Broadway's Personal Data (Privacy) Policy & Statement

1. INTRODUCTION

- This Privacy Policy describes the privacy policies and practices of Broadway Photo Supply Limited, a limited liability company duly incorporated in Hong Kong Special Administrative Region (“Hong Kong”) of 28th Floor, King Palace Plaza, 55 King Yip Street, Kwun Tong, Kowloon, Hong Kong and other companies directly or indirectly owned by Broadway Photo Services (Holdings) Limited (collectively, “Broadway”, “Broadway Group”, “we”, “us”, “our”) in relation to the collection, use, retention, disclosure, transfer, security and access of personal information. When you browse or access our website (www.broadwaylifestyle.com/) (“Website”), purchase products through our Website or physical stores or register to be a member of our royalty membership programme (collectively, “Services”), certain of your information will be collected. We have tried our very best to present this Privacy Policy in a manner that is easily understandable and readable. Please review this Privacy Policy carefully before using our Services.

- If you are under the age of 18 or 21 years of age (depending on your jurisdiction), you must review this Privacy Policy with your parent(s) or legal guardian to ensure that they read and agree to this Privacy Policy on your behalf. By accessing our Services, you represent that you are either over 18 years or 21 years of age (depending on your jurisdiction) or otherwise your parent(s) or legal guardian have read and agreed to this Privacy Policy on your behalf. You understand and agree that we are relying upon such representation in providing our Services to you.

- Here at Broadway, protection of your personal information and use of your personal information properly and legally to serve you better are always our top priorities. We respect your rights on your personal information and only collect adequate (but not excessive) personal information from you in relation to lawful purposes directly related to our functions, activities or Services.

- We shall use our best endeavour to protect your personal information and keep your personal information accurate and up-to-date. If we have reasonable grounds for believing that your personal information is inaccurate, we shall either stop using such information or erase such information.

- We aim to be accountable, open and transparent in handling your personal information. We shall honour and update your request for access to, correction of or ceasing the use of your personal information in a professional and timely manner and in accordance with the applicable laws.

- If necessary, we shall update our Privacy Policy from time to time at our sole discretion without any prior notice to you. Any changes or modifications to the Privacy Policy shall become effective when they are published on our Website. Therefore, please visit this Privacy Policy (www.broadwaylifestyle.com/privacy-policy) periodically. Your continued use of this Website and/or our Services and/or provision of your personal information to us constitute your acceptance to our Privacy Policy in force at the relevant time. 

2. PERSONAL INFORMATION COLLECTED BY US

a. In order for us to provide our Services to you, it is necessary for you to provide us with your personal information. Some of them are mandatory, for instance, basic personal information will be required in order to admit you as our member. If you are unable or unwilling to provide us with complete and correct personal information or other information as requested, we may not be able to admit you as our member or provide or continue to provide to you our Services. Information which we require includes:

(i) your name, delivery or shipping address, email address, user name, password, date of birth, contact number and other registration information;

(ii) information about your preferences and interests;

(iii) transaction-related information, such as your order history, credit card information, delivery address, etc;

(iv) information you provide to us voluntarily, such as when you contact us for enquiries or feedback; and

(v) other information related to your use of our offerings on our Services.

b. We, our agents, vendors, consultants and other services providers (“Services Providers”) may automatically receive or collect certain information from you when you access our Services utilising internal analytics technologies or other automatic tracking and analytic technologies (see below). Such information may include information concerning the below without limitation: 

(i) your connection to our Website, including the type of device you are using, browser information, operation system, name of the internet service provider, wireless carrier, internet protocol (IP) address, geographical location, etc.;

(ii) your interaction with our Website, including your browsing time, number of clicks, your clicks to links in our Website, pages viewed, how did you reach our Website, etc.;

(iii) information collected by our or third-parties’ cookies (see below);

(iv) your personal information;

c. Any problems, feedback, suggestions or data, except for personal information, sent by or posted on the Website or any section of the Website by you to the Website are treated as non-confidential and non-proprietary information voluntarily provided to Broadway. You hereby grant Broadway the full and free right to autonomously use, reproduce, edit, disclose, transmit, publish, broadcast and/or post such (part or all of) data in other places, including but not limited to the provision of such data to any associated companies for the purposes of development, production, and promotion of products and Services and to satisfy customer needs. 

