Effective as of 1 October 2021
Just For You Company Ltd.
We value our customers and respect your privacy. Any information we collect about you is held with the utmost care. However, please note that although we take reasonable precautionary steps to protect your information, no website, Internet/mobile transmission or computer system is completely secure. Our Site/App/Interfaces may contain links to other third-party websites that are not operated by JUST FOR YOU, these linked sites or applications, such as Facebook or YouTube, are for your discretionary use and/or for understanding/acquiring our products, services. As they are not under JUST FOR YOU’s control, we are not responsible for the privacy practices or the content of these linked websites and online applications. If you choose to use these third-party links, we recommend you review their privacy policies.
a) products, services and business rendering through physical store(s) and/or
b) website(s), mobile app(s), e-messaging(s), e-forum(s) (individually or collectively referred to as the “Site”, or the “App”, or the “Interfaces”)
by Just For You Company Ltd (“JUST FOR YOU ”, “JFU”, "we", "our", "us")
It explains how we handle Personal Data and comply with the requirements of the Personal Data (Privacy) Ordinance ("PDPO") in Hong Kong (SAR).
(a) relating directly or indirectly to a living individual;
(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
(c) in a form in which access to or processing of the data is practicable;
1. Collection of Personal Data
1.1 We may collect Personal Data from you through various means, including but not limited to instances when you:
a) provide your Personal Data through our Site/Interfaces to register for and create an account;
b) download or access the App;
c) agree for the Site or the App to process your information;
d) apply for a membership or access your account under our JFU Beauty Pass Loyalty Program (“JFU Beauty Pass”);
e) take part in a promotion or other Site features;
f) receive product or services information including but not limited to marketing communications;
g) respond to promotion activities including but not limited to product or service reviews;
h) raise enquiries to or interact with our staff through physical store visits, emails, Site, App or Interfaces; and/or
i) make purchases through physical store(s) or Site/Interfaces.
1.2 We may also use the following technologies to automatically collect information about your activities as it incurs on our Site, App and/or other Interfaces:
Analytical tags, Clear pixels (no info on paragraph 8), Cookies, Flash Cookies, Geo-location marks, Pixel tags (no info on paragraph 8), Web beacons, Web server logs
Please refer to paragraph 8 for more information about these Mobile Technologies and how they operate to collect information about you.
1.3 You have no obligation to provide any of the Personal Data requested by us. However, it may be the case that if you do not provide the requested Personal Data, we may not be able to provide you with certain products and services.
2. Purposes For Collection, Use, Processing and Disclosure Of Personal Data
JUST FOR YOU will/may collect, use, process and/or disclose your Personal Data for one or more of the following purposes and/or any other directly related purposes:
2.1 administering, processing or dealing in any matters relating to your use or access to the Site. Such as for the following functions, without limitation:
gain access to or sign in to the Site, using your login credentials of social media or internet portal platform(s) or site(s). Or, use any online or mobile communications/networking features such as browser push tags, plug-ins or widgets through our Interfaces.
It may result in your information or Personal Data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may post product you “liked” on their platform.
2.2 tracking your use of the Site to assist us to provide you with a seamless, consistent, and personalized experience, to make informed decisions, and for other legitimate purposes;
2.3 opening a customer, use, membership account with us, administering your account details, activity and/or transaction histories with us through physical store(s) or any of our digital Interfaces;
2.4 processing or fulfilling your orders, requests for information, and/or your subscription to our products or services;
2.5 administering, facilitating your customer relationship with us. Your consent allows us to, without limitation,
a) provide marketing, advertising, promotional information to you (such as contests, gamification, social events) as our potential or existing user, customer, and/or member;
b) respond to your orders, reservations, enquiries, complaints, suggestions;
c) communicate with you by phone/voice call, text message, fax/email/postal mail, other electronic transmissions or technology such as push/in-app/geo-location notifications.
You can always opt-out from promotional/marketing contacts;
2.6 disclosing or sharing suggestions, comments, feedback (collectively “Feedback”) you provide us in any formats (including, but not limited to, audio, video) through our Interfaces, physical store(s), or other third-party social media platforms (such as Facebook, Twitter, Instagram), with public for JUST FOR YOU’s publicity or promotion purposes. Should you choose to provide your Feedback to us, you agree that we can, at our discretion:
a) disclose your name together with your Feedback;
b) publish, post or share your Feedback on public media, including, without limitation, newspaper, the Web, our (including our affiliates’) annual reports; and/or
c) incorporate your Feedback as part of Just For You ’s marketing collaterals/materials or corporate video.
