Respecting and protecting our customers’ privacy and personal data is important to On Pedder Limited and its related companies (including all holding, subsidiary and affiliate companies) (collectively, we or us). This Policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the section What rights do I have?
We collect and process personal data about you when you:
We process personal data for the following purposes:
We may market to you our goods and services, and the goods and services of: (a) our related companies (including our affiliate and subsidiary companies), (b) business partners, and (c) other third party providers. Such marketing communications may be in various forms, including advertisements, special events notifications or newsletters, and delivered via various methods in accordance with the personal data that you provide to us, such as by email, SMS, WeChat messages, smartphone app push notifications, notifications on your social media pages, in –app messaging or postal mail.
Such marketing communications may market or offer products or services (including special events and promotions) in the following categories: Dining, food and beverages, sports, music, film, television and other entertainment, clothing and accessories, jewellery, luggage and bags, cosmetics, personal health and hygiene, electronics, home furnishings, and housewares, automobiles, transport and travel, hotels, financial services, loyalty and reward programs, media services, entertainment services, social networking services, payment services, on-line advertising services, other e-commerce, information and communications and services, concierge services, and other products and services that we think may be relevant to you based on information you provide to us (for instance, via your participation in our surveys).
We have carried out balancing tests for all the data processing we carry out on the basis of our business and legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Policy.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. Specifically, in the case of customers from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) contacting our Privacy Officer at [email protected] or mailing to; Privacy Officer, On Pedder, 22F One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong, or (b) in the case of emails, by clicking the unsubscribe link at the bottom of such emails.
Where permitted by law, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, if you are from EEA you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are from the EEA: If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.)
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at [email protected] or by writing to Privacy Officer, On Pedder, 22/F, One Island South, 2 Heung Yip Road, Wong Chuk Hang, Hong Kong. You may also access, verify or update your personal data by logging into the Site or completing the “Customer Information Renewal Form” at one of our stores.
The data controllers are On Pedder Limited, and its related companies; contact details can be found in the section How do I get in touch with you above.
Where we process registration data, we do this for as long as you are an active user of our Site and it is required for business and legitimate interests or legal requirement [(applicable if you are from the EEA only for 7 years after any business and legitimate interests or legal requirements no longer exist)].
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
(Applicable if you are from the EEA only) Where we process personal data for site security purposes, we retain it for 7 years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for 7 years from your last interaction with us.
We place conspicuous notices in our stores to inform customers we prohibit unauthorised photography, sound and/or video recording for commercial use, private gain, use in press or media, or for promotional purposes in our stores. We reserve the right to remove offenders from our premises.
We permit photography, sound and/or video recording where the images/recordings are solely for personal use and are not published or reproduced in print or electronically for commercial use, private gain, use in press or media, or for promotional purposes.
Permitted photography, sound and/or video recording are subject to the following conditions:
(1) no photographs or video and/or sound footage is taken of staff members or other customers without express permission of the staff member or customer;
(2) flash and tripods are not used without written permission;
(3) customers refrain from taking photographs, and recording sound and/or video footage and/or leave the premises if;
– they are causing concern to any staff member or a nuisance to other customers;
– our staff reasonably believe the customer is causing an obstruction or compromising safety or security in any way;
– our staff reasonably suspect that photography, sound and/or video recording are for commercial use, private gain, use in press or media, or for promotional purposes.
If a customer has queries in relation to the photography policy, he/she may contact the Store Manager.
Policy Statement
This policy outlines the policies and procedures regarding the use of CCTV in our stores undertaken to comply with the requirements of the Personal Data (Privacy) Ordinance (the Ordinance). CCTV is used to procure reasonable security and safety of the monitored area.
In accordance with the Ordinance and relevant guidelines issued by the Office of the Privacy Commissioner for Personal Data (PCPD):
– Data subjects are explicitly informed they are subject to CCTV surveillance by notices reading “CCTV in operation” in areas of surveillance. We places conspicuous notices at the entrance to any monitored area and fixes further notices inside the area.
– Notices are also posted if the CCTV cameras themselves are very discreetly located, or in places where a data subject may not expect to be subject to surveillance.
– CCTV cameras are not installed in places where people have a reason to expect privacy.
Our Privacy Policy reflects the usage of CCTV in our stores and reads:
We employ Closed-Circuit Television (CCTV) in our stores. Store premises are subject to CCTV surveillance and activities are recorded by video camera to procure reasonable security and safety of the monitored area.
Information obtained through CCTV monitoring will be used exclusively for safety, security, and law enforcement purposes. Recorded images will be stored in a secure location with access by authorized staff only and will be securely deleted as soon as practicable once the purpose of collection is fulfilled.
If you wish to contact us in relation to privacy of your personal data, please contact our Privacy Officer at cu[email protected] or mail to: Privacy Officer, On Pedder, 22F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.
General Procedures
(a) The personal data collected is securely deleted from the CCTV as soon as practicable once the purpose of collection is fulfilled. If no incident is reported, the footage will be securely deleted regularly accordingly.
(b) Upon expiry of the applicable retention period, we permanently destroy all personal data: (i) if in hard copy form, by first shredding and then securely disposing of the personal data; and (ii) if in electronic form, by permanently erasing the personal data from our systems. The CCTV footage/images are removed automatically from the system regularly. All authorized users having access to any copy pf the CCTV footage/images delete such copy once the incident being reported is closed or is no long active.
(c) If an incident occurs in the store, CCTV footage is preserved in a secure way until such time as the incident is fully investigated and the matter is closed. Usual deletion policies in relation to CCTV footage are suspended for the relevant footage during that period.
(d) Security measures are in place to prevent unauthorized access to the CCTV system. Recorded images are kept in safe custody, subject to and in accordance with the following measures:
(1) A login account and password for access to and storage of footages is available only to authorized users.
(2) Access to locations where the images recorded by the CCTV cameras are viewed, stored or handled are secured and restricted to authorized users only. The authorized users can only view the CCTV footage only when the incident is reported. Please refer to Appendix 1 for detail.
(3) CCTV footage is not transferred in digital format through email, mobile or any other device other than to the Legal Department or to authorized users provided that the footage is encrypted and then only as strictly necessary for valid reason and subject to and in accordance with this clause and clause II below.
(e) Proper records of the staff members taking charge of and keeping the recorded images are maintained by authorized users.
(f) Transfer and movements of the recorded images are clearly documented and only made in accordance with clause I(d)(3).
(g) The hard disks or any devices storing the recorded images are securely protected from unauthorized access (e.g. an encryption function is used) and only viewed, retrieved or handled upon proper authorization for the intended purpose (e.g. police investigation). Once there is no valid reason to retain the recorded images, they are securely deleted. Safeguards are in place to protect wireless transmission systems from interception should they be used for transmission of data recorded by CCTV.
(a) Personal data is only used for the purposes for which it was collected or a directly related purpose, unless the data subject has given express voluntary consent or when any applicable exemptions under the Ordinance apply.
(b) Disclosure of CCTV records to any third party (e.g. a customer) subject to provisions of the Ordinance is generally prohibited to protect the privacy of personal data.
(c) If we are requested to provide CCTV records to a law enforcement agency e.g. the Police for criminal investigation purposes, we will cooperate only with a written request provided by the relevant law enforcement agency.
III. Misuse or abuse of CCTV system or the recorded images is reported to Natalie Da Gama-Rose, General Counsel of the Group Legal Department (email: [email protected]; Telephone: +852 2118 2280).
Customers Enquiries/Law Enforcement Agencies (Eg Police)
III. We will accept requests from the police or other enforcement agent to view the CCTV footage and/or have a copy of the same upon receipt of formal written application.
