PRIVACY POLICY

Complex CN Shop Privacy Policy

This Privacy Policy is issued on behalf of SV TWO  Limited and its subsidiaries and associated companies. SV TWO Limited, trading as Complex CN Shop (“Complex CN Shop” or “we”) is the controller and is responsible for this Website. We take our customers’ privacy seriously and we will only collect and use your personal information as outlined below.

Your privacy is important to us. We will only use personal data, such as your name and other information, which relates to you in the manner set out in this Privacy Policy. We will only collect your personal data where it is necessary for us to do so and we will only collect information if it is relevant to our dealings with you.

This Website is not intended for children and we do not knowingly collect data relating to children. If you are under the age of 18, you should use our Website only with the involvement of a parent or guardian and should not submit any personal data to us.

We will only keep your personal data for as long as we are either required to do so by law or as required for the purposes for which it was collected. We will promptly delete your personal information once such purposes have been fulfilled We will periodically review the retention period of your personal data. At the end of that retention period, your personal data will either be deleted completely or anonymised.

Where we process your personal data, we do this for as long as you are an active user of our Site and it is required for business and legitimate interests or legal requirement or with your consent. The retention period of your personal data would be subject to our periodical review but would typically be around 7 years from your last interaction with us.

Where we process personal data for marketing purposes with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.

You can visit and browse the Website www.shop.complexchinese.com without having to provide personal details. During your visit to the Website you remain anonymous and at no time can we identify you unless you have an account on the Website and log on with your user name and password.

If you have any comments or suggestions, please email us at shop@complexchinese.com

- Collection of Personal Information

Complex CN Shop does not sell, share or trade customers' personal information collected online with third parties unless as specified in this Policy or where you have given your express consent. In particular, we do not share your personal information to third parties outside our corporate group for direct marketing purposes without your express consent.

Personal information collected online will only be disclosed within our corporate group for internal use and to be provided to our service providers (such as outsourced delivery team, operators of our IT systems, website service providers, data processors, data storage service providers)  for the purpose of providing service to you only.

When you (i) create a Complex CN Shop account or (ii) place an order for any products with us or (iii) when you subscribe to our publications, we may ask you to provide us with the following information :

• Name, including First Name and Last Name.
• Date of Birth
• Delivery Address
• Billing Address
• Payment details, such as credit card details or PayPal account details
• Email Address
• Telephone Number
• Mobile Number
• Social media information, such as Facebook or Instagram IDs.
• Information about your interests, preferences and hobbies.

The provision of the information is voluntary. However, if certain requested information is not provided, we will not be able to process your order and deliver the ordered products to you.

We may also receive the following data from you from your interaction with us or indirectly from your activities on the Website, including from the cookies we may collect:-

• Records of any interactions and correspondence between us
• Information about how you use our Website, products and services
• Details about payments to and from you and other details of products and services you have purchased from us
• Technical Data such as your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website

In addition, we may receive personal data about you from various third parties, including:-

• Your identity and contact particulars from delivery services providers;
• Your financial information from payment service providers

We do not collect any sensitive personal data about you, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

- Use of Personal Information

Personal information we collect from you will be used in some or all of the following ways:

• To deliver to you the products you have purchased from Complex CN Shop by our outsourced delivery team;
• To update you on the delivery of the product and for customer support purposes;
• To provide you with relevant product information
• To process your orders and to provide you with the services and information offered through our website and which you requested;
• To administer your account with us;
• To administer campaigns, contests and lucky draw should you choose to participate;
• To provide you with customer service and support;
• To verify and carry out financial transactions in relation to payments you make online and to transfer the information to financial institutions and credit card companies for processing payment;
• To audit the downloading of data from our website;
• To improve the layout and/or content of the pages of our website and customise them for users;
• To identify visitors on our website;
• To carry out research on our users’ demographics;
• To send you information we think you may find useful or which you have requested from us, including information about our products and services, provided you have indicated that you consent to being contacted for these purposes;
• To meet legal, regulatory or compliance requirements, dealing with enquires from law enforcement or regulatory bodies
• To provide the information to our legal advisors, auditors and accountants to advise us on the operation of the Website and delivery of the products and related issues;
• To transfer the information to our data processors to assist us in processing and storing your personal information;
•  To notify you about changes to our Terms of Service or Privacy Policy;
• All other incidental and associated purposes, including seeking professional advice.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the basis for doing so.

