TM Spa Group (“we”, “our” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this PICS explains our privacy practices.Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This policy may from time to time be revised.”personal data” means any personally identifying information or sensitive data (such as names, occupations, addresses, contact details, ID Card or Passport numbers, credit card information, your age, your marital status, your employer, your income, demographic data) from which it is practicable for the identity of an individual to be ascertained.2. Purposes for using your Personal Data
Your personal data may be collected when you make a purchase on treatment packages, products or apply to be our member. The purposes for which we may use your personal data are divided into obligatory purposes and voluntary purposes. If personal data is to be used for an obligatory purpose, these personal data will not be marked as “optional” in the Members Application Form and you MUST provide your personal data to us if you want us to provide the service for which you are applying. If personal data is only to be used for a voluntary purpose, it is entirely up to you to decide whether you want to provide such information to us or not.Purposes for which it is obligatory for you to provide your personal data are:(a) enrolment into and maintaining your membership as our member;(b) accumulating bonus points as our member;
(c) communicating to you your entitlements and privileges as our member;
(d) redemption of privileges as a member;
(e) notification of any amendment to the membership program;
(f) relationship building; and
(g) data cleansing and customers profile updates.
Purposes for which it is only voluntary for you to provide your personal data are:
(a) to enable us better to understand the demographics of our customers;
(b) for internal research and analysis to enable us to provide rewards, services and product information or offerings better tailored to your needs;
(c) market research;
(d) to enable our advisor to follow up;
(e) to distribute customer satisfaction survey;
(f) to send out VIP newsletters and VIP program updates；and
(g) direct marketing, include:
- communicating to you regarding new product launch and other promotional offers, including where applicable, skincare products, cosmetics products, fragrance products, make up products, body care products, hair care products, home products and make up service, facial services, body care services and waxing services;
- communicating to you regarding our promotional events including where applicable, makeup classes and/or demonstrations, skincare seminars, other beauty classes, PR events, VIP gatherings value sets, shop opening events, store announcement/events, exhibitions, fashion shows and news update;
iii. communicating on-counter or out of counter services and events related to skincare, makeup, body care, hair care, fragrance or home products for promotion or reward purpose;
- marketing reward programs, birthday celebration offers, free sampling, digital campaigns, roadshow/outpost, in store promotion updates;
- communicating joint promotion or events with shopping malls, department stores, credit cards, banks, trades, celebrities, magazines, television, websites, mileage programs, cultural, art or musical societies/organizations, charities or non profit organizations; and
(f) cross brand joint promotions and/or events with brands within the TM Spa Group.
In order to ensure the confidentiality of your personal data, we ensure that our policies and practices regarding the collection, use, retention and transfer of and access to your personal data comply with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong.
You are required to present your Hong Kong Identity Card for record purpose prior to any trial or purchase of our treatments or products. If you refuse to present such copy, we reserve the right to provide any services or products. Pursuant to Section 7AA of the Registration of Persons Ordinance, any person who, without lawful authority or reasonable reason, transfers his identity card to another person commits an offence.
4. Collection of Personal Identifiers
You may need to provide your identifiable information from time to time, including but not limited to your name, gender, age, identity card number, date of birth, phone number, facsimile number, address, email address, credit card details, education level, occupation, household income, hobbies or preferred activities. Failure to provide such data may prevent us from providing appropriate services to you. If you are under 18, you must obtain the consent from parents or guardians before disclosing any of your identifiable personal data to us.
After submitting your identifiable personal data, you may receive the direct marketing phone calls, emails or direct mails from us/our affiliates or business partners from time to time. If at any other point of time you do not wish us to use your personal data for use in direct marketing as described above, you may exercise your opt-out rights by notifying us. Please mail to “Room 06-07, 20/F, CEO Tower, 77 Wing Hong Street, Cheung Sha Wan, Kowloon”or email us at firstname.lastname@example.org . No fee will be charged for this arrangement.
6. Storage of Personal Data
Pursuant to our general policy, we will keep a record of all transactions with you in our course of business for a reasonable period of time for review and verification purposes.
7. Disclosure of Data
We usually share your personal data with or transfer such data to TM SPA GROUP and its member companies, subsidiaries, affiliates or any companies in which they have an interest. Please refer to our Personal Data Collection Statement for details. If you do not want us to disclose your personal data to any third parties, Please mail to “Room 06-07, 20/F, CEO Tower, 77 Wing Hong Street, Cheung Sha Wan, Kowloon”or email us at email@example.com and provide your name, membership number and contact number.
