1.1 Vennic Limited (i.e. TamJai SamGor) and its subsidiaries/associated companies (collectively “we”, “our” or “us”, each a “member of the Group”) respect your legal rights of privacy and are committed to protecting your Personal Data (as defined hereinafter) in line with our obligations under the Personal Data (Privacy) Ordinance (Cap. 486, Laws of the Hong Kong Special Administrative Region, “Hong Kong”) (the “Ordinance”) and other applicable privacy laws. Your privacy is important to us and we have taken steps to ensure that we do not collect more Personal Data than is necessary for us to provide you with our services, and to ensure that your Personal Data is kept safe and secure at all times during our possession.
2. Personal Data that we collect
(a) to handle your orders and process payments;
(b) to handle your requests and enquiries;
(c) to improve and enhance your experience on the Online Platform;
(d) to customize your profile;
(e) to measure and further develop the Online Platform and/or its content;
(f) to verify your identity;
(g) for research and statistical analysis; and to notify you of the redemption of gifts/coupons, and relevant arrangements for the redemption;
(h) to undertake direct marketing, for instance, by providing you with our latest news update on our products, services, promotional events, or other marketing materials or information as and when sent out by us (if any);
(i) to undertake research and statistical analysis;
(j) to comply with the obligations, requirements or arrangements for disclosing and using Personal Data that apply to us or that it is expected to comply pursuant to:-
(i) If we make amendments in the way we use your personal data, we will obtain your express consent.
(ii) If we make amendments in the way we use your personal data, we will obtain your express consent.
(k) for any other purposes as specified at the time of collection of your Personal Data.
2.3 If we make changes in the way we use your Personal Data, we will obtain your written consent through email in advance.
2.4 The Personal Data will be collected in two ways:
(a) Those Personal Data provided by you – When you register for an account and subsequently log in to your account on the Online Platform, or when you place an order on the Online Platform, or when you request for information and/or make inquiries, you will be asked to provide us with your Personal Data, including but not limited to your name and email address.
(b) Those Personal Data collected from your use of the Online Platform – we may collect information in respect of the pages on the Online Platform that you use and how you use them. Such information shall include but not limited to the following:
(i) Device information
We may collect device-specific information (such as hardware model and the operating system version).
(ii) Log information
When you view the contents on the Online Platform, we may collect and store certain information in the server logs. This may include:
• details of how you viewed such content, such as search queries;
• internet protocol address;
• information concerning your device such as crashes, system activity/activities, hardware settings, type and language of your browser, the date and time of your request and the landing page path and/or the destination URL into or from the Online Platform; and
• cookies (“Cookies”) that may uniquely identify your browser and/or your user account.
(iii) Location information
When you use the Online Platform, we may collect and process information about your location such as the country and/or the city you are located in while using the Online Platform.
(iv) Cookies and anonymous identifiers
Cookies are small files that are sent to your device when you visit a website to store your preferences as a user and related information with a view to analyzing your web-surfing habits and preferences. The Cookies allow that website to recognize your browser in your subsequent visits and are commonly used to track your preferences in relation to the subject matter of the website.
You may reset your browser to disallow Cookies or to reject acceptance of Cookies when being alerted. However, by disabling Cookies, you may not be able to access or use certain parts of the Online Platform, and some of its features may not function properly or be made available to you.
2.5 Your supply of the Personal Data to us is voluntary, but a failure to supply such Personal Data may result in us not being able to provide our products or services or otherwise deal with you as the Relevant Person.
