PRIVACY POLICY

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from www.22factor.com (the “Site”). Throughout this Privacy Policy, the terms “we”, “us”, “our” and "22 Factor" refer to 22 Factor and each of its affiliates, subsidiaries and parent companies.

When we collect information from you, our policy is to comply fully with the requirements of the Personal Data (Privacy) Ordinance (the “PDPO“) which regulates in Hong Kong the treatment of personal data, and any other applicable laws regulating the treatment of personal data. Personal data is any information relating to any living individual from which it is possible to identify that individual. In dealing with personal data, we will ensure that we comply with the standards of security and confidentiality prescribed by law.

This Privacy Policy shows our commitment to protect your personal data and explains our practice in relation to the collection, retention, storage and sharing of personal data.

This Site is not intended for use by children or minors under the age of 16 and we do not knowingly collect or use personal information relating to children.

OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

    • Consent: where you have given us clear consent for us to process your personal information for a specific purpose
  • Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
    • Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
    • Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

    PERSONAL INFORMATION WE COLLECT

    When you visit the Site, we collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

    We collect Device Information using the following technologies:

    • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
    • “Log files” track actions occurring on the Site, and collect data including your IP address, browser
    • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

    Additionally when you make a purchase or attempt to make a purchase through the Site, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes name, title, and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Demographic Data includes post code, preferences and interests.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
    • Technical Data includes internet protocol (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 Site.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

    When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • search for a product;
    • create an account on our Site;
    • subscribe to our service;
    • place an order on www.22factor.com (our site);
    • participate in discussion boards or other social media functions on our Site;
    • request marketing to be sent to you;
    • enter a competition, promotion, survey or question and answer sessions; or
    • give us some feedback or report a problem with our Site.
    • Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at the bottom of this page for further details.
    • Your name, website ID/login name, email address and password.  We may need this information in order to provide you with access to this Site and to ensure we can identify you.  We reserve the right to request further information from you in order to verify your identity where required.
    • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
      • Technical Data from analytics providers such as Google.
      • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Shopify, Paypal and etc.

     

    HOW DO WE USE YOUR PERSONAL INFORMATION?

    We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).  Additionally, we use this Order Information to:

    • Communicate with you;
    • Screen our orders for potential risk or fraud; and
    • When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

    We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

    Note that we may process your Personal Information  for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.

    Purpose/Activity

    Type of data

    Lawful basis for processing including basis of legitimate interest

    To register you as a new customer

    (a) Identity

    (b) Contact

    Performance of a contract with you

    To process and deliver your order including:

    (a) Manage payments, fees and charges

    (b) Collect and recover money owed to us

    (a) Identity

    (b) Contact

    (c) Financial

    (d) Transaction

    (e) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to recover debts due to us)

    To manage our relationship with you which will include:

    (a) Notifying you about changes to our terms or privacy policy

    (b) Asking you to leave a review or take a survey

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary to comply with a legal obligation

    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    To enable you to partake in a prize draw, competition or complete a survey

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

    To allow you to participate in interactive features of our service, when you choose to do so

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, compliance with statutory, legal or regulatory obligations)

    (a) Identity

    (b) Contact

    (c) Technical

    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    (b) Necessary to comply with a legal obligation

    To deliver relevant site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (f) Technical

    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

    To administer our site and for internal operations, including troubleshooting, and to use data analytics to improve our site, products/services, marketing, testing, research, customer relationships and experiences, statistical and survey purposes

    (a) Technical

    (b) Usage

    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    To make suggestions and recommendations to you and other users of our site about goods or services that may be of interest to you, including goods and services from our group companies

    (a) Identity

    (b) Contact

    (c) Technical

    (d) Usage

    (e) Profile

    Necessary for our legitimate interests (to develop our products/services and grow our business)

     

    Marketing

    We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. We have established the following Personal Information control mechanisms:

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

    We will only use your Personal Information 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 Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    SHARING YOUR PERSONAL INFORMATION

    Your Personal Information held by us will otherwise be kept confidential and shall not be disclosed or transferred to any third party without your consent. However, we may provide your Personal Information to the persons set out below in accordance with this section ("SHARING YOUR PERSONAL INFORMATION").

    In addition, we may provide your Personal Information to the persons set out below (whether inside or outside Hong Kong), where necessary in order to fulfill one or more of the purposes stated in the "HOW DO WE USE YOUR PERSONAL INFORMATION?" section above, or for any other purpose consented to by you or as notified to you at the time of collection of your Personal Information.

    These persons are:

    • any personnel, agent, adviser, auditor, contractor or service provider who provides services or advice to us in connection with its operations, or any affiliate or subsidiary of us, who is subject to a duty of confidentiality;
    • any person to whom we are required to make disclosure under any law applicable in or outside Hong Kong.

    We may need to share your information with companies who work under contract to us for purposes mentioned in the "HOW DO WE USE YOUR PERSONAL INFORMATION?" section above. We shall ensure that all of these other companies protect your Personal Information by applying the same standards of security as us.

    We share your Personal Information with third parties to help us use your Personal Information, as described above.  For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here:  https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

    We may also share your Personal Information with our group companies, who may contact you by mail, telephone, email or other electronic messaging service with offers of products, services and information which may be of interest to you.  By providing us with your contact details you consent to being contacted by these methods and to our using your personal information for these purposes. If you do not wish to receive marketing information from us or our group companies, please contact our Data Protection Officer.   

    Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

     

    BEHAVIOURAL ADVERTISING

    As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

    You can opt out of targeted advertising by:

       FACEBOOK - https://www.facebook.com/settings/?tab=ads

       GOOGLE - https://www.google.com/settings/ads/anonymous

    Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

    COOKIES

    A cookie is a small file which asks 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 webpage traffic and improve our Site 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 Site 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 Site;

    Session cookies last only for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a Site to identify that a user of a particular device is navigating from page to page, supporting Site security or basic functionality;

    Persistent cookies last after you have closed your browser, and allow a website to remember your actions and preferences for when you next return. Sometimes persistent cookies are used by websites to provide targeted advertising based upon the browsing history of the device but not on this Site.

    This Site may place and access certain Cookies on your computer. 22 Factor uses Cookies to improve your experience of using the Site and to improve our range of services. 22 Factor has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

    You can choose to delete Cookies at any time however you may lose any information that enables you to access the Site more quickly and efficiently including, but not limited to, personalisation settings.

    It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

    The cookies we use are:

    COOKIE NAME: COOKIE DESCRIPTION

    CART: The association with your shopping cart.

    CATEGORY_INFO:Stores the category info on the page to display pages more quickly.

    COMPARE: The items that you have in the Compare Products list.

    CUSTOMER:An encrypted version of your customer id with the store.

    CUSTOMER_AUTH: An indicator if you are currently logged into the store.

    CUSTOMER_INFO: An encrypted version of the customer group you belong to.

    CUSTOMER_SEGMENT_IDS: Stores the Customer Segment ID

    EXTERNAL_NO_CACHE: A flag, which indicates whether caching is disabled or not.

    FORM_KEY: Stores form key used by page cache functionality.

    FRONTEND: Your session ID on the server.

    GUEST-VIEW: Allows guests to edit their orders.

    LAST_CATEGORY: The last category you visited.

    LAST_PRODUCT: The most recent product you have viewed.

    NEWMESSAGE: Indicates whether a new message has been received.

    NO_CACHE: Indicates whether it is allowed to use cache.

    PERSISTENT_SHOPPING_CART: A link to information about your cart and viewing history if you have asked the site.

    RECENTLYCOMPARED: The items that you have recently compared.

    STF: Information on products you have emailed to friends.

    STORE: The store view or language you have selected.

    USER_ALLOWED_SAVE_COOKIE: Indicates whether a customer allowed to use cookies.

    VIEWED_PRODUCT_IDS: The products that you have recently viewed.

    _GA Google analytics

    _GAC_UA Google analytics

    _GID Google analytics

     

    More information about cookies, including how to block them on all sites or delete them, can be found at AboutCookies.org.  

    DO NOT TRACK

    Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

    YOUR RIGHTS

    Free of charge, you have the right to:

    • request an explanation on our fair processing of information and transparency over how we use your use personal information
    • access to your personal information and to certain other supplementary information that this Privacy Statement is already designed to address
    • request correction to any mistakes in your information which we hold
    • request erasure of personal information concerning you in certain situations
    • receive any personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
    • object at any time to processing of personal information concerning you for direct marketing
    • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
    • object in certain other situations to our continued processing of your personal information
    • otherwise restrict our processing of your personal information in certain circumstances  

    If you would like to exercise any of the above rights, please contact our Data Protection Officer.

    Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.  

    TRANSFER OF PERSONAL INFORMATION

    In order to deliver our services your Personal Information may be transferred outside of the jurisdiction in which it was collected and may be processed by individuals and systems in a different jurisdiction. This includes to the following destinations outside of the European Economic Area (EEA): Hong Kong, United States in order to processing the orders. By providing your Personal Information, you agree to such transfer.

    Please note that such countries do not have the same data protection laws as the EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the EEA, any transfer of your personal information will be subject to your consent. To obtain a copy of such safeguards, please contact our Data Protection Officer.

    IF YOU SUPPLY INFORMATION ABOUT OTHER PEOPLE

    If you are providing information about someone else, you confirm that they have appointed you to act for them, to consent to the processing of their Personal Information and that you have informed them of our identity and the purposes (as set out in this Privacy Policy) for which their Personal Information will be processed.  

    OTHER INFORMATION

    You should note that if our business (or any part of it) is sold or transferred at any time, the information we hold may form part of the assets transferred although will still only be used in accordance with this Privacy Policy.

    SECURITY

    Where Personal Information is stored electronically, we will take reasonable steps to ensure that any information provided as a result of accessing this Site is kept secure.  Our Site has security installed to ensure that any Personal Information entered onto the site is protected against loss, misuse or alteration. Personal Information, whether stored in electronic form on computers or in hard-copy form, will be accessible only by authorised officers or employees of us. Persons designated by us to handle Personal Information will comply with this Privacy Policy and/or any other relevant obligations under the PDPO or any other applicable laws, and told how to fulfil our obligations to you.

    Any Personal Information we receive from you will not be disclosed to any third party except as provided in this Privacy Policy, as notified to you at the time of collection, or with your prior consent.

    While we take appropriate steps to maintain the security of your data; however you should understand that the open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended.  Whilst we use all reasonable endeavours to protect your security, we advise users that data transmission over the internet and the World Wide Web cannot be guaranteed as 100% secure, and therefore that you use the Site at your own risk.

    We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    DATA RETENTION

    Personal information you provide to us will be retained only for such period as may be necessary for the carrying out of the purposes referred to in this Privacy Policy or as otherwise specified at the time of collection.

    CHANGES

    We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

    CONTACT US

    For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@22factor.com or by mail using the details provided below:

    Address: 3/F, 926 Cheung Sha Wan Road, Kowloon, Hong Kong

    Business Hours: Monday to Friday 9am to 6pm, Hong Kong time GMT+8.