PRIVACY POLICY STATEMENT

We are committed to safeguarding your privacy and ensuring that your Personal Data is protected. This Privacy Policy Statement explains the types of Personal Data we collect and how we process and protect that data.

We shall keep your Personal Data confidential and shall ensure that our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of your Personal Data comply with the laws of Hong Kong.

This PICS is issued pursuant to the PDPO in relation to the operation of our online businesses by ESD Services Limited (referred to as “we”, “our” or “us”).
1. This PICS is last updated on the Effective Date.

2. Definitions

Under this PICS, unless the context otherwise requires, the following words and expressions shall have the following meanings:

2.1.	“Database” means the database of our Members’ Personal Data.
2.2.	“Effective Date” means 23 July 2024.
2.3.	“Member” means a member of our communities.
2.4.	“Our Apps” mean the mobile applications operated by us.
2.5.	“Our Customer Hotline” the hotline number(s) is available on Our Website or Our Apps.
2.6.	“Our Affiliates” means companies within CK Hutchison Holdings Limited.
2.7.	“Our Partners” means other merchants who offer products, services, activities, discounts, targeted offers and rewards to our Members, or advertise with us.
2.8.	“Our Shop” include health.ESDlife and other marketplace formats that we may operate from time to time (whether online or offline).
2.9.	“PDPO” means the Personal Data (Privacy) Ordinance (Cap.486).
2.10.	“Personal Data” has the meaning ascribed to it under the PDPO.
2.11.	“Our Websites” all websites operated by us and including but not limited to www.esdlife.com and www.healthyd.com.

3. In order for you to become a Member and to enjoy our various products and services, it is necessary for you to provide us with certain essential Personal Data as indicated at the time of collection.  We may also ask for other information which helps us to offer you tailored products and services that we think may be of interest to you.  The types of Personal Data we may collect include, but not limited to, your name, address, email, telephone number, date of birth, gender, age, wedding and/or anniversary dates, social media account, browsing and shopping preferences, hobbies and interest.

4. We shall have the right to collect, hold, process and/or use, the Personal Data in the Database in each case for the purposes as set out in, and in accordance with, this PICS.  Your supply of the Personal Data to us is voluntary. If you are unable or unwilling to provide us with complete and correct Personal Data, we may not be able to provide or continue to provide our products and services to you.

5. You agree that the Personal Data you provide to us and all information relating to the use of Our Apps and/or Our Websites may be used and retained by us for:

5.1. processing your application as a Member;

5.2. providing you with our services and/or products;

5.3. the normal management, operation, and maintenance of Our Apps and/or Our Websites and/or membership/loyalty programs;

5.4. providing you with regular communications from us with details of our  business and/or membership/loyalty programs and relevant benefits;

5.5. providing you with goods or services which you have requested;

5.6. processing your order for purchases at Our Shop, including verifying your payment details/status;

5.7. carrying out prize draws, games or competitions which you have entered;

5.8. carrying out data sorting and analysis to enable us to better understand your characteristics and buying behaviour and to provide other services better tailored to your needs, and to assist us in selecting goods or services that are likely to be of interest to you;

5.9. designing new or improving existing services provided by us, Our Affiliates and/or Our Partners to you;

5.10. investigation of complaints, suspected suspicious transactions, and research for service improvement;

5.11. prevention or detection of crime;

5.12. disclosure as required by laws, regulations, courts or regulatory authorities;

5.13. performing research, statistical analysis or surveys, whether verbally or in writing; and

5.14 analyzing trends, usages and behaviors analysis (whether on an individualized or aggregated basis), which helps us better understand how our collective user base consumed and the underlying commercial activities conducted.

We will only retain the Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for.

6. With your consent or indication of no objection, we will use your Personal Data for direct marketing to you (whether by post, email, phone, SMS, WhatsApp, social media or other media whether now known or available in the future) in relation to offers and promotions from:

6.1. us, our membership/loyalty programs, Our Affiliates and/or Our Partners;

6.2. other companies within the CK Hutchison Holdings Limited group of companies in relation to telecommunications goods and/or services, e-commerce services (including trading platforms and online auctions), payment services, financial, investment and insurance products and services, hotel and tourism services and real property and related services;

6.3. third party merchants that we cooperate with to provide benefits to you in relation to the following types of products or services:
a) retail goods or services;

b) financial, investment, insurance, banking and credit cards;

c) transportation, travel and accommodation;

d) sports, leisure, recreation and entertainment;

e) telecommunications products and services;

f) e-commerce (including trading and payment platforms and online auctions).

7. We may disclose and transfer (whether in Hong Kong or abroad) your Personal Data to any of the following parties for any of the purposes set out in clause 5:

a) Our Affiliates;

b) our agents, contractors, business partners or third party service providers under a duty of confidentiality to us who provide administrative, data processing, data analysis, research and marketing, distribution, telecommunications, professional or other similar services to us;
c) our actual or proposed assignees or transferees of our rights with respect to your Personal Data in connection with a re-structuring of our business, and/or merger (as between us and a third party), sale, or transfer (whether of assets or shares, in whole or in part); and
d) our professional advisors.

8. We use cookies and similar technologies to collect data about you when you visit the Our Websites and our other related websites (“Sites”). Cookies are files that store information on your computer hard drive or browser that mean we can recognise that you have visited our Sites before. We use cookies to give you the best possible experience on our Sites, by evaluating the use of our Sites and reviewing your browsing and shopping habits, personalizing your website experience, evaluating website activity on our Sites and generally making our Sites easier to use.

9. The types of data we may collect from you when you visit the Sites include:

- information about the type of browser you use;

- details of the web pages you have viewed;

- your IP address;

- the hyperlinks you have clicked; and

- the websites you visited before arriving at our Site.

10. You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but to do so you may not be able to utilize or activate all of the functions and services of our Sites.

11. You have the right to:

11.1. check whether we hold any of your Personal Data;

11.2. access your Personal Data held by us;

11.3. require us to correct any Personal Data which is inaccurate;

11.4. ascertain our policies and practices (from time to time) in relation to Personal Data and the type of Personal Data held by us;

11.5. opt out from receiving direct marketing materials from us at any time; and

11.6. request for the Personal Data to be deleted.

Any request in relation to the above shall be in writing (sent by post or email) and addressed to:

Marketing Department

Unit 1209, 12/F, Two Harbourfront, 22 Tak Fung Street, Hunghom, Kowloon, Hong Kong

Email address: marketing@esdlife.com

For enquiries, please contact Our Customer Hotline.

For the avoidance of doubt, if you decide to withdraw a 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 withdrawal of consent.

12. In accordance with the PDPO, we have the right to charge you a reasonable fee for the processing of any Personal Data access request.

13. We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data. However, due to the inherent open nature of the Internet, we cannot guarantee that communication between you and us or the Personal Data will be completely free from unauthorized access by third parties such as hackers.

14. Our Websites may contain hyperlinks to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites.  Once you have left Our Websites, we cannot be responsible for the protection and privacy of any information which you provide.  You should exercise caution and look at the privacy statement for the website(s) you visit.

15. We may also offer you the opportunity to use your social media login. If you do so, please be aware that you share your profile information with us depending on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.

16. Nothing in this Privacy Policy Statement shall limit your rights under the PDPO.

17. If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.

18. This Privacy Policy Statement shall be governed by, and construed in accordance with, the laws of the Hong Kong Special Administrative Region.

19. We may change this Privacy Policy Statement from time to time by posting an updated version on the Our Websites and Our Apps without prior notice.