Privacy Policy Statement and Personal Information Collection Statement
Privacy Policy Statement and Personal Information Collection Statement
This Privacy Policy was updated on and its effective date is July 26, 2021.
1. General
This Privacy Policy aims to give you information on how Lee Kum Kee and its affiliates (referred to in this privacy policy as “we”, “us” or “our”) collect and use your personally identifiable and non-personally identifiable information we may collect through our website https://csa.lkk.com (the “Site”). This Privacy Policy is only applicable to the Site. Because Lee Kum Kee does not control how information is collected or used by third-party websites, this Privacy Policy does not apply to the websites of other individuals or entities that contain links to this Site.
If you are a California resident, please also review our California Privacy Policy by clicking here, which supplements and/or modifies the Privacy Policy described below with respect to only California residents.
We respect your privacy and are committed to protecting your personal information. This Privacy Policy describes how we collect, use and disclose your personal information, and what rights you have with respect to the use of your information.
2. Assent
By using the Site, you assent to this Privacy Policy. If you do not assent to this Privacy Policy, do not use the Site and do not submit any personally identifiable information through the Site.
3. Purpose of this Privacy Policy
In line with our obligations under, in particular and where appropriate, the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong), European data protection laws and other applicable privacy laws, this privacy policy sets out how we will collect, hold and use your personal information where we are a data controller with respect to your personal information. In particular the table in the section “How we collect and use your personal information” below specifies the purposes for which we may use your personal information as a data controller. Where we refer to “you” and “your” in this privacy policy, we are talking to the individual whose personal information we use as a data controller.
4. Types of Personal Data Collected
Personal data, or personal information, means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (anonymous, deidentified or aggregate data). It also does not include publicly available information.
For the purpose of carrying on our business and providing our products and services, including registration and administration of our website and related products and services (including relevant online services), we may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:
● Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
● Contact Data includes billing address, delivery address, email address and telephone and fax numbers.
● Financial Data includes bank account and payment card details.
● Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
● Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
● Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, education and profession; hobbies and leisure activities; Other related products and services subscribed to; and Family and household demographics.
● Usage Data includes information about how you use our website, products and services.
●Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. How is your personal data collected?
We use different methods to collect data from and about you including through:
● Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• subscribe to our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
● Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
● Crazy Egg. Our website uses a service called Crazy Egg to collect anonymous data about user behavior on some of the Website’s pages, such as where they click or scroll to on a page. To do this, Crazy Egg will deposit a cookie in your browser. Neither we nor Crazy Egg will use this information to personally identify our website’s users. Please see Crazy Egg’s Privacy Policy. Find out how to opt out of Crazy Egg.
● Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:
ο analytics providers such as Google Analytics based outside the EU;
ο advertising networks such as Google AdWords based outside the EU; and
ο search information providers such as Google, Bing, Yahoo based outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources.
● Where we are a data controller in respect of your personal information, we are required by European data protection laws to be clear about the purposes for which we are processing that personal information and our lawful basis for doing so.
6. Why we use your data
Lee Kum Kee may use the personally identifiable information you choose to submit through the Site to communicate with you about our products and services. When we collect this information, we may store it in our computer systems. Do not submit any information via this Site that you do not want us to store or use. If you do not want to submit information through this Site, call us instead.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer |
(a) Identity |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges |
(a) Identity |
(a) Performance of a contract with you |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy |
(a) Identity |
(a) Performance of a contract with you |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
7. Marketing By Us and Third Parties
We want to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us where you have purchased products or services from us as an individual customer or if you have requested information from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by unsubscribing from each email sent to you as part of a campaign and by making a request to unsubscribe on the “Contact Us” page on our official website (https://www.lkk.com).
Lee Kum Kee may use the aggregate and non-personally identifiable information collected through the use of cookies or IP address collection to improve users’ experience on the Site. This Site may not support your browser software’s Do Not Track setting or feature. Some Internet browsers include the ability to transmit Do Not Track signals that give you control over the collection and use of web browsing information. Since there are no uniform standards for such signals, Lee Kum Kee does not process or respond to such signals.