3. USE OF INFORMATION

a. All the personal information provided by you to us may be used for all or any of the following purposes:

(i) processing your application for membership;

(ii) providing you with the services under our membership program;

(iii) marketing of goods and/or premiums and/or services by us and/or any member of the Broadway Group;

(iv) providing you with specially selected offers, promotions and benefits by us and/or any member of the Broadway Group;

(v) communication with you on all matters relating to your membership with us;

(vi) management, operation and maintenance of our membership program;

(vii) designing new or improving existing goods and/or premiums and/or Services provided by us and/or any member of Broadway Group;

(viii) processing your orders through our Website or physical stores;

(ix) providing necessary information to you with respect to our products and/or Services;

(x) arranging for delivery, collection or pick-up of products ordered or purchased by you;

(xi) making suggestions to you for other products which we believe you will be interested in;

(xii) responding to and evaluating your enquiries, comments and feedback;

(xiii) understanding how people use our Website and Services;

(xiv) targeting advertisements on Website that are relevant to your interests;

(xv) for direct marketing purposes subject to your separate consent;

(xvi) investigating complaints or suspicious transactions;

(xvii) preventing or detecting criminal activities;

(xviii) any disclosure as required by applicable laws and/or rules;

(xix) performing statistical analysis and/or research for improving our Services and for internal staff training and evaluation purposes;and

(xx) other purposes related or incidental to all or any of the above purposes.

b. For purposes set out in sub-paragraph (a) and subject to Paragraph 4, we may share your information:

(i) with the Services Providers (whether in Hong Kong or aboard) in connection with their work on our behalf;

(ii) with other companies under the Broadway Group;

(iii) to our transferees or assigns in the event of a change of ownership; and

(iv) with other enforcement or governmental bodies to comply with applicable laws or valid court orders.

Services Providers may include but not limited to third party reward, loyalty or privilege programs providers, co-branding or cross-marketing retail partners or charitable or non-profit making organizations, external service providers (which includes but not limited to our agents, contractors, sub-contractors, telecommunication operators, mailing providers, direct sales agents, telemarketing providers, call centres, data processing providers, information technology providers, any other party under a duty of confidentiality to us. Services Providers are under contractual duties to collect, use, store, handle your personal information only in accordance with our instructions and for our purposes but not otherwise

 

4. USE OF PERSONAL INFORMATION IN DIRECT MARKETING

a. We intend to use your personal information for direct marketing purposes. However, we will only do so with your consent.

b. Provided that you consent to our use of your personal information for direct marketing purposes, we intend to use the following personal information for marketing goods and/or Services and/or subjects mentioned in sub-paragraph (d) below:

(i) your name;

(ii) your address;

(iii) your phone number;

(iv) your email address;

(v) your goods and services consumption pattern; and

(vi) other information provided by you in the membership application form (if applicable).

c. In particular, your personal information may be used for marketing the following goods and/or services and/or subjects:

(i) electrical appliances and electronic products and related good, accessories and services;

(ii) telecommunication products and related goods, accessories and services;

(iii) computers and related goods, accessories and services;

(iv) cameras and related goods, accessories and services;

(v) watches and related goods, accessories and services;

(vi) other goods for sale in shops operated by Broadway Group;

(vii) reward, loyalty or privilege programs and related goods and services; or

(viii) donations or contributions for charitable and/or non-profit making purposes.

d. In addition to marketing the above goods, services and subjects by us, we also intend to provide your data mentioned in sub-paragraph (b) above to any member of Broadway Group for use by them in marketing those goods, services and subjects and we may not so provide your personal information unless with your consent .

e. If you do not wish us to use or provide to other persons for use all or any of your personal information in direct marketing for all or any of the goods, services and subjects as described above, you may exercise your opt-out right by writing to us at the address mentioned at the end of this Privacy Policy or by calling our Customer Hotline. Please note that you may give selective consent to (i) the kinds of personal information that we may use; (ii) the classes of marketing subjects; and (iii) the classes of data transferees (however, you acknowledge and understand that we may not provide our Services to you if such data transfer are necessary for us to provide our Services).

5. THIRD-PARTY LINKS

a. The Website may include or contain links to other websites and webpages. Each time you activate any such linked webpage, such as by clicking any links of advertising clients on our Website, you will leave our Website. Any personal information or any other data which you provide to any other organisation after you leave the Website are not within Broadway’s scope of control. Broadway’s Privacy Policy is not applicable to other organisations or websites.