In other words, please do not provide us your Feedback if you do not wish for it to be disclosed to the public. If you want your Feedback not to be disclosed to the public, please use emails to share your Feedback with us and quote “Confidential” in the subject. Our Customer Department email address is firstname.lastname@example.org
2.7 where you have provided your consent to us to disclose your “Beauty Profile Personal Data” (BPPD) , and whether such consent was given through the Interfaces, physical store(s) or otherwise, you will receive our email confirming our notification of your consent. You can withdraw your approval at any time by email. Upon receiving your request, we will stop sharing your BPPD in our physical store(s) and our Interfaces. Otherwise, your consent will allow us, from the third week onward after our said email confirmation, to disclose or share your BPPD with other users of our Site or the public. We may share through our Interfaces or any other media (whether written in print, text/audio/video in electronic platforms) at our discretion. (“Beauty Profile Personal Data/BPPD” includes your name, skin type/ concerns, eye colour, hair colour/ type and other similar information you provide) Please note that once the BPPD is shared and released, it is not possible to remove its content from the public media footprint (whether print or electronic media), even after we stopped sharing them;
2.8 processing your accounts, order payment, order fulfillment. Should you instruct us to deliver your order to a third party and/or your order fulfillment needs to be made through a third-party delivery service we engage, you agree for us to disclose necessary Personal Data to the respective third-party recipient/delivery service. That means your name, contact details and/or other delivery-related information would be featured on the cover of the parcel or delivery related document(s), which third parties could view during the order fulfillment;
2.9 carrying out user/customer due diligence or other screening measures (including background checks) in accordance with applicable legal or regulatory obligations required by Hong Kong (SAR), other jurisdictions or relevant regulatory bodies/authorities to combat money laundry, financial or other criminal offences, investigate/prevent fraud, alleged unlawful activity/misconduct, and/or deal with complaints. This terms applies to legal/audit advice or government/regulatory body instructions made to us and/or to our affiliates/associated companies. In other words, we may/will disclose your Personal Data to such parties upon their requests or direction, with which we are expected to comply;
2.10 facilitating external audit(s) or internal audit(s) of JUST FOR YOU’s business or upon reasonable requests of the business of our affiliates/related corporations;
2.11 conducting research, surveys, market surveys, data analysis, customer profiling/development activities to improve our products/services/facilities, understanding of your interests and enhancing future interaction/communications. We may/will, without limitation, invite you to participate in surveys or interviews by way of email, postal mail, phone calls or through our Interfaces. You can always opt-out of these invitations.
2.12 storing, hosting, processing, backing up (whether for disaster recovery or otherwise) of your Personal Data in a data/technical infrastructure, including, but not limited to, computer databases and servers set within and/or outside Hong Kong SAR. Your consent allows us to store and process your information with third-party IT agents or contractors strictly for our conducting our business in the aspect of, without limitation, the said marketing, research, audit, order fulfillment effort.
We will take reasonably secured measures to store data, without limitation, in password-protected/fire-wall-protected hardware, software and/or iCloud. We also require our service providers to adhere to strict privacy guidelines and not use your Personal Data for unauthorized purposes.
2. Children’s Privacy
We do not intend to directly transact through the Site/Interfaces with anyone we know to be under 18 years olf. If you are under the age of 18, you should use the Site/Interfaces only with the involvement of a parent or adult guardian and should not submit any Personal Data to us. By providing any Personal Data to us, you declare that you are over the age of 18.
3. Sharing and Disclosure of Personal Information
Your Personal Data will be shared with our related corporations that offer related products and service, should you opt-in to such agreement. Otherwise, we will not share your information with other third parties except for the specified Purposes listed above.
For the avoidance of doubt, the PDPO does not apply to anonymized data without identifying individual information. It means organizations that comply with PDPO requirements can freely handle your anonymized data without your approval. For example, they may share anonymized aggregate information about their customers with advertisers and marketing partners. However, JUST FOR YOU decides and promises NOT to share any of our customers’ anonymized data to any third parties for commercial uses to further safeguard our customers’ privacy. We want to remind our customers that a third party, such as web browsers you use, may collect anonymized information when you use our Interfaces (or any websites you visit, for that matter). It is not a situation JUST FOR YOU can control; it is up to your own security settings. We want to emphasize again that we uphold our part to protect your information on our end.
4. Provision Of Third-Party Personal Data By You
To the extent permitted under the applicable laws, should you provide JUST FOR YOU with Personal Data of individual(s) other than yourself, you represent and warrant to JUST FOR YOU and you as a results of this confirm that :
(a) permit you to disclose the individuals’ Personal Data to JUST FOR YOU for the Purposes; and
(b) permit JUST FOR YOU to collect, use, disclose and/or process the individuals’ Personal Data for the Purposes, as set out in paragraph 2 above;
4.2 any Personal Data of individual(s) that you disclose to us is accurate; and
4.3 you are lawfully acting on behalf of the respective individual(s), and that you have the authority of him/her/them to provide us with his/her/their Personal Data, also to your knowledge, we can collect, use, disclose and process the respective Personal Data for the Purposes.
