PRIVACY POLICY
1. INTRODUCTION
1.1. Sir:cular is committed to protecting and respecting your privacy. Our website is located at www.sircular.shop ("Website") and is owned and operated by Sir:cular.
1.2. This Privacy Policy, together with Sir:cular's Terms of Use, sets out the basis on which any personal data Sir:cular collects from you, or that you provide to Sir:cular, will be processed by Sir:cular. You are strongly recommended to carefully read this (i) Privacy Policy, (ii) 's Terms of Use, to obtain an understanding of Sir:cular's policy and practices with regard to the treatment of personal information and data provided by you on the Website. By visiting the Website, you are accepting and consenting to the practices described in this policy. This Privacy Policy is applicable to both registered and non-registered users, and the provisions herein may be updated, revised, varied and/or amended from time to time as Sir:cular deems necessary.
1.3. Sir:cular pledges to fully meet the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong") ("Ordinance"). In doing so, Sir:cular will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via the Website and Sir:cular will not release such information to anyone without the prior consent of the relevant user(s) of the Website (whether registered or not) except to the authorized persons listed under Clause 4 below.
1.4. If you have questions or concerns regarding this Privacy Policy, you should first contact Sir:cular Customer Service Representative at +852 9655 0559 or contact@sircular.shop.
2. PURPOSE OF COLLECTION OF PERSONAL DATA
2.1. In the course of using the Website, you may disclose or be asked to provide personal information and/or data. In order to have the benefit of and to enjoy various services offered by the Website, you will have to provide Sir:cular with your personal information and/or data, as set out in Clause 3 below. Although you are not obliged to provide the information and/or data as requested by the Website, Sir:cular will not be able to render certain services on the Website if you fail to provide the requested information and/or data. Sir:cular collects information and data on the Website for various purposes, including but not limited to the following:
(i) To process your membership application to the Website;
(ii) For the daily operation of the services provided to you;
(iii) To verify your credit, payment and/or status in relation to the Website;
(iv) To enforce your contractual rights in relation to the Website;
(v) To process all of your payment instructions, credit services and/or direct debit services in relation to the Website;
(vi) To process orders placed by you;
(vii) To disclose your address and contact details to third party courier services to deliver the products to you;
(viii) To identify users who have posted materials, messages, photos, views or comments or such other information (collectively the Information) on the Website;
(ix) To identify which users have viewed the Information posted on the Website;
(x) To provide you with marketing and promotional materials for your enjoyment of benefits as a member of the Website (for further details, please refer to Clause 5 below);
(xi) To offer you tailored content including giving you more relevant search results and marketing and promotional materials;
(xii) To identify users who have enjoyed their benefits as members of the Website by receiving and using marketing and promotional materials;
(xiii) To provide you with a platform and forum for posting product requests and photos, and for sharing, buying and selling luxury products;
(xiv) To compile and analyse aggregate statistics about the users use of the Website and service usage by the users for Sir:cular's internal use;
(xv) To facilitate Sir:cular to use your personal data for purposes relating to the provision of services offered by Sir:cular and marketing services, special events and/or promotions of Sir:cular and/or its clients; and
(xvi) To be able to access your account on the Website.
2.2. Sir:cular strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out herein above. If Sir:cular requires the use of your personal data for a purpose other than those set out herein above, Sir:cular may request your consent to the same.
2.3. If you are under the age of 18, you may not form legally binding contracts and as such cannot be a customer of Sir:cular and/or a user of the services offered on the Website. Accordingly, the Website is not designed for persons who are minors and we do not knowingly collect information from minors. If we become aware that we inadvertently received personal information of a visitor who is a minor, we will delete the information from our records.
3. COLLECTION OF PERSONAL DATA
3.1. Sir:cular may ask you for some or all of the personal information and/or data, and non-personal information and/or data (collectively Personal Data) that is not otherwise publicly available, such as:
(i) Name;
(ii) Date of birth;
(iii) Email address;
(iv) Correspondence address;
(v) Credit card or bank account information;
(vi) Payment, billing, or shipping information;
(vii) Telephone number;
(viii) Country of residence;
(ix) Occupation;
(x) Account username; and
(xi) Account password.
