Privacy Policy
About this privacy policy
Our Privacy Policy applies to any customer or visitor to our website.
We care about your privacy and we think it is important that you always know what information we obtain about you in the context of your use of Tini Jewelry website (available at www.tinijewelry.com.hk, including any purchases or associated activities undertaken by you whilst using the website (the “Services“) and what that information is used for.
In the Privacy Policy below, we therefore aim to keep you fully informed as to the type, extent and purpose of the collection, storage, use and processing of your personal data by us.
“Personal data” means any data relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.
This Privacy Policy applies to the Website and your use of the Services.
Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.
IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT VISIT OUR WEBSITE OR USE THE WEBSITE SERVICES.
Who we are
We are an organisation who sell luxury jewellery.
We are Tini Jewelry Company Limited, a company registered in HONG KONG SAR (Business Registration number 59776741-000-05-21-9), whose registered address is at Flat B1, G/F, Lee Chong Building, 218-220 Wan Chai Road, Wan Chai, Hong Kong (hereinafter: “Tini Jewelry” “We” or “us”).
We are the provider of the Website and the Services and the organisation responsible for the personal data collected about you as part of your use of the Website and the Services within the meaning of applicable data protection and privacy laws.
How to contact us
If you have any questions about this Privacy Policy or our use of your personal data, if you need to report a problem, or if you would like to exercise one of your rights under data protection and privacy laws you can contact us using the following contact details:
Email: info@tinijewelryhk.com
Phone number: (852) 2698 8070
Fax number: (852) 2698 9738
Information we may collect
When you (i) use the Services, (ii) visit our Website, (iii) sign-up for our newsletter, (iv) book an appointment with us, (v) contact our customer services department, we may collect the following information from you directly:
- your name;
- your email address and phone number;
- your address;
- your IP address; and
- credit or debit card details.
IF YOU DO NOT WANT US TO COLLECT ANY OF THE INFORMATION DESCRIBED IN THIS SECTION, DO NOT USE OUR WEBSITE OR THE WEBSITE SERVICES.
Why we collect, process and use your information
We use your data to provide you with the Services. We collect, hold, process and use your personal data for the following purposes and any directly related purposes:
- To provide you with the Services
- to maintain updated customer accounts
- to provide you with a personalised online shopping experience
- to fulfil any enquiries you raise
- to process your online orders
- to communicate with you about your orders, and
- to book in-store appointments
For business administrative purposes, We use your data for business administrative purposes:
- to facilitate our internal business administration, including maintaining proper business records
- to administer databases (including our contacts database)
- to establish and manage good with you or the organisation with which you are associated
- to investigate or respond to any incidents, complaints or grievances
- to compile statistical data on the use of the Services to report on the cross section of people who use
- the Services, and
- as part of our efforts to keep the Website and our physical and digital assets safe and secure.
We use your data to provide you with details of our new products and services.
For marketing and promotion purposes to update you on our latest products and services which we think you may be interested in.
How long we keep your information for
We retain your personal data until you ask us to delete it or it is no longer necessary for the purposes described above.
You have a number of rights regarding your data.
- Your rights
You have various rights in relation to the data which we hold about you as described below.
To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out above. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. - Right to object
This right enables you to object to us processing your personal data where we do so for one of the following reasons: - to send you direct marketing materials; or
for scientific, historical, research, or statistical purposes. - Right to withdraw consent
If we obtain your consent to process your personal data for any activities, you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition. You can withdraw your consent by updating your preferences in your account or by contacting our customer services department. - Right to erasure
You have the right to request that we “erase” your personal data in certain circumstances. Normally, this right exists where:
The data are no longer necessary;
You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue; The data has been processed unlawfully;
It is necessary for the data to be erased in order for us to comply with our obligations under law; or
You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data. - Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances, if we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data. - Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. Requests for rectification should be sent using the contact details set out above. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision. - Right to complain
You also have the right to complain to your data protection authority. In Hong Kong the data protection authority is the Office of the Privacy Commissioner for Personal Data.
