(last updated: 25 May 2018)

1. General

Respecting and protecting our customers’ privacy and personal data is important to Joyce Boutique Holdings Limited and its related companies (including all holding, subsidiary and affiliate companies) (collectively, we or us). This notice will help you understand how we collect, use and safeguard your personal data in our interactions with you.

It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the section What rights do I have?.

2. What information do we collect?

We collect and process personal data about you when you:

3. How do we use this information, and what is the legal basis for this use?

We process personal data for the following purposes:

4. Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our business and legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

5. Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. Specifically, in the case of customers from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) amending your preferences in the logged-in area of this Site, (b) contacting our Privacy Officer at dataprivacy@joyce.com or mailing to; Privacy Officer, Joyce Group, 26F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong, (c) in the case of emails, by clicking the unsubscribe link at the bottom of such emails.

6. Who will we share this data with, where and when?

We will share your personal data with the related companies of Joyce Boutique Holdings Limited.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified above. In particular, we use third party providers of courier services, e-mail/SMS/MMS/WeChat blasting services, telecom companies (for providing in-store Wi-Fi services), data storage and cloud service providers (for storage of your personal data and hosting of applications that process your personal data for the purposes identified in this notice), Google and Facebook (for matching of your personal data with their database in order to send you our direct marketing materials through your Google and/or Facebook account(s)), digital marketing and website analytic agencies (for display of advertising materials on our Site and other websites that you may visit, and analysis of your online behaviour and usage of our Site – these agencies use cookies; please refer to our separate Cookies Policy for details).

In the event that our business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

If you are from the EEA, where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data will be adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to the contact mentioned in the section "How do I get in touch with you" below. Your personal data may be transferred to Hong Kong and Macao Special Administrative Regions, Mainland China, Taiwan Region, Indonesia, Singapore, Australia, United States, and Japan.

7. What rights do I have?

Where permitted by law, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, if you are from EEA you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are from the EEA: If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.)

8. How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at dataprivacy@joyce.com or by writing to Privacy Officer, Joyce Group, 26/F, One Island South, 2 Heung Yip Road, Wong Chuk Hang, Hong Kong. You may also access, verify or update your personal data by logging into the Site or completing the “Customer Information Renewal Form” at one of our stores.

9. Who is the data controller?

The data controllers are Joyce Boutique Holdings Limited, and its related companies; contact details can be found in the section How do I get in touch with you above.

10. How long will my data be kept?

Where we process registration 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 [(applicable if you are from the EEA only for 7 years after any business and legitimate interests or legal requirements no longer exist)].

Where we process personal data for marketing purposes or 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 future.

(Applicable if you are from the EEA only) Where we process personal data for site security purposes, we retain it for 7 years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for 7 years from your last interaction with us.

11. Photography Policy

We place conspicuous notices in our stores to inform customers we prohibit unauthorised photography, sound and/or video recording for commercial use, private gain, use in press or media, or for promotional purposes in our stores. We reserve the right to remove offenders from our premises.

We permit photography, sound and/or video recording where the images/recordings are solely for personal use and are not published or reproduced in print or electronically for commercial use, private gain, use in press or media, or for promotional purposes.

Permitted photography, sound and/or video recording are subject to the following conditions:

If a customer has queries in relation to the photography policy, he/she may contact the Store Manager.

12. Closed-Circuit Television (CCTV) Policy

Policy Statement

This policy outlines the policies and procedures regarding the use of CCTV in Joyce stores undertaken to comply with the requirements of the Personal Data (Privacy) Ordinance (the Ordinance). CCTV is used to procure reasonable security and safety of the monitored area.

In accordance with the Ordinance and relevant guidelines issued by the Office of the Privacy Commissioner for Personal Data (PCPD):

Our Privacy Policy reflects the usage of CCTV in our stores and reads:

We employ Closed-Circuit Television (CCTV) in our stores. Store premises are subject to CCTV surveillance and activities are recorded by video camera to procure reasonable security and safety of the monitored area.

Information obtained through CCTV monitoring will be used exclusively for safety, security, and law enforcement purposes. Recorded images will be stored in a secure location with access by authorized staff only and will be securely deleted as soon as practicable once the purpose of collection is fulfilled.

If you wish to contact us in relation to privacy of your personal data, please contact our Privacy Officer at dataprivacy@joyce.com or mail to: Privacy Officer, Joyce Group, 26F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.

General Procedures

I. Proper Handling of the Recorded Images

II. Transfer of CCTV Records to Third Parties

III. Misuse or abuse of CCTV system or the recorded images is reported to Natalie Da Gama-Rose, General Counsel of the Group Legal Department (email: natalie.dagamarose@lcjgroup.com; Telephone: +852 2118 2280).

IV. Compliance checks and audits are carried out annually to review the effectiveness of the safeguards and procedures of the CCTV system.

Customers Enquiries/Law Enforcement Agencies (Eg Police)