B. Non-Personal Information
3.2. Sir:cular does not collect any personally identifiable information from you while you visit and browse the Website, save and except where such information is expressly requested from you. When you access the Website, Sir:cular only records your visits and does not collect your Personal Data. The Website uses cookies to distinguish between users. This helps Sir:cular to improve your experience when you browse the Website and it allows Sir:cular to improve the Website. This includes recording the domain name server address and tracking the pages you visit; Sir:cular stores such information in cookies within your computer. Sir:cular also gathers and stores information, such as internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without you being aware that they are occurring.
3.3. Sir:cular does not link the Personal Data automatically collected in the above manner to any personally identifiable information. Sir:cular generally uses such automatically collected Personal Data to estimate the audience size of the Website, gauge the popularity of various parts of the Website, track your movements and number of entries in Sir:cular's promotional activities and special events, measure your traffic patterns, and administer the Website. Such automatically collected Personal Data will not be disclosed save and except in accordance with Clause 4 below.
3.4. Occasionally, Sir:cular may also collect additional Personal Data from you in connection with surveys and/or special offers. Only duly authorised staff of Sir:cular will be permitted to access your Personal Data, and Sir:cular shall not release such Personal Data to any third parties save and except for the circumstances listed out under Clause 4 below.
4. DISCLOSURE OR TRANSFER OF DATA
4.1. Sir:cular agrees to take all practicable steps to keep all your Personal Data confidential and/or undisclosed, subject to the following.
4.2. Sir:cular will only disclose and/or transfer your Personal Data to Sir:cular's personnel and staff for the purpose of providing services to you, except that Sir:cular may disclose and/or transfer such Personal Data to third parties under the following circumstances:
(i) If Sir:cular sells or buys any business or assets, in which case Sir:cular may disclose the Personal Data;
(ii) If Sir:cular or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be among the transferred assets;
(iii) Where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorised by Sir:cular to use such information and/or data and who will facilitate the services on the Website, under a duty of confidentiality;
(iv) Where the information and/or data is disclosed and/or transferred to any agents, affiliates or associates of Sir:cular who have been duly authorised by Sir:cular to use such information and/or data;
(v) Where Sir:cular needs to protect and defend its rights and property;
(vi) Where Sir:cular needs to disclose to credit reference agencies, debt collection agencies, fraud detection and/or prevention agencies, relevant pubic authority or law enforcement agency;
(vii) Where Sir:cular reasonably believes it to be reasonably necessary to Investigate or prevent fraud or illegal conduct;
(viii)Where Sir:cular considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Website; and
(ix) Where Sir:cular deems necessary in order to maintain and improve the services on the Websites.
4.3. You should take care when using social networking features of the Website since the information you choose to make available can be seen by other users in the selected group. Sir:cular does not monitor the use of such features in the normal course of business although it reserves the right to do so at its discretion.
4.4. Personal Data collected via the Website is transferred, stored and processed in Hong Kong SAR. By using the Website, you are deemed to have agreed to, consented to and authorised Sir:cular to disclose and/or transfer your Personal Data under the circumstances stated above, and to transfer information (including the Information) outside of your country.
5. SUBSCRIPTION TO NEWSLETTER, PROMOTIONAL MATERIALS, AND MARKETING MATERIALS
5.1. Sir:cular may from time to time send to you newsletters, promotional materials and marketing materials based on the Personal Data that you have provided to Sir:cular, if you have consented thereto, or the sending of such materials is permissible under applicable laws and regulations. Sir:cular may use your Personal Data in direct marketing and Sir:cular requires your consent (or an indication of no objection) for that purpose. In this connection, please note that:
(i) Your Personal Data held by Sir:cular from time to time may be used by Sir:cular and/or its authorised personnel or staff in direct marketing;
(ii) The following classes of services, products and subjects may be marketed:
(a) Special events hosted by Sir:cular and/or its affiliates for you;
(b) Products and services offered by Sir:cular and its advertisers (the names of such entities can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); or
(c) Donations and contributions for charitable and/or non-profit making purposes;
(iii) The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by Sir:cular and/or:
(a) Third party service providers providing the products, services and subjects posted in paragraph 4.1(ii)(b) above; and
(b) Charitable or non-profit making organizations.
5.2. Sir:cular has implemented suitable measures to allow its members to "opt-out" of receiving such materials. In this regard, you may, at any time, choose to sign up for or unsubscribe from receipt of such materials by logging into the registration or user account maintenance webpage, or by clicking on the automatic link appearing in each newsletter or message, or by emailing Sir:cular's Customer Service Representative at: contact@sircular.shop. Any such request should clearly state the details of Personal Data in respect of which the request is being made. Please note that after opting-out, you may still receive non-marketing messages, such as product updates and service notices as permitted under applicable local laws and regulations.
