This policy is applicable to https://www.emphasis.com ("Site") only. The data controller (i.e. an entity which determines the purposes and means of processing of your personal data) or data user (i.e. an entity which controls the collection, holding, processing or use of your personal data) of the Site is Chow Sang Sang Jewellery Company Limited ("we", "us" or "the Company").
We hope the following policy will help you understand how we collect, use and safeguard your personal data.
This policy is prepared with reference to the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong) (the "Ordinance") and the General Data Protection Regulation (EU) 2016/679 ("GDPR"). Throughout this policy, the meanings of the terms "personal data" and "direct marketing" are the same as defined in the Ordinance unless otherwise specified. To the extent that the GDPR is applicable, references to "personal data" shall also include personal data as defined in the GDPR.
Updates to this policy will be posted on this page.
1. How We Collect and Use Personal Data
1. The Company collects your personal data to ensure we can fulfil our service promises and offer you a personal experience online on the Site.
2. Different levels of personal data may be gathered depending on your usage of our services:
- You need to input your personal data to register in order for us to process some features and services that we offer to our registered users, such as email updates or requesting information from customer service. We may store some of the data provided for these features and services for such purpose. You have the right to refuse to provide your personal data to us. However, certain services and functions may not be available to you if you do not supply us with data on mandatory field(s) on the data collection form.
- You can place an order with us to purchase our products as a registered user on the Site. We will only collect information necessary to fulfil the relevant order (such as your name, contact details and payment information).
- You may from time to time provide us with your personal data at the Site. For instance, you may be required to provide us with your personal data when you apply to be a member of "MEMBER", purchase from us or make enquiries at the Site, use our concierge services, provide feedback to us (such as via a survey) or participate in our promotions and events. The data we collect may include your name, gender, date of birth, address, mobile phone number, email address and password.
- You can also log into the Site using sign in services that bridge your social media log in information with the Site. These services will authenticate your identity and provide you with the option to share certain personal data with us such as your name and email address to pre-populate the sign up form for the Site. These services give you the option to post information about your activities on the Site to your profile page to share with others within your personal network.
3. We may process and use your personal data for the following purposes and, where you are a data subject in the European Economic Area ("EEA"), on the following legal bases under the GDPR:
|Purposes of processing||Legal bases for processing|
|(a)||Operating and administering our customer loyalty programmes and facilitating your participation therein||
|(b)||Providing goods and/or services you ordered or requested||
|(c)||Sending you promotions as well as marketing and advertising materials||
|(d)||Sharing your personal data with other members of the Group (i.e. Chow Sang Sang Holdings International Limited and its subsidiaries) for their use in marketing purposes||
|(e)||Providing features at your request such as sharing a product with a friend, making a store appointment, maintaining your wish list, maintaining your shopping bag on the Site||
|(f)||Analysing trends and behaviour as well as conducting surveys||
|(g)||Verifying your payments||
|(h)||Sending you information about any administrative changes, updates and/or amendments to our policies, terms and conditions||
|(i)||Responding to or following up on your queries, requests and/or complaints, providing customer service||
|(j)||Protecting and enforcing our contractual and legal rights and obligations||
|(k)||Meeting the requirements to make disclosure under the requirements of any law, regulation or court order binding on us||
4. The legal bases for our processing and use of your personal data set out in paragraph 1.3 above are further elaborated as follows:
- Consent: where you have consented to our use of your personal data. You may withdraw your consent to the use of your personal data by contacting us;
- Contract performance: where processing of your personal data is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract with us;
- Legal obligation: where we need to use your personal data to comply with our legal obligations;
- Legitimate interests: where our use of your personal data is necessary for our legitimate interests. We will only rely on this basis if we consider that such legitimate interests are not overridden by any interests or fundamental rights and freedoms that you may have, or any prejudice that you may suffer, from the relevant use of your personal data; and
- Legal claims: where your personal data is necessary for us to establish, exercise or defend any legal claims.