8. Access to Personal Data
You can send mail to Room 06-07, 20/F, CEO Tower, 77 Wing Hong Street, Cheung Sha Wan, Kowloon”and write to request access to your personal information to the company’s customer service manager, the Company is based on the provisions of section 19 (1) of the Personal Data (Privacy) Ordinance, to reply you in receipt of your requirements within 40 days. In accordance with the provisions of section 20 (3e), if you refuse the access request form or in writing, the Company reserves the right to refuse your access request. Under section 28, the Company may charge a reasonable fee for information access. However, if you indeed to make reasonable corrections access to personal data, the Company may exempt from the relevant charges.
9. Correction of Personal Data
You shall send your request to correct your personal data in writing to our Customer Service Manager and provide the correct information. Pursuant to Section 23 of the Personal Data (Privacy) Ordinance, we will correct your personal date within 40 days upon request without charge.
The person to whom (1) requests (i) for access to data or correction of data, (ii) for general information regarding our policies and practices with respect to personal data and (iii) about the kinds of personal data that we hold and (2) general questions and complaints should be sent to the below email: firstname.lastname@example.org
All personal data provided by you will be properly stored in our customer service system and can only be accessed by authorized persons.
(This Statement may be amended from time to without prior notice. Please review it regularly.)
12. Personal Data Collection Statement
As a customer of TM SPA GROUP, you may be required to provide your personal data (“Personal Data”) to us prior to any trial or purchase of our services and/or products (“Services”). Incomplete or incorrect data may prevent us from providing or continuously providing the Services.
We will always keep your personal data confidential. Our policies and practices regarding collection, use, retention, disclosure, transfer and confidentiality of and access to your personal data comply with the laws of Hong Kong and are stated in this Statement.
You agree that we may use and retain any personal data provided by you for the following purposes and any other purposes mutually agreed by you and us or required by law from time to time:
- provision of Services;
- promotion of any goods and/ or services related to the Services or any other goods and/or services by us, our agents, subsidiaries or business partners;
- handling of any interest in or in relation to the Services;
- analysis, confirmation and/or verification of your credit, payment and/ or other status in respect of the provision of the Services;
- handling of any payment instructions, direct debit payment and/or credit payment requested by you;
- day-to-day management of your account and/or collecting any account payable in respect of the Services; and
You also agree that for the above purposes, we may disclose and transfer (whether within or outside Hong Kong) the right to use, disclose, hold, handle, retain or transfer your personal data to our agents, contractors, any telecommunication operators, any third party receiving organizations, any credit consultants, any security organizations, any credit providers, banks, financial institutions, any other persons under a duty of confidentiality to us, and any actual or proposed assignees of us. In addition, pursuant to the agreement between you and us, we may disclose and transfer (whether within or outside Hong Kong) your personal data to TM SPA GROUP. and its member companies, subsidiaries, affiliates and any companies in which they have an interest, and may store the Personal Data in the database or databases (which may contain any other information collected by us or TM SPA GROUP. and its member companies, subsidiaries, affiliates or any companies in which they have an interest) held by us or TM SPA GROUP. and its member companies, subsidiaries, affiliates and any companies in which they have an interest for the above purposes to promote any goods and/ or services of us and/or TM SPA GROUP. and its member companies, subsidiaries, affiliates and any companies in which they have an interest and to compare any other information provided by you to us and/ or TM SPA GROUP. and its member companies, subsidiaries, affiliates and any companies in which they have an interest for the above purposes. If you do not wish to receive any marketing materials of any goods and/ or services unrelated to the Services, or do not wish us to disclose, transfer or use your personal data for the purposes described herein, please send your request together with your name, membership number and contact number in writing to the following address. Pursuant to the Personal Data (Privacy) Ordinance, you shall have the right to:
- confirm whether your data is being held by us;
- access the data held by us within a reasonable period;
- access the data held by us in a reasonable manner;
- correct any incorrect personal data.
Pursuant to the Ordinance, we have the right to charge you a reasonable fee for accessing any personal data. If you wish to access or correct your personal data, or acquire a copy of the data held by us, please send your request in writing to the following address:
TM SPA GROUP
Room 06-07, 20/F, CEO Tower, 77 Wing Hong Street, Cheung Sha Wan, Kowloon