Sharing your information
We may share your data with certain third parties (e.g. to help us provide the Services and the Website). In general, your data is processed exclusively by us and we do not pass on any personal user data to third parties unless in the context of our Website and Services. Where we do share your personal data, we do so with the following categories of recipients:
- Service providers
We may share your personal data with third party service providers who perform functions on our behalf (including logistics companies, website providers, email communications service providers, payment and tax calculation services providers, technical support functions and IT consultants carrying out testing and development work on our business technology systems). We will only share your data with these third party service providers where we have an appropriate data processing agreements (or similar protections) in place and they will not be able to use your data for their own purposes (e.g. for their own marketing purposes). - Professional advisors and Auditors
We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us. - Replacement providers
In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If Tini Jewelry or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.
Otherwise, your data will only be disclosed in special exceptional cases, where we are obligated or entitled to do so by statute or upon binding order from a public authority.
Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time.
We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page from time to time to review the Privacy Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded to our Website. This Privacy Policy was last revised on 19/08/2021
Grounds for processing your information
Where you give us your consent to process your personal data
We are allowed to use your personal data where you have specifically consented. In order for your consent to be valid:
It has to be given freely, without us putting you under any type of pressure;
You have to know what you are consenting to – so we’ll make sure we give you enough information;
You should only be asked to consent to one thing at a time – we therefore avoid “bundling” consents together so that you don’t know exactly what you’re agreeing to; and
You need to take positive and affirmative action in giving us your consent – for example, we could provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We currently seek your consent to use your personal data for marketing and advertisement purposes.
Before giving your consent you should make sure that you read any accompanying information provided by us so that you understand exactly what you are consenting to.
You have the right to withdraw your consent at any time, and details can be found in the “Right to withdraw consent” paragraph in the section on your rights above.
We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:
- To provide you with the Services;
- To ensure that our systems run smoothly;
- To protect against improper use or unauthorized use of our Website;
- To protect against fraud; and
- To market our Website and Services.
We don’t think that any of the activities set out above will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this in the section on your rights above.
Where processing your personal data is necessary for us to carry out our obligations under our contract with you.
We are allowed to use your personal data when it is necessary to do so for the performance of our contract with you.
For example, we need to collect and store your email address in order to provide you with our newsletter if you have requested it.
Where processing is necessary for us to carry out our legal obligations
As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we are allowed to use your personal data when we need to comply with those other legal obligations.
Use of personal data for direct marketing
- We intend to use your name, phone number, delivery address, email address, products and services portfolio information, transaction pattern as well as behaviour and demographic information held by us from time to time for direct marketing to provide marketing materials to you relating to our products and Services offered in our online and retail stores which shall include jewellery, after-sales services, media and publications.
- We may conduct direct marketing (including providing reward, loyalty or privileges programmes) in relation to the products and services that we, our affiliates and our co-branding partners may offer, including mailings, cards, gifts, event invitations, brochures and magazines.
- The above products and services may be provided by us and/or any of our affiliates and franchisees.
- In addition to marketing the above products and services, we may provide the personal data described in paragraph 1 above to all or any of the persons described in paragraph 3 above for use by them in marketing those products and services and we require your consent for that purpose.
- We may receive money or other property in return for providing the data to the other persons in paragraph 4 above and, when requesting your consent as described in paragraph 4 above, we will inform you if we will receive any money or other property in return for providing the data to the other persons.
Where we use and provide the data to the third parties as set out above for any promotional or marketing purpose, we will obtain your consent.
You may withdraw your consent to the use and provision to a third party of your personal data for direct marketing purposes at any time, and thereafter we shall, without charge to you, cease to use such data for direct marketing purposes. If you wish for us to exclude your personal data for direct marketing purposes, please contact us using the contact details above.