- Direct Marketing

When you register as a user on this Website, we may also use your personal information (name, contact details, product information, transaction pattern and behavior, demographic data) held by us to send you marketing and/or promotional materials from time to time which will require your consent.  You may give your consent by checking the appropriate boxes. You may withdraw your consent at any time by notifying us as indicated below.

If you have given your consent, we would use your personal data, such as name, phone number, email address and address for direct marketing which will include the marketing and promotion of all products and services offered by our corporate group. We will not provide your personal information to other third parties for use in their direct marketing activities.

 You may withdraw your consent for us to use your personal information in our direct marketing activities at any time by (i) indicating your preference where appropriate or (ii) by unsubscribing to our emails or (iii) by contacting us at shop@complexchinese.com.

For customers in the European Economic Area (EEA), we rely on our legitimate interests and your consent as the legal basis to send you direct marketing materials, unless you object to our use of your personal information in directly marketing. You have the right to opt-out of our direct marketing activities at any time. by (i) indicating your preference where appropriate or (ii) by unsubscribing to our emails or (iii) by contacting us at shop@complexchinese.com. Your withdrawal will be properly documented and withdrawal will not affect the lawfulness of processing before the withdrawal.

- Collection of Computer Data

When you visit our Website Complex CN Shop, our company servers will automatically record information that your browser sends whenever you visit a website. This data may include:

• Your computer's IP address
• Browser type
• Webpage you were visiting before you came to our site
• The pages within DDT Store Website that you visit
• The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics.
• This information is collected for analysis and evaluation in order to help us improve our Website and the services and products we provide. This data will not be used in association with any other personal information.

- Use of cookies

How we use cookies

A cookie is a small file which asks for permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

The table below lists the cookies we collect and what information they store.

 

You can set your browser to block some or all cookies. Please however note that if you set your browser to disable cookies, you may not be able to access certain parts of our Website and other parts of our service may not work properly. 

Apart from cookies, we may also collect information by automated means, such as web server logs. 

- Disclosure of Personal Information

We may pass your name and address on to a third party in order to make delivery of the product to you (for example to our courier or supplier) or to process payments (for example to financial service providers).

Your actual order details may be stored with us but for security reasons cannot be retrieved directly by us. However, you may access this information by logging into your account on our Website. There you can view the details of your orders that have been completed, those which are open and those which are shortly to be dispatched and administer your address details, bank details and any newsletter to which you may have subscribed. You undertake to treat the personal access data and password confidentially and not make it available to unauthorised third parties. We cannot assume any liability for misuse of passwords unless this misuse is our fault.

Unless in accordance with the law or with your written consent or as specified in this Privacy Policy, we will not share your information with any other organisations other than related companies and those third parties directly related to the delivery of the products you have purchased from Complex CN Shop Website, such as financial institutions, credit card companies, logistics companies and courier companies.

We have proper contract with the outsourced delivery team to control how it processes the data and to comply with the laws in this respect.

- Links to other websites

Our website may contain links to other websites of interest. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

- Our Legal Basis for Processing Personal Data for Customers in the EEA

For customers in the EEA, Complex CN Shop lawfully process your personal data under the following legal basis:-

1) Where using your data is in our legitimate interests

We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:

conducting business by providing services to you, including verifying your identity and any accounts you have with us; administering any marketing activities, processing your orders for products and maintaining your shopping cart, attending to billing, payments, refunds and delivery arrangements; handling and responding to your inquiries, suggestions or complaints; conducting analysis ; providing you with direct marketing communication (where you have given consent);

• to help us satisfy our legal obligations (for example, in relation to prevention of money laundering and anti-terrorism);
• to help us understand you better and provide better, more relevant services to them;
• to ensure that our service runs smoothly; and
• to help us keep our systems secure and prevent unauthorised access or cyber-attacks.