8. Retention of Personal Data
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Disclosure of Personal Data
We may share your personal data with the parties set out below to enable us to carry out the activities specified in the table above:
● Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control within the Lee Kum Kee Group;
● Any person or company who is acting for or on behalf of the Company, or jointly with the Company, such as our service providers including hosting providers, advertising and email service provider;
● Any party as ordered by court or competent authority. For example, if we were served with a court order demanding certain customer information then we would need to disclose the information to the duly appointed officer of the court or such other persons as the court orders.
In addition, if we choose to sell, transfer, or merge parts of our business or our assets or if we seek to acquire other businesses or merge with them, we may need to share your personal information with those other businesses. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
10. Transferring Your Information
The Lee Kum Kee Group is a global organization. Personal information is stored on servers located in different international jurisdictions, and personal information may be processed outside of the European Economic Area.
Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it.
11. Security of Personal Data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. Individual Rights for Site Users Who Do Not Reside in the United States
If you reside in the European Economic Area, European Union, or Switzerland; submitted personally identifiable information to Lee Kum Kee through this Site; and want to request a copy of, correct, delete, or limit the ways Lee Kum Kee uses the information, send an email to contact@lkkusa.com indicating your request. We will use reasonable and appropriate measures to honor your request.
13. Individual Rights for Site Users and Consumers Who Reside in California
If you are a California resident, please also review our California Privacy Policy by clicking here.
14. Children
Lee Kum Kee does not target, market to, or offer its products or services to children under the age 13 who are living anywhere in the world. Lee Kum Kee does not target, market to, or offer its products or services to anyone living outside the United States, which includes children under age 16. If Lee Kum Kee learns a child under age 13 living in the United States or a child under age 16 living outside the United States submitted through the Site the child’s personally identifiable information without parental consent or Lee Kum Kee learns it collected information about the child through the Site, Lee Kum Kee will take reasonable and appropriate steps to delete it.
15. Assignment
If Lee Kum Kee sells its assets to or is acquired by another company, or if Lee Kum Kee merges with another company, you, by using this Site, authorize Lee Kum Kee to assign the personally identifiable information you provided to Lee Kum Kee or that Lee Kum Kee collected while you used this Site.
16. Email Communications
If you submit your personally identifiable information through this Site, Lee Kum Kee may send you emails. If you receive an email from Lee Kum Kee that you did not want to receive or if you want Lee Kum Kee to stop sending you emails after you receive one from Lee Kum Kee, notify the email’s sender or follow the unsubscribe instructions in the email. Lee Kum Kee will use reasonable and appropriate measures to honor your request.
17. Data Security
Lee Kum Kee uses reasonable and appropriate measures to safeguard the information you submitted to us through the Site or that Lee Kum Kee received about you through the Site. You agree by using this Site that you understand that no transmission of information over the Internet can be guaranteed to be totally secure. If you do not want to transmit information to Lee Kum Kee because Lee Kum Kee cannot and does not guarantee it will be 100% secure during its transmission, do not submit personally identifiable information through the Site, call us instead.
18. Choice/Opt-out
Registering with the Site is voluntary. You may view most of the Site without registering or submitting your personally identifiable information through the Site. Some portions of the Site may only be available to users who have registered. If you want to stop receiving the information you requested when you registered, to update the registration information you submitted, or to correct any personally identifiable information in or remove any personally identifiable information from Lee Kum Kee’s computer systems, send an email to contact@lkkusa.com indicating your request. Lee Kum Kee will use reasonable and appropriate measures to honor your request.
19. Changes to Privacy Policy
Lee Kum Kee may change this Privacy Policy. When Lee Kum Kee changes it, Lee Kum Kee will revise the Privacy Policy’s effective date. If Lee Kum Kee changes the Privacy Policy in a way that will decrease limitations on how Lee Kum Kee may use the information it collected about you, Lee Kum Kee will either send a notice email to you at the email address you provided or the email address Lee Kum Kee has on file for you, or Lee Kum Kee will publish a notice on the Site, or Lee Kum Kee will use other reasonable and appropriate measures to notify you of the change.
This Policy was written in English. To the extent a translated version conflicts with this Policy, the English version will take priority.
20. Getting in touch
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at contact@lkkusa.com.