2. Third parties
1. This policy applies to the Site, but not to websites, online services or mobile applications maintained by other companies or organizations, websites, online services or mobile applications to which we may link nor third parties with which we engage in joint promotions.
2. If you follow a link on the Site to any third party websites, online services or mobile applications or submit personal data to third parties via the Site or any third party websites, online services or mobile applications, please check and read the personal information collection statements of such third parties before submitting your personal data. Note that we do not accept any responsibility or liability for such statements or the acts or omissions of such third parties.
3. Security and Protection of Your Personal Data
1. Access to your personal data collected by us is protected by physical, electronic and managerial measures and we therefore limit the access to your personal data to our employees and agents who need it to do their jobs.
2. To protect your personal data when you use the Site, we will encrypt any personal data you transmit to us using Secure Socket Layer (SSL) — an industry standard for encryption over the Internet to protect the data you send us.
3. We will never ask you for your personal password either in writing or on the phone. Please take reasonable care in protecting the access to your password, computer and mobile device from any unauthorized use.
1. We intend to provide services on the Site only to persons aged 18 or above. If you are under the age of 18, please do not use this Site and do not provide us with your personal data.
5. Disclosure of Your Personal Data
1. Your personal data held by the Company will be kept confidential but we may disclose or transfer your personal data to the following parties, where such disclosure or transfer is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected:
- Any subsidiaries of the Company, or affiliates of, or companies controlled by, or under common control with, the Company;
- Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided by you; and
- Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such data confidential, provided such person or company has a legitimate right to such data.
2. Your personal data may also be disclosed by us to any person or persons pursuant to any legal obligations or as required by court of law. In addition, your personal data may be disclosed by us under any of the exemptions described in Part VIII of the Ordinance or (if the GDPR is applicable) as permitted by the GDPR.
3. The persons to whom we disclose or transfer your personal data may be located in Hong Kong, Macau, Taiwan, Mainland China or other jurisdictions. Such jurisdictions may offer lesser protection of personal data than that provided in your jurisdiction. Such transfer, if subject to the GDPR, would be made with appropriate or suitable safeguards (the details of which can be obtained from our Data Protection Officer) or with your explicit consent. Such transfer may present possible risks for you due to the lack of an adequacy decision or appropriate safeguards.
4. For the avoidance of doubt, we will not transfer, disclose or provide your personal data to any third party for direct marketing purpose save and except in accordance with paragraph 6.2 below.
6. Direct Marketing
1. We intend to use your personal data provided to us for direct marketing purpose. We may not use your personal data for such purpose unless we have received your consent to such use. In this connection, please note that:
1. Your name, salutation, email address, phone number, city of residence, address, postal code, date of birth, language preference, transaction pattern and behaviour and demographic data held by us from time to time may be used by us in direct marketing.
2. The following classes of goods and services may be marketed by us using your personal data:
- Jewellery products, watches and accessories;
- Customer services in relation to (a) above;
- Social networking services;
- Customer reward, loyalty or privilege programs, (including "MEMBER") and related services, products and facilities;
- Dining services, food and beverages, sporting equipment, music, films, television and other entertainment, clothing and accessories, luggage and bags, beauty products and cosmetics, personal health and hygiene products, beauty and health services, computers, computer software and mobile applications, toys, household goods, printed matters including books, newspapers and magazines, electronics, home furnishings, housewares, flowers and plants, automobiles, transport and travel services, holiday and leisure services, advertising services, professional services, concerts, sporting and special events, hotel and accommodation services, payment services and instruments;
- Online shopping services relating to the matters above; and
- Promotional/social events relating to the above matters.
2. We also intend to provide your personal data to other members of the Group for their use in direct marketing. We may not do so unless we have received your written consent to such intended provision. In this connection, please note that:
1. All kinds of personal data described in paragraph 6.1.1 above may be provided by us to other members of the Group for their use in direct marketing.
