Privacy and Data Protection
Indoguna Lordly Co. Ltd. (the “Company”) provides services and information and sells products through different channels, as well as to provide different services through online channels for different people including members, business partners, shareholders and other people in which the Company, as the website owner of www.indoguna-hongkong.com including other applications and online services of the Company (collective referred to as the “Website”). We are aware of the importance of your personal information and we respect all of your privacy rights as our service recipient.
Personal information that the Company collects
The Company will collect the following personal information:
- Identifiable information such as name, surname, birthdate, identification card number;
- Contact information such as address for invoices, address for shipping product, email and phone number;
- Transaction information such as payment details, bank account, required information for issuing tax invoice, product details and other services that you bought from the Company, including the information of accessing our Website and other services;
- Technical information such as username, password, interests, setting preferences, IP address, login information, browser type, browser version, time and date setting, connection setting, operation and platform system and other technology that you have used your devices to sign in into our system;
- Marketing and communication information such as marketing services’ satisfactions and communication channels, other survey information, opinion, and suggestion;
- Other information such as captured image or footage, voice record when you have contacted with the Company; and
- Sensitive data such as health information, criminal record, religion and blood type.
Methods that the Company uses to collect your personal information
Your personal information that our Company directly collects will include when:
- You register your personal information for membership registration in order to receive services from the Company;
- You login into our Website or the products that you have ordered through our Website or other online channels;
- When you enter into commercial transactions and make payments. This includes the use of membership card;
- When you request for document relating to tax such as tax invoice;
- You contact the Company, our representatives or our business partners through offline channels;
- You subscribe to our advertisement or our marketing news, participate in any competition, receive discounts, or answer surveys;
- You have participated indifferent events of the Company such as taking photos when receiving prizes or where you participated in other PR events;
- When you contact the Company, our customer service via both online and offline channels; and/or
- Other cases according to security protection system of the Company such as CCTV.
The Company will collect your personal information only if you have consented to us or as permitted by laws. For those who are our existing customers before The Personal Data (Privacy) Ordinance (the "PDPO") comes into force, we will continue processing your personal information for the original purposes, which you allowed us to collect your information. If you wish to withdraw your consent or no longer wish the Company to continue collecting or processing your personal information, you may file a form available at the Company’s office, or send an e-mail to email@example.com or contact the Call Center at (852) 2730 2025, Monday-Friday between 09.00-17.00 hours.
If necessary, the Company may collect your sensitive personal information such as health information, criminal record, religion, blood type, etc. only with your explicit consent or when permitted by laws.
Purposes of collection, use or disclosure of personal information
Any collection of your personal information by relevant employees of the Company or other relevant persons or any actions performed on behalf of the Company which is necessary for providing services and management of our Website, including the use of personal information for any undertakings may rely on (1) consent basis (2) contract (i.e. performance of a contract or taking steps at your request before entering into a contract) (3) legal obligation basis and (4) legitimate interest basis by which the purposes of collection, use or disclosure of personal information will be as follows:
- To proceed your request for membership registration, to execute your orders or provide services via Website and other channels when you enter into commercial transactions and make payments, which includes the use of membership card such as payment for products, making refund, product delivery, using your membership card for entering into any transaction with the Company, and prize delivery, etc. This includes checking and managing the financial transactions initiated by you for the product payment.
- To manage and improve the service quality in orderto provide an appropriate and satisfiable services.
- To conduct marketing, including to inform you about information and offers regarding the Company’s products, services, discounts and other benefits via the Company’s communication channels including SMS, E-mail, post, LINE application and other electronic and online channels, and to assess your purchasing behaviour and service usage as well as your preferences and interests to develop sales and services specifically for you and to offer products, services and benefits which suit your needs.
- To interview you, including taking photos and recording videos, and publish such interview, photos and/or video recordings on social media and other online platforms for the purpose of promoting and advertising the Company.
- To conduct business planning, reporting and forecasting.
- To perform internal administration, including to verify the Company’s internal IT system.
- To proceed the request relating to tax such asissuing tax invoices, tourist tax refund.
- To use information for preventing any misconduct or fraud, and for complying with the law, including using information for monitoring and investigating the misconduct, fraud and for security measures.
- To monitor security in our buildings or premises including to protect your security via CCTV system.
- To investigate and prepare an incident report in the case where there is any incident occurred.
- To comply with laws, regulations, orders, legal requirements and obligations of the Company, or to report or disclose information to government authorities as required by laws or upon receiving an order or a writ of attachment from police officers, government authorities, courts, or other competent authorities, to undertake detection and investigation under legal procedures and other regulations including to establish, comply or exercise the rights to legal claims or defend against the rights to legal claims.
- To assign rights, obligations and any benefits under a contract between you and the Company, for example, merger or transfer of the contract which has been done legally.
In the case where the personal information collected by the Company as stated above is necessary for the Company’s compliance with applicable laws or performance of contract, if you do not provide us with such necessary personal information, the Company may be subject to legal liabilities; and/or may not be able to provide you with our products and services; and/or may not be able to manage or administer the contract or give any convenience for you.
Disclosure of personal information
- Agencies, contractors/sub-contractors and/or service providers for their implementation and procedures, for example, carriers, food ordering and delivery service providers, document storage and destruction service providers, printing house, marketing agency, IT development and maintenance service providers, auditors, lawyers, tax and legal advisors, and any consultants;
- Government authorities, supervisory authorities or other authorities as stipulated by laws, including competent officials;
- Our business partners or other third parties as per your consent or relevant contractual requirements or legal requirements, as the case may be.
