Our Commitment to Privacy
What is Personal Data
(a) relating directly or indirectly to a living individual;
(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
(c) in a form in which access to or processing of the data is practicable.
Information we collect from you and How we use such information
We will collect and process the following data about you:
(a) Information we collect about you
When you visit our Website, we will record each of your visit and will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for, filtered or purchased/redeemed, the hyperlinks you have clicked, the websites you visited before arriving at our Website, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse the Website, and any phone number used to call our customer service number.
This information is stored exclusively by us to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and for the control of illegal acts. We reserve the right to check these log files and data retroactively if there is reasonable suspicion of an illegal act due to concrete indications. As far as personal data is processed, we do so solely to protect our legitimate interest to control illegal acts particular in connection with our Website.
(b) Information you give us
This is information about you that you give us by placing an order with us at our store(s) and/or through our Website, signing up to our newsletters or promotional materials, registration for marketing and promotional activities or membership offered by us or any member of the TTI Group (as defined below), registering for product warranty, registering as a registered user of our Website, redemption of souvenirs, registering for servicing of your products, corresponding with us by e-mail, telephone or social media, creating an account with us, submitting your resume through our job recruitment section or otherwise. It includes information you provide when you enter a competition, promotion or survey, search for a product, report a problem with our site or tools via customer service or other social media functions on our site. The information you give us may include but is not limited to your name, your trade, your employer/company information, job title, telephone number, fax number, address, email address, personal description, photographs, age group, gender, date of birth, financial and credit card information, social media accounts information, the products you owned and their serial number, purchase history and payment receipt, service booking details, comments on products you provided, shopping preferences, interest and hobbies or personal information as set out in your resume. We will only request information, which is required for the specific purpose. Please note that it is mandatory for you to provide personal data marked with asterisks. Refusal to provide such information may render us unable to handle any application or request you are making, or may otherwise defeat the objectives of your visit.
By using our Website and providing personal data to us, you give your consent that we collect and process the data to provide you with the information, products and services that you requested from us. You have the right to withdraw this consent at any time. We may also use this data to carry out our obligations arising from any contracts entered between you and us. We store your personal data only as long as we need it to provide the information, services or offers you requested or to carry out our obligations arising from any contracts.
(c) Information we receive from other sources
This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Most of the cookies we use are so-called “session cookies”. Other cookies remain on your device until you delete them. These cookies allow us to recognize your browser at the next visit.
As far as personal data is processed in this regard, we carry out such processing on basis of our legitimate interest to improve our Website for users. We only process pseudonymised data in this regard upon your visit of our Website. You can delete cookies on your device at any time and once they are deleted we cannot process any information contained in a cookie.
You can further adjust your browser so that you are informed about the setting of cookies and only allow cookies on an individual basis, exclude accepting cookies for specific cases or in general, and activate the automatic deletion of cookies when you close your browser. The functionality of this Website may be restricted when cookies are deactivated.
- Google Analytics
As far as personal data is processed in this regard, we carry out such processing as part as of our legitimate interest for own marketing purposes. We safeguard your interests by anonymizing your IP address upon collection so that you are not identifiable.
- Facebook Pixel
We use the Facebook Pixel from Facebook Inc. (1601 S. California Ave. Palo Alto, CA 94304 (“Facebook”)) on this Website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected is anonymous to us. However, this data is stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
You can object to the collection of your data by Facebook Pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting Facebook.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
- Google Tag Manager
With Google Tag Manager, website tags can be administered via an interface. Google Tag Manager solely implements tags and it does not place any cookies and no personal data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If, at domain or browser level, a deactivation of certain websites is affected, this remains in place for all tracking tags to the extent that these are implemented with Google Tag Manager.
- Yahoo Tag Manager
With Yahoo Tag Manager, website tags can be administered via an interface. Yahoo Tag Manager solely implements tags and it does not place any cookies and no personal data is collected. For more information about Yahoo Tag Manager go to (https://marketing.yahoo.co.jp/service/tagmanager/) and (https://privacy.yahoo.co.jp/)
- Google Adword
Google AdWords inserts a cookie or a pixel on your computer or on your mobile device if you were directed to our Website via Google advertisement. These cookies are no longer applicable after 30 days. They do not serve for any personal identification. If the user visits certain pages of our Website and the cookie is still active, both we and Google will be able to see that you clicked on the advertisement and were forwarded to our Website. We, as well as all other clients of Google-AdWords, receive different cookies. The cookies affected by our Google advertisements can therefore not be followed beyond our Internet Service.
The information obtained from the conversion tracking serves to compile statistics on the conversion for us. We learn about the total number of users who clicked on an advertisement and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.
If you do not wish to take part in conversion tracking, you may deactivate the conversion cookie in the settings of your browser. More information on this can be obtained from the Google Data Protection Statement. You may also adjust your settings for Google Advertising in the Google settings for advertising.
