Privacy Statement

PRIVACY STATEMENT / Personal Information Collection Statement

To enable Thinking Technology Limited, its holding company, branches, subsidiaries, representative offices, shop, affiliates, related and associate companies (the “Company”, “we” or “us”) to provide you with the discounts, benefits and promotional offers established in or outside Hong Kong S.A.R. (the “Services”), it is often necessary for the Company to collect your personal data (including name, address, date of birth, credit card number, contact number, e-mail address etc.) (“Data”). The Personal Data (Privacy) Ordinance regulates how the Company collects, holds, processes and uses such data. This Personal Information Collection Statement contains details of how the Company may process and use the Data collected.



PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site or the Company, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Personal Data”.

When we talk about “Personal Information” or "Data" in this Privacy Policy, we are talking both about Device Information and Personal Data.

Data which you submit to the Company website may be transmitted in non-encrypted form over the internet.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Personal Data that we collect generally for the following purpose:


a) providing you with the Services;

b) sending you information about the Services;

c) sending you information (via e-mail, short message service (“sms”), direct mailer or any other appropriate mode of transmission) about other promotions, campaigns, products and services organized or provided by the Company;

d) maintaining records of persons registered with the services;

e) meeting disclosure requirements under any law, or as requested by a government body or regulatory agency or authority having jurisdiction over the Company;

f) processing orders for products purchased; and

g) for our own marketing and promotion purposes.

h) Communicate with you.

i) Screen our orders for potential risk or fraud.


We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with following type of parties to help us use your Personal Information, as described above:

a) agents, contractors, and third party services providers who provide administrative, payment or other services to the Company in connection with the Services;

b) business partners which we use for the purposes of providing the Services;

c) the Company’s marketing partners;

d) government bodies or regulatory agencies or authorities;

e) other persons under a duty of confidentiality to the Company;

f) any actual or proposed assignee of the Company;

g) the Company’s holding companies, branches, subsidiaries, representative offices, shops, affiliates, related and associate companies, wherever situated.

h) third services providers for web analytics service, for examples, we use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by email to enquiry@thinking.com.hk

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada, China and the United States.

Under the Personal Data (Privacy) Ordinance, you (subject to certain exemptions) have the right to request access to and correction of your personal data held by us. Requests for access to or correction of personal data shall be in writing and addressed to: Thinking Technology Limited, Suite 1217, 12/F, Chevalier Commercial Centre, No. 8 Wang Hoi Road, Kowloon Bay, Hong Kong
and the Company reserves its right to charge a reasonable fee for Data access and correction request Provided That the Company shall not be liable for any losses or damages that may be suffered by you arising (whether directly or indirectly) from the Company’s delay or failure in updating the database for any reasons whatsover.

DATA RETENTION

When you place an order through the Site, we will maintain your Personal Data for our records unless and until you ask us to delete this information.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONFLICT OF INTERPRETATION

In case of conflict of interpretation or any inconsistency between the English version and the Chinese version of this Statement, the English version shall prevail.



CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at enquiry@thinking.com.hk or by mail using the details provided below:
Suite 1217, 12/F, Chevalier Commercial Centre, No. 8 Wang Hoi Road, Kowloon Bay, , Hong Kong

June 2012

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