2) Where you have given us your consent to use your personal data

We process your personal data based on your consent for the purpose of direct marketing, such as sending you news, events and product updates.

For this purpose you have the right to withdraw your consent at any time by contacting us at shop@complexchinese.com.

3) Where using your personal data is necessary for us for contract performance

We may use your personal data when it is necessary to do so to provide services to you. For example, we need to collect your credit card and payments details in order to be able to process your payments; we need your name and mailing address to deliver products to you

4) Where processing is necessary for us to carry out our legal obligations

We also have legal obligations that we need to comply with and we are allowed to use your personal data when we need to in order to comply with those other legal obligations.

- Your Rights to Your Personal Data

You have the right to ascertain whether Complex CN Shop has your personal data, to obtain a copy of your personal information, and to modify, update, delete or correct any information that is inaccurate. Request for access and correction or for information should be addressed in writing by email to shop@complexchinese.com.  We may charge a reasonable fee for processing any data access request.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at shop@complexchinese.com. We will promptly correct any information found to be incorrect.

Where we have obtained your consent to process your personal data for certain activities (for example, for direct marketing), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to. You may choose to restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at shop@complexchinese.com. We will not sell, distribute or lease your personal information to third parties unless we have your consent or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
  
  

- Your Rights to Your Personal Data for Customers in the EEA

For customers in the EEA, in addition to the rights above, you also have the following rights under the General Data Protection Regulation (GDPR):-

• You may object to us processing your personal data where we process your personal data based on our legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. We shall act on your objection by ceasing to process your personal data unless we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms in some cases.
• You have the right to withdraw your consent where we process your personal data based on consent, particularly for the purpose of direct marketing;
• You have the right to request that we erase your personal data, where the data is no longer necessary for the purpose for which we originally collected and/or processed it, where you have withdrawn your consent previously given, or where it is necessary for the data to be erased in order for us to comply with our obligations as a data controller under the GDPR.
• You have the right to request that we restrict our processing of your personal data whilst we consider any inquiry or complaint you have raised in relation to our processing of your personal data.
• In relation to our marketing activities, we analyse some of the information that we collect about you to determine what offers are most likely to be of interest to you. To do this, we combine personal data that we have collected from you about your purchase history and interactions with us. From time to time, we will assess and analyze the personal data that we hold about you in order to tailor our marketing communications to include offers and content that are relevant to you. You have the right to opt out of such marketing and analysis of your personal data.
• You have the right to request for us to transfer the details we hold on you to a third party.

All of your rights under this section are subject to certain exemptions to safeguard the public interest and our interests.

We will aim to respond to requests within 30 days. If we are unable to resolve an inquiry or a complaint, you have the right to contact the data protection regulator in the country in which you are based.

- Security of Personal Information 

Complex CN Shop ensures that all information collected will be safely and securely stored in our or our service providers’ secure servers. We ensure protection of your personal data by:

• Restricting access to personal information
• Maintaining technology products to prevent unauthorised computer access
• Maintaining appropriate measures to protect the confidentiality and security of your personal data
• Securely destroying your personal information when it's no longer needed for our record retention purposes

No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion.  However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with the requirements of data protection legislation.

If you believe that your privacy has been breached by Complex CN Shop, please contact us at shop@complexchinese.com

- Changes of Privacy Policy

Complex CN Shop reserves the right to modify and change the Privacy Policy at any time. Any changes to this policy will be published on our Website. This version was last updated on 16 January 2022 

- Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

- Export of your Personal Data

Where necessary to deliver our services, your personal data may be transferred outside the country in which you are located or outside Hong Kong.

For customers in the EEA, please note your personal data may be accessed, transferred or stored outside the EEA, including to countries which may have a lower level of data protection than under European Union law.  When we do so, we will use appropriate safeguards such as contractual terms to protect any personal data being transferred.

- Contact Us

If you have any questions regarding the way we handle your personal information or if you have any enquiry or complaint, please don't hesitate to contact us at shop@complexchinese.com

In case of any discrepancies between the English and Chinese versions of this Privacy Policy, the English version shall prevail.