data may be used for:
|(a)||Communicating to you regarding new product launch and other promotional offers, including where applicable, skincare products, cosmetics products, make up products, beauty health supplement, body care products, make up services, body care services and facial services;|
|(b)||Communicating to you regarding our promotional events including where applicable, makeup classes and/or demonstrations, skincare seminars, other beauty classes, PR events, VIP gatherings, value sets, shop opening events, store announcement/ events, exhibitions, fashion shows and news update;|
|(c)||Communicating on-counter or out of counter services and events related to skincare, makeup or beauty services for promotion or rewarded purpose;|
|(d)||Marketing reward programs, birthday celebration offers, free sampling, digital campaigns, roadshow/ outpost, in store promotion updates;|
|(e)||Communicating joint promotion or events with shopping malls, department stores, credit cards, banks, trades, celebrities, magazines, television, websites, mileage programs, cultural, art or musical societies/ organizations, charities or nonprofit organizations; and|
|(f)||Cross brand joint promotions and/ or events with brands within WLS Limited.|
If at any other point of time you do not wish us to use your personal data for use in direct marketing as described above, you may exercise your opt-out rights by notifying us through the communication channels as stated in paragraph 7 below.
All personal data provided by you will be properly stored in our customer service system and can only be accessed by authorized persons.
Your Right to Access and Correction
You may at any time request access to and to correct personal data relating to you in any of our records. You have the right to request access, deletion and correction of your personal data by emailing to our Customer Service Department firstname.lastname@example.org.
You may also request us to delete you or your personal data from any active mailing or distribution list. If you no longer wish to receive any future promotional or direct marketing material from us, please contact us at the telephone number or email below, marking your communication “Confidential”. In response, we may ask you to provide certain details about yourself to ascertain the authenticity and validity of the request.
Personal Data Privacy Officer
The person to whom (1) requests (i) for access to data or correction of data, (ii) for general information regarding our policies and practices with respect to personal data and (iii) about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:
Personal Data Officer
Please indicate your name, member ID or contact number for us to follow up your request.
Retention of Data
We will keep your personal data only for as long as necessary to fulfill the purpose for which the data was collected. Pursuant to our internal policy, we will keep a record of all transactions with you in our course of business for a reasonable period of time for review and verification purposes. Personal Data which is no longer necessary for the purposes for which the data was originally collected will be destroyed.