Respecting and protecting our customers’ privacy and personal data is important to Liberty Supply Co and its related companies (including all subsidiary and affiliate companies) (collectively, we or us). This Privacy Policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.

It also describes your data protection rights, including a right to object to some of the processing which we carry out.

 

What information do we collect?

We collect and process personal data about you when you:

- visit and/or register on any websites owned and operated by us (collectively, our Site);

- place an order or an appointment with us as a guest or as a registered user on our Site;

- Subscribe our e-newsletter;

- use a third-party service offered by service providers such as analytics companies, advertising networks and cooperatives, demographic companies, and any other third-party service providers that we choose to collaborate or work with, and we obtain your personal data from those third parties; and

- provide us with your personal data via: our physical stores, social media platforms/networks or telephone enquiries, your application for or use of our services or loyalty programme.

In this Privacy Policy, your personal data means: your name, email address, contact number, MAC address, IP address, credit/debit card and other payment information, gender, date of birth, age, interests, geographical location, Site usage (including browsing behaviour / activities), shopping and purchasing behaviour and other personal data you provide.

 

How do we use this information, and what is the legal basis for this use?

We process personal data for the following purposes:

To conduct our business and pursue legitimate interests, in particular:

- To provide our services to you, including: responding to any questions you may have, providing you with recommendations on products in our physical stores or on our Site; maintaining your shopping cart on our Site; assessing your applications with us for any of our services or loyalty programme; fulfilling any orders you may make with us (including verification and security checks of your details, processing of your payments, shipping products that you have ordered to you, and processing returns or exchanges of products you have purchased); personalizing our services to you and enhancing your experience in using our services; and

- We monitor use of our Site and our services (both online and offline), and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;

- To analyse trends, usage, browsing and shopping behaviour with us (whether on an individualized or anonymized and aggregated basis), which helps us better understand how you and our collective customer base access and use our Site, physical stores and services, for the purposes of:

- improving our services;
- to respond to customer desires and preferences;
- measuring the effectiveness of our marketing campaigns;
- conducting marketing activities targeted at external, potential customers (on an aggregated and anonymized basis only); and
- crowdsource data analytics and hackathon activities (on an aggregated and anonymized basis only).

When you give us consent (if required):

- To provide you with direct marketing communications in relation to products, services, events, offers or promotions under the categories stated below, provided by: (a) us or our related companies (including our affiliate and subsidiary companies), (b) business partners, and (c) other third-party providers. Such marketing communications may be in various forms, including advertisements, special events notifications or newsletters, and delivered via various methods in accordance with the personal data that you provide to us, such as by email, SMS, Whatsapp, smartphone app push notifications, notifications on your social media pages, in–app messaging or postal mail; and

- To allow you to register for and participate in our events and promotions, including verifying your identity at those events and promotions.

Relying on our Legitimate interests:

We have carried out an assessment on all the data processing activities described above in order to weigh up any privacy implications against our legitimate business interests. You can obtain information on any of our assessments by contacting us using the details set out later in this policy.

Withdraw consent or otherwise objecting to direct marketing:

Wherever we require your consent under applicable law, you will always be able to withdraw any consent provided to us. We shall cease to use your personal data for the purpose in respect of which you have withdrawn your consent, but we may still use, process, store and transfer your data for other purposes, such as those set out above. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) contacting our us via email: jaaamhk@gmail.com, or (b) in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.

Who will we share this data with, where and when?

Personal data will be shared with related companies of Liberty Supply Co and third party service providers located within or outside of Hong Kong and Macau, who will process it on our behalf for the purposes identified in this Privacy Policy. In particular, we use the following third party providers:

-       Courier services;

-       E-mail/SMS/MMS/Whatsapp blasting services;

-       Data storage and cloud service providers (for storage of your personal data and hosting of applications that process your personal data for the purposes identified in this policy);

-       Google, Facebook and other advertising networks (for matching of your personal data with their database in order to send you our direct marketing materials through your Google and/or Facebook account(s));

-       Marketing (including digital marketing) and website analytic agencies (for display of advertising materials on our Site and other websites that you may visit, and analysis of your online behaviour and usage of our Site – these agencies use cookies); and

-       E-commerce platform providers and reservation platforms.

In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

What rights do I have?

Where permitted by law, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at jaaamhk@gmail.com. You may also access, verify or update your personal data by logging into our e-commerce platform: www.jaaamhk.com .

How long will my data be kept?

Where we process registration data, we do this for as long as you are an active user of our Site and it is required for business and legitimate interests or legal requirement.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.

Browsing information collected from you (Cookies) 

We use cookies and similar technologies to collect data about you when you visit our Sites. Cookies are files that store information on your computer hard drive or browser, that means that we can recognise that you have visited our Sites before. We use cookies to give you the best possible experience on our Sites, by evaluating the use of our Sites and reviewing your browsing and shopping habits, personalizing your website experience, evaluating website activity on our Sites and generally making our Sites easier to use.   

The types of data we may collect from you when you visit the Sites include: 

-       Information about the type of browser you use; 

-       Details of the web pages you have viewed; 

-       Your IP address;

-       The hyperlinks you have clicked; and

-       The websites you visited before arriving at our Site.   

You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but to do so you may not be able to utilize or activate all of the functions and services of our Sites.