5. Request For Access And/ Or Correction Of Personal Data
5.1 You may request to access and/or correct your Personal Data currently possessed by us by submitting a written request. We will need enough information from you to ascertain your identity before completing your request. Please submit your written request to email@example.com
5.2 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant Personal Data within 30 days, in compliance with the PDPO. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. In any event within 40 days after receiving your data access request, we will inform you in electronic/written communications that we are unable to comply with your data access request with respective reasons, or comply with your data correction request to the extent, if any, that we can comply with the same; or as soon as practicable after the expiration of the initial 40 day period, fully comply with your data access request. Please be aware that the PDPO exempts certain types of Personal Data from being subject to your access and correction request.
5.3 We may also charge you a reasonable fee for the handling and processing your requests to access your Personal Data. If so, we will provide you with a written estimate of the fee. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
6. Request To Withdraw Consent
6.1 You may withdraw your consent for the collection, use and/or disclosure of your Personal Data possessed by us or under our control by submitting your request to firstname.lastname@example.org
6.3 Please be aware that your consent withdrawal could raise certain legal consequences. Depending on the circumstances, it may mean that we cannot fulfill the transaction you entered into with us or provide you service or information you requested, without limitation.
7. Managing and Protecting Your Personal Data
7.1 We endeavour to take all reasonable steps to safeguard your Personal Data and take appropriate technical and organizational measures to prevent unauthorized access and data breach of your information.
7.2 We rely on the information you provide us to form some of our product and/or service offerings/renderings to you. A reasonable effort will be taken to keep the information you provide to us is accurate and complete. It means you will need to update us with any changes in your Personal Data or information you had initially provided us. We will take reasonable precautions to remind you to provide a respective update on appropriate occasions, but it is your responsibility to keep us informed and updated with information we request from you and/or deemed important by or to you. We will not be responsible for relying on inaccurate or incomplete Personal Data provided by you, or arising from you not providing updates of changes in your Personal Data possessed by us.
7.3 For your convenience, our App and/or our Interfaces includes functionality allowing you to remain logged in to the App so that you do not have to re-enter your password each time you access the App. IF YOU CHOOSE TO REMAIN LOGGED IN, YOU SHOULD BE AWARE THAT ANYONE WITH ACCESS TO YOUR MOBILE DEVICE WILL BE ABLE TO ACCESS AND MAKE CHANGES TO YOUR ACCOUNT AND MAY BE ABLE TO MAKE PURCHASES THROUGH YOUR ACCOUNT. For that reason, if you choose to remain logged in to your device using the App, we strongly recommend that you enable the “Passcode Lock” security feature on your mobile device to protect against unauthorized access to and use your mobile device and your App account. Please also notify us as soon as you suspect any unauthorized use of your account or any password leaks. You agree that you will be responsible for all transactions made to us or interactions made with us by your account, including unauthorized usage at your end.
7.4 We will either destroy or anonymize your Personal Data when it is deemed reasonable to assume that the purpose for which the data collected is no longer being served and the retention of the data is no longer necessary for any legal or essential business reasons directly related to the Purposes.
8. Cookies and Mobile Technology
8.1 Analytics Tags. We may use analytical tags to analyze what our clients’ browsing and the effectiveness of our advertising or other features. They help customize your browsing and shopping experience with us. We may combine Personal Data you provide to us, together with other Personal Data (such as purchase history) and information collected through analytical tags (and/or other tracked links). We may work with third-party contractors to help us track, collect and analyze this information, but they are prohibited from using this information for any other purpose.
8.3 Geo-Location Technologies. Geo-location technology permits us to determine your country/region. Users can manually input location to enable mobile devices to send us precise country/region information or receive mobile notifications. If you select “Do Not Allow/Enable,” you opt-out of having the App/Interfaces to send you specific notifications or confirmations. If you choose “OK/Enable”, the App/Interfaces can communicate with your mobile device. It may collect data guided by this Policy, including, but not limited to, information about your mobile device such as make, model, operating systems, on/off settings of location services/Bluetooth/wifi, notifications/application permissions or other similar information. If any, uour JUST FOR YOU activities may also be captured, such as membership status, product wishlist, purchase history, feedback and location coordinates near our physical stores. Your consent will also allow us to send you targeted offers based on your country/region. You can always opt-out of sharing country/region data with the App by changing your device settings.
8.4 Web Beacons. Web beacons are small graphic images on web pages or in emails that can be used for recording pages and advertisements clicked by users, tracking the performance of e-marketing campaigns or other similar functions.
8.5 Web Server Logs. Web server logs are records of activity created by your computer or mobile device when you browse web pages. For example, it may record the web link you clicked or keywords you searched. It may also collect other browsing information, including your IP address and your browser’s cookies.
8.6 We utilize third-party software to create a more personalized experience when you use our Interfaces, for example, showing you relevant products, services, in-store offers and/or social activities.
8.7. To register through our Interfaces, you must provide your name and a valid email address and set up an account password. It is your responsibility to keep your password safe at your end.
10. Problems, queries or complaints
10.2 You may also contact us at the said email address if you have any complaint about how we handle your Personal Data. We will investigate your complaint and use reasonable endeavours to respond to you in writing as soon as possible.