1. Collection of Information
1.1 Survey Information
The Website collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Website, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, the Website or a third party (a "Third Party") may ask an individual to provide various information to the Website, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, "Survey Information"). The Website may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide survey information to the Website or Third Party, but an individual may receive incentives from the Website or a Third Party in exchange for providing Survey Information to the Website.
1.2 Other Information
Other occasions when the Website obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by the Website or by a third party, (2) when an individual requests assistance through the Website's customer service department, and (3) when an individual voluntarily subscribes to a service or newsletter on the Website (together, "Other Information").
1.3 Cookies, Web Beacons, and Other Info Collected Using Technology
1.4 Outside Information
The Website may receive information about individuals from third parties or from other sources of information outside of the Website including information located in public databases ("Outside Information").
1.5 Individual Information
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information the Website gathers or receives about individuals. 1.6 No Information Collected from Children The Website will never knowingly collect any personal information about children under the age of 13. If the Website obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, the Website has no such information to use or to disclose to third parties. The Website has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA"). 1.7 Credit Card Information The Website may in certain cases collect credit card numbers and related information, such as the expiration date of the card ("Credit Card Information") when an individual places an order from the Website. When the Credit Card Information is submitted to the Website, such information is encrypted and is protected with SSL encryption software. The Website will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.
2. Use of Individual Information
2.1 Discretion to Use Information
The company may use individual information (personal data) for any legally permissible purpose at company's sole discretion. "Personal data" is defined in Article 4(1) of the GDPR: "(1) 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person". The following paragraphs in Section 2 describe how the Website currently uses Individual Information, but the Website may change or broaden its use at any time.
As noted below, the Website may update this policy from time to time. The Website may use Individual Information to provide promotional offers to individuals by means of email advertising, direct mail marketing, online banner advertising, and package stuffers, among other possible uses. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties, please inform us by contacting customer service using the information at the bottom of this document and we will certainly honour your request. How we use your personal data Article 13(1) of the GDPR provides that: "(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information: ... (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party".
Article 6(1)(f) of the GDPR provides that: "(1) Processing shall be lawful only if and to the extent that at least one of the following applies: ... (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child." Section 2.2 Article 14 of the GDPR, which applies where personal information is not obtained from the data subject, provides that information about "the categories of personal data concerned" must be supplied to data subjects. Article 13 of the GDPR, which applies where personal information is obtained from the data subject, does not include an equivalent provision. Nonetheless, we have included references to general categories of data in this document, because this facilitates the identification of particular purposes of processing and the legal bases of processing - information which does need to be provided under Article 13.
The Website uses Individual Information to provide promotional offers by email to individuals. The Website may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. 2.3(a) Content of Email Messages In certain commercial email messages sent by the Website, an advertiser's name will appear in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to the Website. The "Subject:" line of the Website email messages will usually contain a line provided from the advertiser to the Website.
2.3 Solicited Email
The Website only sends email to individuals who have agreed on the Websites to receive email from the Website or to individuals who have agreed on third party websites to receive email from third parties such as the Website. The Website does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to the Website's email messages.
2.4 Targeted Advertising
The Website uses Individual Information to target advertising to an individual. When an individual is using the Internet, the Website uses Technology Information (see also Section 2.5 below) to associate an individual with that person's Individual Information, and the Website attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. The Website may, at its discretion, target advertising by using email, direct mail, cell phones, and other means of communication to provide promotional offers.
2.5 Use of Technology Information
The Website uses Technology Information (1) to match a person's Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person's online browsing habits on the Internet, (3) to determine which areas of the Website's web sites are most frequently visited. This information helps the Website to better understand the online habits of individuals so that the Website can target advertising and promotions to them.
2.6 Profiles of Individuals
The Website uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.
2.7 Storage of Individual Information
The Website stores the Individual Information in a database on the Website's computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under the Website's control. Notwithstanding such measures, the Website cannot guarantee that its security measures will prevent the Website's computers from being illegally accessed, and the Individual Information on them stolen or altered.
3. Dissemination of Individual Information
3.1 Order Fulfillment
The Website will transfer Individual Information to third parties when necessary to provide a product or service that a person orders from such third party while using the Website or when responding to offers provided by the Website.
3.2 Legal Process
The Website may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.3 Summary Data
The Website may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting customer service using the information at the bottom of this document. The Website may also grant advertising clients and email services providers access to an individual's email address to verify the origin of the Individual Information collected.
4. Privacy Practices of Third Parties
4.1 Advertiser cookies and web beacons
Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. The Website does not control Advertisers' use of such technology and the Website has no responsibility for the use of such technology to gather information about individuals.
The Websites and email messages sometimes contain hypertext links to the web sites of third parties. The Website is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. The Website does not operate or control in any respect any information, software, products or services available on such third party web sites. The inclusion of a link to a website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
4.3 Affiliated Companies
The Website may disclose, transfer, and sell Individual Information to entities affiliated with the Website in the Website's discretion. Company may disclose personal information to other companies in connection with marketing efforts including but not limited to direct marketing, which may have no relationship to Company. Furthermore, we may sell, license, or share your information with third-parties for various marketing purposes, including but not limited to telemarketing, e-mail marketing, text messaging, and direct mail. 5. Unsubscribe Procedures If you wish to discontinue receiving email messages from the Website please inform us by contacting customer service using the information at the bottom of this document. We reserve the right to add Individual Information to multiple lists maintained by the Website. For more information about protecting your privacy, you may wish to visit: www.ftc.gov or www.gov.uk. If you have questions about this policy, please inform us by contacting customer service either on +66 02 821 6767
or by emailing [email protected]