- The assignee of the rights, duties, and any benefits from the Company, including any persons who are assigned by the aforesaid assignee to act on its behalf, for example, in the case of organizational restructuring, merger or acquisition, etc.
Sending or transfer of personal information within the country
Sending or transfer of personal information to overseas
Retention period of personal information
You are entitled to the following rights under the PDPA:
Data Subject’s Rights
Right of access
You have a right to get access and obtain a copy of your personal information that we hold about you, or you may ask us to disclose the sources of where we obtained your information that you haven’t given consent. The Company will send such copy to you within 30 days upon obtaining your request. In certain cases, the Company may request additional information in order to confirm your identity and your rights as part of our security measures.
Right to data portability
You have a right to request us to transfer your personal information to other persons/organizations, or request to see the personal information that we have transferred to other persons/organizations, unless it is impossible due to technical circumstances.
Right to object the processing of your information
You have a right to object to the processing of your personal information at anytime, for example:
1) It is for the purpose of direct marketing; and/or
2) It is for the purpose of scientific, historical or statistical research unless it is necessary to performance of a task carried out for reasons of public interest by the data controller.
Right of access
You have a right to request us to delete, destroy or anonymise your personal information in the following circumstances where:
1) The personal information is no longer necessary for the purpose of which it was collected, used or disclosed;
2) You have withdrawn your consent to which the collection, use or disclosure is based on;
3) You have objected to the collection, use or disclosure of the personal information and the Company has no ground to reject such request; and/or
4) When the personal information has been unlawfully collected, used or disclosed under the PDPA.
Right to restrict the processing of your information
You have a right to request us to restrict the processing of your personal information in the following circumstances when:
1) It is under the pending examination process of checking whether the personal information is accurate, up-to-date and complete or not;
2) It is the personal information that should be deleted or destroyed as it does not comply with the law and you request to restrict it instead;
3) The personal information is no longer necessary to retain for the purpose of which it was collected, used or disclosed, but you still have the necessity to request the retention for the purposes of the establishment, compliance, exercise of legal claims or the defense of legal claims;
4) The Company is pending verification in order to reject the objection request of the collection, used or disclosure of personal information.
Right to withdraw consent
You may withdraw your consent at any time, unless it is restricted by law, or the contract which gives benefits to you. However, the withdrawal of consent shall not affect the processing of personal information you have already given consent legally.
Right to rectification
You have a right to rectify inaccurate personal information in order to make it accurate, up-to-date, complete and not misleading. If the Company rejects your request, the Company will record such rejection with reasons.
Right to lodge a complaint
You will have the right to make a complaint in the case of where the Company, the data processor including the employees and contractors of the Company do not comply with the PDPO or other announcements of the PDPO.
If you have any questions or would like to exercise any rights relating to your personal information, please contact us by filling in the form available at the Company office, or contact by email to firstname.lastname@example.org, or you can contact us at our Call Center at (852) 2730 2025, Monday-Friday between 09.00-17.00 hours, In case of a request for copy of your personal information, the Company will send such copy to you within  working days upon obtaining your request. In certain cases, the Company may request additional information in order to confirm your identity and your rights as part of our security measures.
Updating your personal information
In the event that the personal information you have provided has changed, you must notify the Company of such update or edit the provided personal information so that your personal information is always accurate and up-to-date. If any of your personal information is incorrect, it may affect the service provision of the Company and the Company will not be responsible for any loss or damage that may occur to you or the third party as a result of your failure to correct or update your personal information to be accurate in anyway.
Security measures of your personal information
The Company will send information about products or marketing information to you from time to time if you have expressed your intention to the subscription to receive the information via our newsletters, telephone, email, or other communication channels. However, you can change the way you receive information, or cancel such subscription at any time by using the same method as to when you subscribed to receive such information from the Company or you may send an email to email@example.com or Call at 023901 369
Redirecting to other parties’ websites
The Company’s Website may be redirected to other websites for the purpose of facilitating you when you visit other websites. These websites may collect your personal information and the Company will not be involved or responsible for the collection and use of your personal information or the disclosure of your personal information to other websites of other parties, or privacy notice of these websites in any way. For this reason, the Company recommends that you carefully review the privacy notice of these websites before you use the service on those websites.
Information that is the right or property of the Company
The information that appears on online services and Websites of the Company is only for informational purposes only, where all of the information, including text and images that appear on all types of online media, is protected by copyright and other relevant intellectual property laws. Due to this, no one may distribute, reference, copy, reproduce or modify any part of the information, by any means, without obtaining prior written consent from the Company.
In addition, illustrations, photographs, drawings from computers and any other information that appears on online media and Websites will be considered as the Company's property and the Company’s right that has been legally authorised by the copyright owner. The use of such images or information must obtain prior written consent from the Company.
If you have any comments, suggestions, questions or want to make a complaint regarding your personal information, please contact the DPO of the Company by sending an email to firstname.lastname@example.org
In addition, you can contact the Company via our Call Center at 023 901 369 Monday-Friday between 09.00-17.00 hours or through or at our head office Unit B, 7/F, Sing Mei Industrial Building, 29-37 Kwai Wing Road, Kwai Chung, N.T. Hong Kong.