Wing On Rewards Personal Data Protection and Privacy Policy (Version: April 2018)

The Wing On Department Stores (Hong Kong) Limited ("Wing On" or "we" and "us" and "our" shall be construed accordingly) owns and operates Wing On Stores in Hong Kong. We respect the privacy of all individuals, and we ensure that our employees handle personal information in accordance with the strictest standard of security and confidentiality. We pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) ("Ordinance") in Hong Kong. This Personal Data Protection and Privacy Policy applies to all products and services provided by us including but not limited to the app or such other program or software named as Wing On Rewards ("Wing On Rewards") and sets out how we may collect, use and disclose your personal information. We protect and handle your personal information in accordance with these terms and conditions.

1. Collection of Personal Data

1.1 Your privacy is important to us and we do not collect excessive personal information from you for the purpose of providing this service and protect the personal information ("Wing On Rewards Membership Account") provided by you.

1.2 When you use your Wing On Rewards Membership Account, including when you register as a Wing On Rewards member, we may ask you to provide personal information, including without limitation to name, date of birth, gender, phone number, email address, contact/delivery address, etc. (collectively "Personal Data"). Please note that it is mandatory for you to provide certain fields of Personal Data as specified at the time of collection. Or else, we may not be able to provide you with our products and/or services (including registering you as Wing On Rewards member).

2. Use and Transfer of Personal Date

2.1 We may collect certain your personal Information, including contact details, and the record about the services or support that you have requested. Any Personal Data provided to us means you authorise us to collect, retain and use Personal Data about you for the following purposes:
(a) operating and/or managing your Wing On Rewards Membership Account; (b) verifying your identity; (c) providing you with rewards, promotions, vouchers or services under Wing On Rewards; (d) updating you for the latest service update or notice; (e) providing you with customer services and responding to your queries; (f) performing statistics and analysis in order to develop or improve our services; (g) for marketing and promotional purposes; and (h) making such disclosures as may be required for any of the above purposes or as required by law or in respect of any feedback or claims made by you.

2.2 You further agree that we may disclose and transfer (in Hong Kong or overseas) your Personal Data to third party service providers engaged by us to provide
(a) data entry, (b) customer database management, (c) customer contact (and service providers may contact you regarding promotions, product rewards, vouchers, redemptions and customer services), and (d) secure data disposal services ("Third Party Service Providers"). The Third Party Service Providers are under a duty of confidentiality to us and are only permitted to use your Personal Data in connection with the purposes specified in 2.1 above, but not for their own purposes (including direct marketing).

2.3 When necessary we may also disclose and transfer (in Hong Kong or overseas) your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations for purposes specified in 2.1(h) above.

2.4 We may only use your name, phone number, email address and contact/delivery address with your consent or with your indication of no objection to provide marketing materials to you relating to Wing On Rewards and/or your Wing On Rewards Membership Account and goods/services which may be redeemed under Wing On Rewards and/or your Wing On Rewards Membership Account, including goods and services provided by all Wing On related companies and Wing On's merchants/partners.

2.5 We may share unidentified aggregate data with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt to our products and services.

2.6 Any Personal Data supplied by you will be retained by us and will be accessible by our employees, the Third Party Service Providers and third parties referred to in 2.3 above, for or in relation to any of the purposes stated in 2.1 herein.

2.7 We may permit individuals who are staff members of Wing On ("Staff Members") to use Wing On Rewards (including but not limited to registering as a Wing On Rewards member and using the various functions provided by Wing On Rewards) but such Staff Members must at all times comply with all applicable codes of conduct and/or other relevant company policies of us and/or their relevant employer(s) when using Wing On Rewards . Notwithstanding anything stated herein, in the event it is found that a Staff Member misuses Wing On Rewards in his/her capacity as a Staff Member (including but not limited to using any confidential or other similar insider information to obtain an unfair advantage from any promotions or offers offered by Wing On Rewards), we will report the said matter to the relevant authorities for investigation and/or disciplinary purposes.

3. Safety of Personal Data

No system is impenetrable and no information provided over apps or the internet can be guaranteed to be completely secured. Thus, we cannot guarantee the security of any information that you transmit to us or receive from us over Wing On Rewards or the internet. All reasonable efforts are made to ensure that any Personal Data held by us is stored in a secure and safe place, and accessed only by our authorised employees or authorised Third Party Service Providers.

4. Use by Third Parties

Wing On Rewards may link to other apps, websites and/or webpages which are operated by third parties. We have no control over the content of the linked apps, websites and/or webpages or the way in which the operators of those apps, websites and/or webpages deal with your Personal Data. You should review the Personal Data Protection and Privacy Policy for those third party apps, website and/or webpages to understand the ways in which your Personal Data may be used by those third parties.

5. Access or Amend Personal Data

5.1 Under the Ordinance, you have the right of access to Personal Data held by us about you and to request correction of your Personal Data.

5.2 If you have any questions regarding this Personal Data Protection and Privacy Policy or if you wish to access or correct your Personal Data, you may send your request in writing to the following address:
Customer Service Department
Wing On Department Stores (Hong Kong) Limited
Wing On Godown Building, 1 Wang Kee Street, Kowloon Bay, Kowloon, Hong Kong

5.3 In accordance with the Ordinance, we reserve the right to charge you a reasonable fee for the processing of any data access or correction request.

6. Updates

We may amend or update this Personal Data Protection and Privacy Policy from time to time without prior notice and your Personal Data collected shall be governed by our latest Personal Data Protection and Privacy Policy, which shall be available in this webpage.

7. Versions

In case of discrepancies between the English and Chinese versions in respect of all or any part of this policy, the English version shall prevail.