6. YOUR RIGHTS

a. You have the right to:

(i) check whether we hold any of your personal information;

(ii) access your personal information held by us;

((iii) require us to correct any personal information which is inaccurate;

(iv) ascertain our policies and practices (from time to time) in relation to personal information and the type of personal information held by us;

(v) opt-out from allowing us or other parties to use your personal information for direct marketing, please see Paragraph 4 above.

7. PERSONAL INFORMATION SECURITY

a. Broadway will make every reasonable effort to ensure that all personal information held by us is stored in a safe and secure environment and is guarded against unauthorised or accidental access, processing, erasure or other use.

b. Your Information will not be retained by us for longer than is necessary for the purposes for which it was collected.

8. COOKIES AND THIRD-PARTY TRACKING

a. Cookies are text files that your computer or mobile device keeps. Cookies make web-browsing easier for you by saving your preferences so that we can use the saved information to facilitate and improve your use of our Website and Services. For example, cookies keep track of items in the shopping cart so that such items in the cart will not be removed when you are browsing our Website. In particular, Broadway may use cookies in the Website in order to:

(i) strengthen security measures;

(ii) allow visitors to the Website to continue browsing the Website;

(iii) customise the Website according to the needs of individual customers for personalised usage, such as to store user preferences, store and retrieve login information on your computer and personalise contents and offers for your interests;

(iv) build data on information of visitors to the Website.

b. If you do not wish to allow the use of cookies, please make the necessary adjustments to your internet browser settings by disabling cookies on your computer. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, by disabling cookies, you may not be able to use certain features on the Website or our Services and may not receive advertising or other offers from us that are relevant to your interests and needs

c. Third-party services may use their own tracking technologies to collect information about you:

(i) Google Tag Manager (“GTM”) - a tag management system to manage JavaScript and HTML tags used for tracking and analytics on our Website. Tags are small code components that are capable of doing things such as measuring traffic and visitor behaviour, understanding the results of online advertising and social channels and remarketing towards target users, etc. For more information about GTM’s privacy practices can be found at http://www.google.com/intl/de/policies/privacy/.

(ii) Google Marketing Platform – enables us to place ads on our Website and it uses cookies to facilitate behavioural targeting by indicating which areas of our Website you are browsing. You may visit the above link for more information.

(iii) Addthis – a bookmark service provider. Addthis gathers data on the page(s) of our Website that you share. You can permanently prevent AddThis from placing a cookie on your browser by downloading and installing the opt-out cookie available at the following link: http://www.addthis.com/privacy/opt-out. Please however note that you may not be able to use all the functions on our website if you install the opt-out cookie. You may also view the privacy policy of Addthis at http://www.addthis.com/privacy/privacy-policy.

(iv) Facebook pixels – collects data on what you do after you see or click on Facebook advertisement. Facebook can also connect this data with your Facebook account and use it for advertising purposes. You may view Facebook’s Data Policy at https://www.facebook.com/about/privacy/.

(v) Hotjar - Hotjar is a technology service that helps us better understand users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location, and the preferred language used to display our Website. Hotjar stores this information on our behalf in a pseudonymised user profile.

(vi) Queue-it – a waiting room system for controlling network traffics and it uses cookies to provide the queue services. You may visit the privacy policy of Queue-it at https://queue-it.com/privacy-policy-customer/.

(vii) Emarsys - We also use the services of Emarsys to track and gather certain information on this website that helps us to better understand our visitors’ needs related to our Website and/or Services. You can learn about Emarsys’s privacy policy at https://www.emarsys.com/en-hk/privacy-policy.

(viii) New Relic – We use performance tracking cookies to enhance the performance of our Website by gathering data on the number of users accessing our Website. Information on how New Relic collects and processes your data is available here: https://newrelic.com/termsandconditions/applicant-privacy-policy.

d. Broadway maintains its own official pages on various social media platforms and when you visit these pages by clicking the links from our Website. The provider of the social media platforms may track on your browser or device, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operator or provider of the social media platforms links. The inclusion of such links on the Website do not imply endorsement of the linked site or service by us or the Broadway Group.

9. Personal Information Access Request

a. All requests for access to, correction or deletion of personal information, regarding policies and practices and types of personal information held should be in writing and addressed to:

Personal Data Protection Officer
Broadway Photo Supply Limited
28th Floor, King Palace Plaza
55 King Yip Street
Kwun Tong
Kowloon
Hong Kong

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