Privacy policy
Privacy Policy 私隱政策 (目前私隱政策只提供英文版本)
INTRODUCTION
Purpose of this Privacy Policy
Good Lucky Sky Limited (referred to in this Privacy Policy as “Good Lucky Sky”, “Bulbul Teahouse”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit us at bulbulteahouse.com (the “Website”), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.
This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to our newsletter, purchase any products or services and/or take part in a competition.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them.
Data Controller
Bulbul Teahouse is a “data controller” of your personal data.
In simple terms, this means that we (i) “control” your personal data, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or as otherwise permitted by law.
Contact Information and Complaints
If you have any questions about this Privacy Policy or any questions regarding our use of your personal data, please contact our data privacy manager at contact us page.
Changes to this Privacy Policy and Personal Data
This Privacy Policy is regularly reviewed and was last updated on 27 April 2023. We may amend or update our Privacy Policy from time to time. For this purpose, we will provide you notice of amendments to this Privacy Policy and update the “last updated” date above.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
THE DATA WE COLLECT ABOUT YOU
The types of personal data we collect, use and store about you will depend on the services you have requested from us and/or the nature of your interaction with us. When using our Website, we collect and process the following types of personal data:
- your first name, last name, username or similar identifier, date of birth and gender (“Identity Data”);
- your billing address, delivery address, email address and telephone numbers (“Contact Data”);
- your bank account and payment card details (“Financial Data”);
- details about payments to and from you and other details of products and services you have purchased from us (“Transaction Data”);
- your 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 (“Technical Data”);
- your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (“Profile Data”);
- information about how you use our Website and services (“Usage Data”); and
- your preferences in receiving marketing from us and our third parties and your communication preferences (“Marketing and Communications Data”).
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW WE COLLECT YOUR DATA
Direct Interactions
We collect Identity Data, Contact Data and Financial Data about you that you provide to us 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;
- register on our Website;
- subscribe to our newsletter;
- request other marketing material to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us in any way or form.
Automated Technologies and Interactions
As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
A cookie is a small file of letters and numbers stored by computer after being sent to your computer when you visit a website. Whenever you visit the same website again, the information stored in the cookie can be retrieved to notify the website of your previous activity. We use cookies to facilitate website navigation, maintain quality of online service, provide additional security, allow the customization of your access to the Website and remember you when you return to the Website.
A cookie cannot give us access to your computer or to information beyond what you provide us and we don't store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience on our Website. If you do not wish to enable cookies, you'll still be able to browse the Website and use it for research purposes.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
When you visit our Website, you may notice some cookies that are not related to Bulbul Teahouse. If you go on to another website that contains embedded content, you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Third Parties
We are also working closely with third parties (including, for example, analytics providers).
We will receive personal data about you from such third parties as set out below:
- Technical Data from analytics and search information providers such as Google;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Visa, MasterCard; and
- Identity and Contact Data from publicly available sources
HOW WE USE YOUR PERSONAL DATA
We are committed to only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (“Performance of Contract”).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
- Where we need to comply with a legal obligation (“Legal Obligations”).
We plan to use your personal data for the following purposes, and pursuant to the corresponding legal bases:
|
Purpose |
Type of Data |
Lawful Basis and Basis of Legitimate Interest |
|
Registration as a new customer |
Identity Data; Contact Data. |
Performance of Contract |
|
Processing and delivery of your order |
Identity Data; Contact Data; Financial Data; Transaction Data; Marketing and Communication Data. |
Performance of Contract; Legitimate Interest (to recover debts due to us). |
|
Management of our relationship with you (i.e. notifications about changes to Privacy Policy and asking you to leave a review or take a survey) |
Identity Data; Contact Data; Profile Data; Marketing and Communication Data. |
Performance of Contract; Legal Obligations; Legitimate Interest (to keep your records updated and to study how customers use our products/services). |
|
Enabling you to partake in a prize draw, competition or complete a survey |
Identity Data; Contact Data; Profile Data; Usage Data; Marketing and Communication Data. |
Performance of Contract; Legitimate Interest (to study how customers use our products/services and grow our business). |
|
Administration and Protection of our Website (including troubleshooting, data analysis, testing, system maintenance, support reporting and hosting of data) |
Identity Data; Contact Data; Technical Data; |
Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Legal Obligations |
|
Delivery of relevant website content and advertisements to you and understanding the effectiveness of the advertising we serve to you |
Identity Data; Contact Data; Profile Data; Usage Data; Marketing and Communication Data; Technical Data. |
Legitimate Interest (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). |
|
Using data analytics to improve our Website, products/services, marketing, customer relationships and experiences |
Usage Data; Technical Data. |
Legitimate Interest (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). |
|
Suggestions and recommendations about goods or services that may be of interest to you |
Identity Data; Contact Data; Profile Data; Usage Data; Marketing and Communication Data. |
Legitimate Interest (to develop our products/services and grow our business). |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please feel free to contact us any time.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Marketing and Promotional Offers
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity Data, Contact Data, Technical Data, Usage Data 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 emails and newsletters from us if you have requested information from us or purchased products or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have expressly consented to receiving such marketing emails and newsletters.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by:
- by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences;
- by following the opt-out links on any marketing message sent to you; or
- by contacting us at contact uspage at any time.
Where you opt-out of receiving these marketing messages or newsletters, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions (which we will continue to process in order to perform a contract with you or as a result of our regulatory or legal obligations).
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who 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.
DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
In some circumstances, we will anonymise your personal data (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.
YOUR LEGAL RIGHTS IN HONG KONG
If you are currently staying in Hong Kong, you are entitled, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”), to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. Requests for access to or to correct personal data should be addressed to our Data Privacy Manager at contact us page. In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.
DEFINITIONS
In this Privacy Policy, the following expressions shall have the following meanings except where the context otherwise required:
“External Third Parties” shall mean (a) service providers based in Hong Kong who provide IT and system administration services; (b) professional advisors including lawyers, bankers, auditors and insurers based in Hong Kong who provide consultancy, banking, legal, insurance and accounting services; and (c) the Inland Revenue Department, regulators and other authorities based in Hong Kong who require reporting of processing activities in certain circumstances.
“Legitimate Interests” shall mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Legal Obligations” shall mean processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
“Performance of Contract” shall mean processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.