2. Other members of the Group may use your personal data to market the goods and services as described in paragraph 6.1.2 above.
3. We will use your personal data in direct marketing, and provide your personal data to other members of the Group for their use in direct marketing, only in accordance with the Ordinance and (if applicable) the GDPR and, in all cases, subject to your consent.
4. If you do not wish us to use your personal data in direct marketing, you may exercise your opt out right (upon which we must cease to use your personal data in direct marketing) at any time via email or phone or login to your member account at https://www.emphasis.com to change your preference. Similarly, if you do not wish us to provide your personal data to other members of the Group for their use in direct marketing, you may exercise your opt out right (upon which we must cease to so provide your personal data and to notify the Group members to whom the data has been so provided to cease to use the data in direct marketing) at any time via email or phone. You would not be subject to any charges from us when you exercise your opt out right. Our relevant email and phone for such purpose can be found in paragraph 10.3.1 below.
7. Our Corporate Policy
1. The Company will endeavour to fully comply with the obligations and requirements of the Ordinance and (if applicable) the GDPR. Our officers, management and staff members will, at all times, respect the confidentiality of and endeavour to keep safe any and all personal data collected and / or stored and / or transmitted and / or used for, or on behalf of, the Company.
2. The Company will endeavour to ensure all its collection, storage, transmission and other handling of usage of personal data will be done in accordance with the Ordinance and (if applicable) the GDPR.
9. Automated decision making
In connection with our business, we will use your personal data to make various decisions about you and your eligibility to access our services, to determine what marketing offers are most likely to be of interest, to ensure security of our systems, to detect fraud or to profile you or assign you to a particular segment. Some of these decisions may be taken on an automated basis including by matching your personal data against other information in our possession or against data models created for us. If you are assigned to a segment, we may use the segment information to tailor our marketing communications (if permitted under applicable laws) to include offers and content that are more relevant to you. You will not be subject to automated decisions that produce legal effects concerning you or similarly significantly affect you, unless we have a lawful basis for doing so.
10. Your rights
1. Under the Ordinance, you have the right to:
- check whether we hold data about you;
- request access to such data; and
- request correction of such data.
2. Where you are a data subject in the EEA, in certain circumstances you have the right under the GDPR to:
- access and rectify your personal data;
- request us to erase your personal data without undue delay;
- restrict how we process your personal data;
- where our processing of your personal data is based on consent, withdraw your consent at any time;
- object to our processing of your personal data on the basis of legitimate interests, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
- object to direct marketing (including any profiling for such purposes) at any time;
- receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such data to another data controller without hindrance from us; and
- lodge a complaint with a supervisory authority.
3. You may make the above requests by:
Cheung Sha Wan, Kowloon, Hong Kong
Tel: (852) 2192 3228
2. Using the online account you established on the Site; or
3. Completing and submitting our relevant prescribed form at one of our stores.
4. In accordance with the Ordinance, we have the right to charge a reasonable fee for processing any data access request.
5. Where you are a data subject in the EEA, we will not charge a fee when we deal with your requests to exercise the rights described under paragraph 10.2 (a) to (g) above.
6. Please contact our Data Protection Officer in accordance with paragraph 10.3.1 if you have any questions in connection with our data processing practices.
11. Data retention
Your personal data will be processed and stored by us only for a period necessary for the purposes for which the information is collected. Generally, if you are a member of our customer loyalty programme(s), we will keep your personal data as long as you remain a member thereof, although we may keep it longer in order to response to any questions, claims or complaints or to comply with legal, accounting or regulatory requirements. When we no longer need to use your information for those purposes, we will remove it from our systems and records.
We reserve the right to amend this policy at any time and will place any such amendments on this page. To the extent permitted by the Ordinance and (if applicable) the GDPR, this policy is not intended to, nor does it, create any obligations on the Company. Nothing in this policy shall limit the rights of data subjects under the Ordinance or (if applicable) the GDPR.