6. ACCESS
6.1. Under the Ordinance, every user is entitled to request access to or make amendments to his/her own Personal Data kept with Sir:cular by logging into the registration or user account maintenance webpage, or by emailing 'Sir:cular’s Customer Service Representative at: contact@sircular.shop. Any such request should also clearly state the details of Personal Data in respect of which the request is being made.
6.2. If you are in an EU Member State, you have the right under EU law (subject to certain limitations and/or restrictions):
(i) to request access to and rectification or erasure of your personal data;
(ii) to obtain restriction of processing of your personal data or to object to processing of your personal data;
(iii) to data portability; and
(iv) to lodge a complaint about the processing of your personal data with your local data protection authority.
6.3. You may request access or make amendments to your own Personal Data kept with Sir:cular by logging into the registration or user account maintenance webpage, or by emailing Sir:cular's Customer Service Representative at: contact@sircular.shop. Any such request should also clearly state the details of Personal Data in respect of which the request is being made. In the event that you wish to access or amend your Personal Data, Sir:cular may request you to provide personal details in order to verify and confirm your identity. Sir:cular will use its best endeavours to respond to your requests within 30 days of your request and will endeavour to do so wherever possible.
7. LINKS TO OTHER WEBSITES, MEDIA PLATFORMS, APPLICATIONS
7.1. The Website may provide links to other websites, media platforms, or applications that are not owned or controlled by Sir:cular. Personal Data from you may be collected on these other websites, media platforms, or applications when you visit them and make use of the services provided therein. You are reminded and acknowledge that when and where you decide to click on any advertisement or hyperlink on the Website which grants you access to other websites, media platforms, or applications, the protection of your Personal Data which is deemed to be private and confidential may be exposed in these other websites, media platforms, or applications.
7.2. This Privacy Policy is only applicable to the Website. You are reminded and acknowledge that this Privacy Policy grants no protection over your Personal Data that may be exposed on websites, media platforms, or applications other than the Website, and Sir:cular is not responsible for the privacy practices of such other websites, media platforms, or applications. You are strongly recommended to refer to the privacy policy of such other websites, media platforms, or applications.
8. SECURITY
8.1. The security of your Personal Data is important to Sir:cular. Sir:cular will always strive to ensure that your Personal Data will be protected against unauthorised access. Sir:cular has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure your Personal Data.
8.2. All Personal Data provided by you is only accessible by the authorised personnel of Sir:cular or its authorised third parties, and such personnel are instructed to observe the terms of this Privacy Policy when accessing such Personal Data. You may rest assured that your Personal Data will only be kept for as long as it is necessary to fulfil the purpose for which it is collected. Registered users should safeguard his/her unique Username and Password by keeping it secret and confidential, and should never share these details with anyone.
8.3. Sir:cular uses third party payment gateway service providers to facilitate electronic transactions on the Website. Regarding sensitive information provided by you, such as credit card details for completing any electronic transactions, the web browser and third party payment gateway communicate such information using secure socket layer technology (SSL).
8.4. Sir:cular follows generally accepted industry standards to protect the Personal Data submitted by you to the Website, both during transmission and once Sir:cular receives it. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while Sir:cular strives to protect Personal Data against unauthorised access, Sir:cular does not guarantee its absolute security.
9. RETENTION OF PERSONAL DATA
9.1. Once Sir:cular has obtained your Personal Data, it will be maintained securely in Sir:cular's system. Subject to legal requirements, your Personal Data will be retained by Sir:cular after deactivation of the relevant service until you request Sir:cular in writing to erase your Personal Data from Sir:cular's database or to terminate your membership of the Website.
10. CHANGES IN THIS PRIVACY POLICY
10.1. Sir:cular reserves the right to update, revise, modify or amend this Privacy Policy in the following manner at any time as Sir:cular deems necessary. You are strongly recommended to review this Privacy Policy frequently. If Sir:cular decides to update, revise, modify or amend this Privacy Policy, Sir:cular will post those changes to this webpage and/or other places Sir:cular deems appropriate, so that you will always be in a position to ascertain what information Sir:cular collects, how Sir:cular uses it, and under what circumstances, if any, Sir:cular discloses it.
10.2. If Sir:cular makes material changes to this Privacy Policy, Sir:cular will notify you on this webpage, by email, or by means of a notice on the home page of Sir:cular.