This policy statement provides information on the obligations and policies of Bluebell (Asia) Limited, its subsidiaries, affiliates, and associated companies (the “Company”) under the Hong Kong SAR Personal Data (Privacy) Ordinance – Cap.486 (the “Ordinance”). Although this policy specifically addresses the Company’s obligations in respect of the laws of the Hong Kong SAR, the Company believes the principles embedded in the Ordinance are equal to any in the world in respect of the protections they provide to an individual. As such, the Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations elsewhere. Where the Company’s operations are subject to privacy legislation other than that of Hong Kong SAR, then this policy shall be applied so far as practicable and consistent with such local legislation.

The statement is designed to assist you in understanding how we collect, use and safeguard the personal data you provide to us and to assist you in making informed decisions when using the Bluebell Web site, our products and services. We endeavour to continuously assess our privacy practices in light of new technologies, business practices and our customers’ needs. Our Privacy Statement may therefore be amended from time to time. You should check our Privacy Statement regularly to ensure you are aware of our latest policies.
The Company’s officers, management, and members of staff shall, 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.
Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data.

For the purpose of carrying on the Company’s business, including registration and related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:

·Your name;
·Correspondence address and/or billing address;
·Accounts details, including account numbers, service numbers, or user accounts;
·Payment details, including credit card and banking information;
·Contact details, including contact name and telephone number or email address;
·Information for the verification of identity, including identification type and identification number.

In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalized service, or provision of a product is dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:

·Your age;
·Gender;
·Salary range and employment details;
·Education and Profession;
·Hobbies and leisure activities;
·Other related products and services subscribed to;
·Family and household demographics.

In support of the services offered by the Company, information may be automatically collected relating to those services so we may perform accurate reporting and administration of your accounts.The Company’s web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server’s usage so that we may better meet the demands and expectations of visitors to our sites. This type of data may include, but is not limited to:

·The browser type and version;
·Operating system;
·Domain name

TYPES OF PERSONAL DATA COLLECTED THROUGH THE STAFF TRAINING MOBILE APPLICATION 

For the purpose of carrying on the Company’s staff training, you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy request:

·Your name, user accounts;
·Information for the verification of your staff identity, including identification type and staff identification number and/or staff email address.

Broadly speaking, we use personal data for purposes of administering our business activities, providing customer service and making available other products and services to our customers and prospective customers.The main proposes for which personal data may be used by us are:

·sending information in relation to our products and services, activities, competitions, promotions and events;
·marketing and promotional purposes for us, our vendors and business partners and other selected companies;
·joint marketing schemes with other parties;
·customising the advertising and content you visit so as to streamline your online experience at our site and to provide personalised marketing and promotional information;
·fulfilling any of your orders for products and services, order processing and payment clearing;
·responding to your inquiries;
·membership registration and offering benefits and privileges;
·collecting statistical information, conducting analysis and providing anonymous reporting for internal and external clients;
·conducting surveys relating to our customers, products or services;
·evaluation and further enhancement of our products and services;
·fulfilling any purpose directly related to the above purposes.

We use cookies in order to improve your navigation experience when you visit the website  of Bluebell. Cookies are small pieces of information that your web browser stores on your computer when you visit a website. Our cookies let us personalise your visits to Bluebell Web site and recognise you when you return. Information collected from these cookies may be used for the purposes laid out above in this Privacy Statement.
Most browsers automatically accept cookies. You can disable cookies on your computer by indicating this in the preferences or options menus in your browser. We recommend you do this if you are concerned about receiving cookies.

Please note that the Bluebell Web site contains links to other sites and occasionally allows other sites to be co-branded with the Bluebell Web site. Please remember that when you use a link to go from our Website to another Web site or when you use a co-branded site, our Privacy Statement is no longer in effect. Your browsing and interaction on any other Web site, including Web sites that have a link to the Bluebell Web site, is subject to that Web site’s own rules and policies which may differ from that of the Bluebell Web site.
We are not responsible for the practices employed by websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Website.

Bluebell Web site and mobile application will take reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment accessible only to our authorised employees and contractors. However, we give no warranty against third parties hacking into the data or any unauthorised access to the data by anyone.

You have the right to check whether we hold any of your personal data and, if so, may also request access, update, correct or request a copy of your personal data held by us by e-mailing to: privacy@bluebellgroup.com
The Company will, upon satisfying itself of the authenticity and validity of the access request, make every endeavour to respond to the request within 40 days after receiving the request.

We retain personal data for as long as necessary to fulfil the purpose for which it is being collected. We reserve the right to retain copies indefinitely for our archives for statistical purposes.

All personal data held by the Company will be kept confidential and protected but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:

·our subsidiaries, associated companies or affiliates or other related companies;
·our vendors and business partners;
·parties which assist us in carrying out the purposes laid out above in this Privacy Statement;
·parties which participate in joint marketing scheme with us;
·any agent, contractor or service provider who provides administrative, order processing, payment clearing, credit reference,debt collecting or other services necessary to the operation of our business;
·any other person or organisation who are bound by confidentiality agreements with us; and
·any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law

You should also note that the privacy protection as set out in this Privacy Statement does not apply to personal data which is passed to third parties, and we are not responsible for the protection of your personal data or lack thereof by such third parties.
Except as otherwise provided in this Privacy Statement, personal data about you as an individual subscriber will not be provided to any third party without your consent.
Personal data may also be disclosed to any person or persons that have a right to gain access to such information provided they are able to prove their authority to access such information. For example, if the Company were served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.

By using the Bluebell Web site and/or enrolment in the Bluebell CRM and/or Loyalty Programs, and/or mobile application, you consent to our collection and use of your personal data as described in this Privacy Statement. If we shall change our privacy policies and procedures, they will be posted on the Bluebell Web site and mobile application to keep you aware of the changes and what information we collect, how we use it and under what circumstances we may disclose it.
If anyone wants to unsubscribe emails from us, please click Unsubscription link included in every message

The Company’s Personal Data (Privacy) Contact Details

All enquiries should be in writing to:
Bluebell (Asia) Limited
Privacy Protection
21/F., Dorset House
979 King’s Road
Quarry Bay
Hong Kong

Tel: +852 2968 1188

Or via email to:
privacy@bluebellgroup.com