Types of Personal Data Collected
Personal data, or personal information, means anyinformation about an individual from which that person can be identified. Itdoes not include data where the identity has been removed (anonymous data).
For the purpose of carrying on our business, includingregistration and administration of our website and related products andservices (including relevant online services), we may collect, use, store andtransfer different kinds of personal data which we have grouped together asfollows:
· Identity Data includes first name, lastname, username or similar identifier, marital status, title, date of birth andgender.
· Contact Data includes billing address,delivery address, email address and telephone numbers.
· Financial Data includes bank account andpayment card details.
· Transaction Data includes details aboutpayments to and from you and other details of products and services you havepurchased from us.
· Technical Data includes internet protocol(IP) address, your login data, browser type and version, time zone setting andlocation, browser plug-in types and versions, operating system and platform andother technology on the devices you use to access this website.
· Profile Data includes your username andpassword, purchases or orders made by you, your interests, preferences,feedback and survey responses, education and profession; hobbies and leisureactivities; Other related products and services subscribed to; and Family andhousehold demographics.
· Usage Data includes information about howyou use our website, products and services.
· Marketing and Communications Data includesyour preferences in receiving marketing from us and our third parties and yourcommunication preferences.
Where we need to collect personal data by law, or underthe terms of a contract we have with you and you fail to provide that data whenrequested, we may not be able to perform the contract we have or are trying toenter into with you (for example, to provide you with goods or services). Inthis case, we may have to cancel a product or service you have with us but wewill notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about youincluding through:
· Direct interactions. You may give us yourIdentity, Contact and Financial Data by filling in forms or by correspondingwith us by post, phone, email or otherwise. This includes personal data youprovide when you:
o apply for our products or services;
o subscribe to our services or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey;or
o give us some feedback.
· Automated technologies or interactions. Asyou interact with our website, we may automatically collect Technical Dataabout your equipment, browsing actions and patterns. We collect this personaldata by using cookies, server logs and other similar technologies. We may alsoreceive Technical Data about you if you visit other websites employing ourcookies.
· Third parties or publicly availablesources. We may receive personal data about you from various third parties asset out below:
o Technical Data from the following parties:
§ analytics providers such as GoogleAnalytics;
§ advertising networks such as Google AdWords;
§ search information providers such asGoogle, Bing, Yahoo
o Contact, Financial and Transaction Datafrom providers of technical, payment and delivery services.
o Identity and Contact Data from data brokersor aggregators.
o Identity and Contact Data from publiclyavailable sources.
Why we use your data
We have set out below, in a table format, a descriptionof all the ways we plan to use your personal data, and which of the legal baseswe rely on to do so. We have also identified what our legitimate interests arewhere appropriate.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
a. Manage payments, fees and charges
b. Collect and recover money owed to us
e. Marketing and Communication
a. Performance of a contract with you
b. Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
b. Asking you to leave a review or take a survey
d. Marketing and Communication
a. Performance of a contract with you
b. Necessary to comply with a legal obligation
c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
e. Marketing and Communication
a. Performance of a contract with you
b. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing By Us and Third Parties
We want to provide you with choices regarding certainpersonal information uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage andProfile Data to form a view on what we think you may want or need, or what maybe of interest to you. This is how we decide which products, services andoffers may be relevant for you.
You will receive marketing communications from us whereyou have purchased products or services from us as an individual customer or ifyou have requested information from us and, in each case, you have not optedout of receiving that marketing.
You can ask us to stop sending you marketing messages atany time by unsubscribing from each email sent to you as part of a campaign andby making a request to unsubscribe on the “Contact Us” page on our officialwebsite (www.egihk.com).
Retention of Personal Data
We will only retain your personal information for as longas necessary to fulfil the purposes we collected it for, including for thepurposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personaldata, we consider the amount, nature, and sensitivity of the personal data, thepotential risk of harm from unauthorised use or disclosure of your personaldata, the purposes for which we process your personal data and whether we canachieve those purposes through other means, and the applicable legalrequirements.
In some circumstances you can ask us to delete your data:see under Your Data Protection Rights for Further Information.
In some circumstances we may anonymise your personalinformation (so that it can no longer be associated with you) for research orstatistical purposes in which case we may use this information indefinitelywithout further notice to you.
Disclosure of Personal Data
We may share your personal data with the parties set outbelow to enable us to carry out the activities specified in the table above:
· Any subsidiaries, holding companies,associated companies, or affiliates of, or companies controlled by, or undercommon control within the EG;
· Any person or company who is acting for oron behalf of the Company, or jointly with the Company, such as our serviceproviders including hosting providers, advertising and email service provider;
· Any party as ordered by court or competentauthority. For example, if we were served with a court order demanding certaincustomer information then we would need to disclose the information to the dulyappointed officer of the court or such other persons as the court orders.
We require all third parties to respect the security ofyour personal information and to treat it in accordance with the law. We do notallow our third-party service providers to use your personal data for their ownpurposes and only permit them to process your personal information forspecified purposes and in accordance with our instructions.
Security of Personal Data
We have put in place appropriate security measures toprevent your personal data from being accidentally lost, used or accessed in anunauthorised way, altered or disclosed. In addition, we limit access to your personaldata to those employees, agents, contractors and other third parties who have abusiness need to know. They will only process your personal data on ourinstructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with anysuspected personal data breach and will notify you and any applicable regulatorof a breach where we are legally required to do so.
Your data protection rights
Under certain circumstances, you have rights under dataprotection laws in relation to your personal information. This may include thefollowing rights:
· Request access to your personal information(commonly known as a "data subject access request"). This enables youto receive a copy of the personal information we hold about you and to checkthat we are lawfully processing it.
· Request correction of the personalinformation that we hold about you. This enables you to have any incomplete orinaccurate information we hold about you corrected.
· Request erasure of your personalinformation. This enables you to ask us to delete or remove personalinformation where there is no good reason for us continuing to process it. Youalso have the right to ask us to delete or remove your personal informationwhere you have exercised your right to object to processing (see below).
· Object to processing of your personalinformation. This right applies where we are relying on our legitimateinterests (or those of a third party) and there is something about yourparticular situation which makes you want to object to processing on thisground. You also have the right to object where we are processing your personalinformation for direct marketing purposes.
· Request the restriction of processing ofyour personal information. This enables you to ask us to suspend the processingof personal information about you, for example if you want us to establish itsaccuracy or the reason for processing it.
· Request the transfer of your personalinformation to another party (known as the “right to data portability”).
· Withdraw consent. This right applies onlyif we are relying on your consent to process any of your personal information.This will not affect the lawfulness of any processing carried out before youwithdraw your consent.
If you wish to exercise any of the rights set out above,please contact email@example.com
You will not have to pay a fee to access your personalinformation (or to exercise any of the other rights). However, we may charge areasonable fee if your request is clearly unfounded, repetitive or excessive.Alternatively, we may refuse to comply with your request in thesecircumstances.
We may need to request specific information from you tohelp us confirm your identity and ensure your right to access your personalinformation (or to exercise any of your other rights). This is a securitymeasure to ensure that personal information is not disclosed to any person whohas no right to receive it. We may also contact you to ask you for furtherinformation in relation to your request to speed up our response.
This Policy was written in English. To the extent atranslated version conflicts with this Policy, the English version will takepriority.
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