1. Our Commitment

We are committed to protecting your privacy. We value the trust that you place in us by providing to us your personal data and we are committed to taking all reasonable precautions to protect your personal data from misuse and keeping it secure by complying with all applicable data protection laws and regulations in Hong Kong, as amended from time to time. We regularly review this Privacy Policy and may revise it from time to time. Please read on for more details on how we collect, use, transfer and retain your personal data.

2. Provision of Your Personal Data

We may obtain personal information about you in a number of ways, such as:
(a) when you shop at our online or physical stores;
(b) when you participate in our events or promotions;
(c) when you apply for or use our VIP card and teens card or participate in any of our loyalty or promotion programs;
(d) when you register an account with us;
(e) when you participate in any surveys or marketing campaigns;
(f) when you login to visit our websites, use our mobile applications or view any of our social media pages;
(g) when you use the wifi service at our stores or events;
(h) when you contact us whether in person, by phone, by email or via any social media platforms, to make enquires or provide information;
(i) when verifying your identity;
(j) when you subscribe to our marketing or promotional materials.You are not required to provide the personal information that we request, but we may not be able to provide you with our products, services or benefits or you may not
be able to login to our platforms or use certain features without such information.

3. The Types of Personal Data We Collect

The types of personal data we collect may include:
(a) your name, telephone number, email address, home, mailing, billing or delivery address, your day and month of birth, your payment and credit card information and other personal data you voluntarily provide to us; and
(b) IP address, real-time geographic location data, browser settings, browsing records and other internet log on information of your computer or mobile device.

4. Purposes of Collection

Your personal data may be used for one or more of the following purposes (“Purposes”):
(a) communicating with you;
(b) verifying your identity and any accounts you have with us;
(c) administering any loyalty or other marketing, promotional or corporate programs that we are involved in, including providing you with the benefits that you are entitled ;
(d) processing your orders for products and services you place with us (such as maintaining your shopping cart, attending to billing, payments, refunds and delivery arrangements);
(e) handling and responding to your inquiries, suggestions or complaints;
(f) conducting customer surveys or organizing events for customers;
(g) providing you with customers service;
(h) conducting analysis to help us better understand our customers and to improve our services and products;
(i) customising the information displayed on our shopping websites/apps and social networking/media platforms to create better customers experience;
(j) designing targeted promotional offers;
(k) conducting advertising activities, including targeted advertising;
(l) with your consent, conducting direct marketing activities;
(m) meeting legal, regulatory or compliance requirements, dealing with enquires from law enforcement or regulatory bodies or for the purpose of obtaining legal advice; and
(n) any other purposes directly related to any of the above purposes.

5. Direct Marketing

We intend to use your personal data for direct marketing which will include the marketing and promotion of all products and services offered by the Sa Sa Group (comprising all companies wholly-owned by Sa Sa International Holdings Limited which are engaged in the sale of cosmetic products). We will not, however, use your personal data for such direct marketing activities without your consent (which includes an indication of no objection). You may opt-out of receiving information in relation to the direct marketing activities by indicating your preference where appropriate or request us to change your preference (without any fees), at any time by contacting our Customer Service Representative as set out below under “Further Information” or the unsubscribe link provided.

6. Information We Collect by Automated Means

We may collect certain information by automated means when you visit any of our mobile or on-line platforms, such as cookies, web beacons and web server logs. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, address of the web page that linked you to our platforms, information on actions taken on our platforms, and dates and times of visits to our platforms. Information collected from these automated means may be used for some of the Purposes.

Cookies are small pieces of information that your web browser stores on your computer or other Internet-connected device when you visit a website. Our cookies identify your browser to us and allow us to recognize you when you return. Most browsers automatically accept cookies. You may choose to disable certain cookies by changing your browser’s settings. But without cookies, you may not be able to use all features and services offered on our websites.

Our web servers may log details and record your information automatically. We may also use web beacons, tags on our web pages, to link web pages to particular web servers and their cookies and to transmit information collected through cookies back to web servers.

7. Websites of Third Parties

This Privacy Policy only applies to us, but not to any other third parties (including any websites maintained by them). When you click on links and/or ad banners that take you to either third parties’ websites or websites of companies associated with us, you will be subject to the privacy policies of those parties. Whilst we support the protections of privacy on the internet, we do not accept responsibility for any actions taken by third parties outside our web domain.

8. Transfer of Personal Data

We may disclose or transfer your personal data to companies within the Sa Sa Group or to any third party service providers or business partners, whether within or outside Hong Kong, as necessary on a need-to-know basis to fulfill any of the Purposes, which include the processing and storing of your personal data. We may also disclose or transfer your personal data to any other party when we believe such disclosure or transfer is required for legal or regulatory reasons or where it is necessary to protect our interests (as permitted by law).

We also reserve the right to transfer your personal information with us in the event we are involved in any merger, acquisition or corporate reorganization. However, we will not transfer your personal data unless the transferee agrees to use your personal information in accordance with this Privacy Policy.

9. Retention of Personal Data

We will retain your personal data for as long as it is necessary to fulfill the Purposes for which the personal data is to be used and delete any of your personal data that we have stored as soon as reasonably practicable, subject to, or where otherwise required by law or permitted by law.

10. Protection of Information

In order to protect your personal data against accidental, unlawful or unauthorized access, we maintain appropriate administrative, technical and physical safeguards to keep your personal data safe. Our security measures include secured servers and restricting access to personal data to personnel who have a need to use the data and who have been trained to handle such data properly and observe confidentiality.

11. Rights of Access and Correction

You have the right to request access to, and the correction of, your personal data held by us about you. If you wish to access or correct your personal data, please contact our Customer Service Representative as set out below under “Further Information”. We will verify your identity before handling your request and a reasonable administrative fee may be charged for complying with such request.

12. Changes to Privacy Policy

We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy on our website (www.eleanor.world). We encourage you to visit frequently to stay informed of our most updated version.

13. Further Information

If you have any questions regarding this Privacy Policy, please contact our Customer Service Representative:
by telephone: 2505 5023 (during business hours: Monday to Friday, 9:00 am to 6:00pm) (Hong Kong is GMT +8);
by e-mail: customer@sasa.com

In case of discrepancies between the English and Chinese versions, the English version shall apply and prevail.

Last update: November 2017

Eleanor, a member of the Sa Sa Group