3. Data Sharing and Transfer of Personal Data
3.1 We will take all reasonable and practicable steps to keep your Personal Data confidential, although we may provide such information to any of the following parties (whether within or outside Hong Kong) for any of the purposes set out in the above:
(a) any agent, contractor or third-party service provider who provides marketing, promotional, administrative, management, telecommunications, computer, technology, legal, payment clearance or other services to us in connection with our business operations (including but not limited to promotion, gifts, lucky draws, games and other activities from time to time);
(b) any person under a duty of confidentiality to us, including a member of the Group which has undertaken to keep such information confidential;
(c) any person to whom we are under an obligation or otherwise required to make disclosure under the requirement(s) of any law binding on or applicable to us, or any disclosure pursuant to the requirements of any law or order issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations existing currently and in future with which we are expected to comply;
(d) any actual or proposed assignee of us, or enforcer of our rights in respect of the Relevant Persons;
(e) any member of the Group; and
(f) any other external service providers (including but not limited to telemarketing companies, data processing companies and information technology companies) that we engage for purposes set out in the above.
3.2 Personal Data of Relevant Persons may be transferred to a place outside Hong Kong. To the extent that is legally permissible to do so, we shall seek to ensure any transfer of Personal Data across jurisdictions will be afforded with such degree of protection similar to that being afforded in Hong Kong.
4. Direct Marketing
4.1 We may use your Personal Data for direct marketing purposes, in which case we shall obtain your consent or an indication of no objection from you prior to the collection and/or use of your Personal Data for such direct marketing activities. In this connection, please note that:-
(a) we may use your contact details such as your name, telephone number and email address that are held by us from time to time in direct marketing activities including but not limited to marketing and promotional materials relating to our restaurants, food and drink items, and related events, services and products; and
(b) the above marketing may be provided by us and/or any member of the Group.
4.2 You may unsubscribe to our marketing and promotional materials at any given time by contacting our Data Protection Officer in charge of handling personal data matters based on the contact details set out in paragraph 7 below.
5. Information Security
5.1 We value and place great importance in ensuring the security of the Personal Data that we have gathered. We have put in place various physical, electronic, and managerial procedures to seek to safeguard the Personal Data that we have collected. Despite the implementation of such measures, however, we cannot state with absolute certainty and do not warrant that the communications between yourself and ourselves, or your Personal Data stored on the Online Platform and/or our servers will be perpetually and completely free from unauthorized access by third parties such as hackers. Therefore, by using our Online Platform, you acknowledge the possibility in respect of unauthorized interception, access, collection and/or use of your Personal Data by third parties, and agree to assume the relevant risks. Despite such possibility, however, we will seek to continuously improve and update our Online Platform, servers and related system to try to further enhance the underlying information security.
6.1 In order for us to provide better services to you, please ensure that your contact details (including your address, your telephone number, e-mail address and other relevant details) registered with us are up to date. Should there be any changes or updates on the information you provided, you are advised to update the same promptly (if the relevant function is made available) or send us a data correction request regarding data correction based on paragraph 7 below. We shall not be responsible in any way and at any given time for any and all consequences caused by the inaccuracy of any information that you have provided to us.
7. Access, Correction and Ceasing to use Personal Data
7.1 Under and in accordance with the terms of the Ordinance, any Relevant Person shall have the right:-
(a) to check whether we hold Personal Data about him/her and request for access to such Personal Data;
(b) to require us to correct any Personal Data relating to him/her which is inaccurate; and
(c) to ascertain our policies and practices in relation to Personal Data and to be informed of the kind of Personal Data held by us.
7.2 The contact details of the person responsible for responding to or handling requests for access to Personal Data, exercise of opt-out right, correction of Personal Data or information regarding policies and practices and kinds of Personal Data held are as follows:
The Data Protection Officer
8/F, D2 Place ONE,
No. 9 Cheung Yee Street,
Cheung Sha Wan,
Kowloon, Hong Kong
7.3 Upon receipt of sufficient information verifying your identity, we will endeavour to comply with your request within or less than 40 days. Please note that in accordance with the terms of the Ordinance, we have the right to and may charge you a reasonable fee in processing your data access request.
7.4 For the avoidance of doubt, in the event that you withdraw the consent previously given to us, such withdrawal shall not affect the lawfulness of any processing of your Personal Data carried out by us prior to your indication for withdrawal of the consent.