PRIVACY POLICY STATEMENT

We are committed to respecting your privacy. This Privacy Policy Statement is made in accordance with the Personal Data (Privacy) Ordinance Cap 486 and the Personal Data (Privacy) (Amendment) Ordinance of the Laws of Hong Kong (“Ordinance”) and related guidelines issued by the Hong Kong Office of the Privacy Commissioner for Personal Data and sets out our policies and practices with regard to the use, collection, sharing and security of your Personal Data when you use this Website and our Services.

1. What is “Personal Data”?

For this Privacy Policy Statement, the meaning of the term “Personal Data” is defined in the Ordinance.

2. What personal data do we collect and when?

We collect the following Personal Data:
a. when you register to use the Services we collect your Registration Details, like name, contact number, email address, physical address, gender and date of birth;
b. we also collect the Personal Data you may volunteer in response to surveys or questionnaires we may conduct;
c. please refer to paragraph 7 “Cookies” for Personal Data we may collect when you visit our Website.
We collect the above Personal Data when you register for our Services, access our Services, activate the services of our Business Partners and at any time you update your Personal Data.

3. For what purposes do we use your Personal Data?

Your Personal Data is collected for the following purposes: –
a. provision of our Services to you;
b. carrying out your instructions or responding to your enquiries, requests and complaints;
c. forming part of Solvil et Titus’s customer data base necessary for the operations carried on by us;
d. Research and analysis for marketing and promotional purposes;
e. transferring or sharing your Personal Data to/with our Business Partners for the purposes of carrying out (a) to (d) above in this section;
f. to allow our Business Partners or person or body corporate with whom our Business Partners enter into arrangements with to carry out the purposes set out in (a) to (d) above in this section;
g. any purposes related to and/or for the furtherance of (a) to (f) above; and
h. direct marketing purposes carried out in relation to our Stores, at this Website and other online or social media platforms managed by us or our Affiliates.
Without your consent, we shall not use your Personal Data for purposes other than those specified above.

4. Accuracy

We will take all practicable steps to ensure that Personal Data collected is accurate. Please endeavour to provide us with accurate Personal Data when you register and where there are any changes to your Personal Data, please inform us as soon as possible.

5. Personal Data Sharing, Transfer and Disclosure

Your Personal Data may be collected, processed and stored in countries outside of Hong Kong. Where sharing, transfer or disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, we may provide your Personal Data to the following parties:
a. we will transfer or share your Personal Data with our Business Partners;
b. we will transfer and share your Personal Data with our Business Partner Affiliates;
c. Personal Data may also be disclosed to any person or persons pursuant to any statute or as required by any court of law in Hong Kong, provided such person or persons are able to prove the required right/authority to access such information;
d. we will not sell your Personal Data to any person or company; and
e. we will not share, transfer or disclose your Personal Data to/with any person or company (except our Affiliates) for direct marketing purposes.

6. Access and Correction

a. you may check whether we hold any of your Personal Data and, if so, may request access (i) by sending an email to our Data Protection Officer at cs@solvil-et-titus.hk; or (ii) by mailing us at 27th Floor, Stelux House, 698 Prince Edward Road East, San Po Kong, Kowloon, Hong Kong (Attention: Data Protection Officer);
b. corrections (i) by sending an email to our Data Protection Officer at cs@solvil-et-titus.hk; or (ii) by calling our hotline at (852) 2113 2266. We may record your conversation with us for good record keeping purposes.
We will take reasonable steps to verify your identity before granting access or permitting corrections to your Personal Data. We will endeavour to respond within 40 days of your request in compliance with the Ordinance. We will charge a reasonable fee to cover our administrative costs when you request access to your Personal Data. We will comply with your request after the imposed fee is paid. We will not charge a fee for corrections to your Personal Data. Should we refuse your request for access or correction, reason(s) will be given. You may object to our reason(s) for our refusal to grant you access or correction.

7. Security

We will use reasonable commercial endeavours to protect your Personal Data against unauthorised or accidental access, processing, erasure or other use but at the same time we cannot guarantee a 100% security, for example from hacking or cybertheft as your Personal Data is transmitted over the Internet. We maintain our commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Data.

8. Retention of Personal Data

Your Personal Data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless this is contrary to any applicable laws.

9. Amendment to this Statement

We may amend this Privacy Policy Statement from time to time. If we make any amendments in the way we use your Personal Data, we will obtain your prior consent through your contact details provided to us.

10. Statement of Policies and Practices on Direct Marketing

Solvil et Titus intends to use and may share with our Affiliates your name, email, contact number, physical address and gender for direct marketing purposes as described below:-
a. Promotions relating to the Services, Products and other lifestyle accessories sold:
i. at our Stores,
ii. at this Website and/or
iii. other online or social media platforms
that are managed by us or our Affiliates.
b. Marketing activities relating to the Services, Products and other lifestyle accessories sold:
i. at our Stores,
ii. at this Website and/or
iii. other online or social media platforms
that are managed by us or our Affiliates.

You shall not receive direct marketing materials if you do not consent to Solvil et Titus’s use of your Personal Data for direct marketing purposes as described in this Privacy Policy Statement.
In future, if you do not wish to continue receiving our newsletters, marketing and promotional materials for direct marketing purposes, please either send an email to Data Protection Officer at cs@solvil-et-titus.hk or call our hotline at (852) 2113 2266 to notify us accordingly. We may record your conversation with us for good record keeping purposes. Our customer database will be updated accordingly at no charge to you.