Respecting and protecting our customers’ privacy and personal data is important to THEA Home Beauty. This 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 that we carry out. More information about your rights, and how to exercise them, is set out in the section ‘What rights do I have?’.
2. What information do we collect?
We collect and process personal data about you when you:
2.1 visit and/or register on any websites owned and operated by us (including www.theahomebeauty.com and blogtheahomebeauty.com, i.e. our Site);
2.2 place an order with us as a guest or as a registered user on our Site;
2.3 provide your personal data through our Site for the purpose of registering for and creating an account;
2.4 request a product or services information or to receive any marketing, promotional or other types of communications;
2.5 provide us with your personal data via: our physical stores, Wi-Fi, mobile devices, social media platforms/networks or telephone enquiries, your application for or use of our services or loyalty programmes (such as our Privilege Cards or Private Sales);
2.6 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
2.7 make enquiries or comments through info@theahomebeauty.com: and/or interact with our sales staff or with us, including via WhatsApp, and at our physical stores via registration tablets.
3. How do we use this information and what is the legal basis for this use?
We process personal data for the following purposes:
3.1 to conduct our business and pursue legitimate interests, in particular:
3.1.1 To provide our services to you, including: responding to any questions you may have; providing you with recommendations on products in our stores or on our Site; maintaining your shopping cart on our Site; assessing your applications with us for any of our services or loyalty programmes; providing our Privilege Card to you; 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); providing free Wi-Fi services to you at our physical stores and providing the THEA App services to you; personalising our services to you and enhancing your experience in using our services; and
3.1.2 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;
3.1.3 To analyse trends, usage, browsing and shopping behaviour with us (whether on an individualised or anonymised and aggregated basis), which helps us better understand how you and our collective customer base access and use our Site, stores and services, for the purposes of:
3.1.3.1 improving our services;
3.1.3.2 responding to customer desires and preferences;
3.1.3.3 measuring the effectiveness of our marketing campaigns;
3.1.3.4 conducting marketing activities targeted at external, potential customers (on an anonymised and aggregated basis only); and
3.1.3.5 crowdsourcing data analytics and hackathon activities (on an aggregated and anonymised basis only).
3.2 when you give us consent (if required):
3.2.1 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, WeChat messages, smartphone app push notifications, notifications on your social media pages, in-app messaging or postal mail.
Such marketing communications may market or offer products or services (including special events and promotions) in the following categories: dining, food and beverages, sports, music, film, television and other entertainment, clothing and accessories, jewellery, luggage and bags, cosmetics, personal health and hygiene, electronics, home furnishings and housewares, automobiles, transport and travel, hotels, financial services, loyalty and reward programmes, media services, entertainment services, social networking services, payment services, on-line advertising services, other e-commerce, information and communications and services, concierge services, and other products and services related to any of the foregoing, which we think may be relevant to you based on information you provide to us (for instance, via your participation in our surveys); and
3.2.2 To allow you to register for and participate in our events and promotions, including verifying your identity at those events and promotions.
3.3 for purposes which are required by law:
3.3.1 In response to requests by government or law enforcement authorities conducting an investigation.
3.4 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, your physiological data in images captured by our analytics cameras (which data will be anonymised and aggregated before usage) and security CCTV, and other personal data you provide.
4. 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.
5. Withdrawing 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 to 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. Specifically, in the case of customers from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. 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 us via info@theahomebeauty.com; or (b) in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.
6. With whom, where and when will we share this data?
We will share your personal data with the related companies of Thea Home Beauty Group Limited for the purposes set out in Clauses 3.1 and 3.2 above.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes set out in Clause 3.3 above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified in Clause 3 above. In particular, we use the following third party providers:
6.1 Courier services;
6.2 E-mail/SMS/MMS/WeChat blasting services;
6.3 Telecom companies (for providing in-store Wi-Fi services);
6.4 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);
6.5 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));
6.6 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; please refer to our separate Cookies Policy for details); and
6.7 Data analytics and hackathon service providers and agencies (for the purposes stated in Clause 3.1.3 above, in which only anonymised data will be sent to service providers for those purposes in Subclauses 3.1.3.4 and 3.1.3.5)
Your data, in an anonymous form such that your identity cannot be ascertained, may also be sold to third parties for their own purposes.
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.
If you are located in the European Economic Area (EEA), where information is transferred outside the EEA and where this is to a business partner or third party service provider in a country that is not subject to an adequacy decision by the EU Commission, data will be adequately protected by EU Commission-approved standard contractual clauses, an appropriate Privacy Shield certification or third party or business partner’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to the contact mentioned in the section ‘How do I get in touch with you?’ below. Your personal data may be transferred to Hong Kong and Macao Special Administrative Regions, Mainland China, Taiwan Region, Indonesia, Singapore, Australia, the United States and Japan.
7. 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, and to ask us to share (port) this data to another controller.
In addition, if you are located in the EEA, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).
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 that 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.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests assessment, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are located in the EEA: if you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.)
8. 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 info@theahomebeauty.com or by writing to Privacy Officer, THEA Home Beauty Group Limited, Shop 302, Third Floor, Landmark Atrium, Hong Kong.
9. Who is the data controller?
The data controllers are THEA Home Beauty, and its related companies; contact details can be found in the "About Us" section of this website.
10. 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 request). 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.
(Applicable only if you are located in the EEA: where we process personal data for site security purposes, we retain it for seven years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for seven years from your last interaction with us.)
We will not keep the images captured by our analytics cameras for more than one day, and such images will be anonymised and aggregated before any use of the same for the purposes stated in Clause 3.1 above