All personal data you provide to us is secured on our Website or stored on our secure servers with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorized access or disclosure, accidental loss, alteration or destruction. In addition, we will adopt contractual or other means to prevent any personal data transferred to our data processor (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use, if we are to engage any data processor. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Use of Personal Data Collected
By using our Website and/or providing personal data to it, you agree that your personal data provided by you may be used and retained by us (in electronic form and/or hard copy form or in any appropriate manner) for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time:
– providing information about the Company and our products and/or services to you;
– processing your order for purchase, including verifying your payment details or status;
- processing your registration for any newsletters, marketing and promotional activities or membership;
- processing your registration for product warranty;
- processing your registration as a registered user of our Website;
- processing your redemption of souvenirs;
- processing your registration for servicing of your products;
- providing you with our products and/or services;
- providing you with regular communications from us with details of our products, services and relevant benefits;
- carrying out promotional campaign which you have entered;
- carrying out data sorting and analysis to enable us to better understand your preference and buying behaviour and to provide products and services better tailored to your needs, and to assist us in selecting products and services that are likely to be of interest to you;
- processing any enquiries arising out of or in connection with the Company, products and/or services;
- investigation of complaints and suspicious transactions;
- prevention or detection of crimes;
- disclosure as required by law;
- processing your job application;
– other related purposes for which you have otherwise made it available to us;
– if you have provided your consent for the use of your data for marketing purposes, we will contact you by electronic means (e-mail, SMS, other media whether now known or available in the future) and/or by direct mail with information about goods and services like those which were the subject of such consent; and
– if you have provided your consent, to permit selected third parties to use your data, to contact you by electronic means and/or by direct mail.
We will not use your personal data to provide marketing materials to you unless we have your prior consent.
The Company may not so collect, process, retain or in any manner use your personal data unless we have received your consent to the above intended use. If you no longer wish us to use your personal data for the above intended purposes, you may at any time inform us by sending your request in writing through email to the Legal Department (email@example.com), or by post to Techtronic Industries Company Limited, 29/F, Tower 2, Kowloon Commerce Centre, 51 Kwai Cheong Road, Kwai Chung, Hong Kong.
Retention/Accuracy of the Information
We retain records of your dealings with us for the above purposes. Our general policy is to retain your personal data no longer than is necessary for the fulfillment of the purposes mentioned above unless a longer retention period is required or permitted by applicable law.
We will take reasonable steps to ensure the accuracy of your personal data held by us. If we note that the personal data is inaccurate, we will not use such data and will notify any third party to which your personal data has been transferred regarding the same.
Sharing and Disclosure of Information
By using our Website and/or providing personal data to it, you agree that we may disclose or transfer (whether in Hong Kong or abroad) to third-parties if legally required or if we instruct third parties to process your data under our authority, but this will be done following strict adherence to applicable laws and regulations. These third parties may include, if applicable, (i) any agent, contractor or other third party service provider who provides data processing, telecommunications, collection, credit reference, security, credit, banking, financial, or other professional services, to us; (ii) any company within TTI Group; (iii) any of our actual or proposed assignees or transferees of our rights (whether in Hong Kong or abroad); and/or (iv) any person or entity to whom we are under an obligation to make disclosure under the requirements of any laws, rules, regulations, codes of practice or guidelines issued by any regulatory or other authorities, for any or all of the purposes mentioned above. TTI Group means Techtronic Industries Company Limited, its subsidiaries and affiliates in Hong Kong or abroad.
In this regard your data may also be processed by staff which might be operating outside the European Economic Area who work for us, our affiliates or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. The transferee(s) may not be in places where data protection laws are substantially similar to that of Hong Kong. This means your personal data may not be protected to the same or similar level in Hong Kong.
The Company may not so transfer your personal data unless we have received your consent to the above intended transfer.
Access to and Correction of Information
As a data subject, you have the right to assert the rights of the data subject vis-à-vis us at any time. In particular, you and/or your legal guardian (if applicable) have the right to:
1. obtain information whether and if applicable to which extent we process personal data concerning you or not;
2. access information, in particular, the following information: stored data concerning you, purpose(s) of the processing, categories of data, recipients to whom we disclose data or duration of the storage in the case of processing of personal data concerning you ;
3. require us to correct any personal data without undue delay which is inaccurate or incomplete; and
4. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;
5. require us to delete or cease the collection, processing or use of your personal data without undue delay;
6. withdraw your consent given vis-à-vis us concerning the processing of your data at any time;
7. let the processing of your personal data be restricted; and
8. receive the personal data concerning you which you had provided to us in a structured, standard and machine-readable format, and to transmit these data to another controller
Legal Officer Phone number : (852) 2402 6888 Fax number: (852) 2413 5971 E-mail address : firstname.lastname@example.org 29/F, Tower 2 Kowloon Commerce Centre 51 Kwai Cheong Road Kwai Chung, New Territories, Hong Kong
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Effective date of this Privacy Statement – 03/06/2020