E-Commerce Service Privacy Policy
Last updated: 5th January, 2024
1. We care about your privacy
We care about protecting and respecting your privacy. In order to serve you better and provide you with the best customer experience, we need to collect some personal data about you. This Privacy Policy will help you understand how we collect and use your personal data, who we share your personal data with, and how you can control the way your personal data is collected and used by us.
If you access or use our mobile and/or website e-commerce services (“E-Comm Service”), or register to create an account (“User Account”) to use the E-Comm Service, then this Privacy Policy will apply to you. If you do not agree with this Privacy Policy, please stop using our E-Comm Service, and do not apply for a User Account.
2. Who are we?
The Dairy Farm Company, Limited (“DFI”, "we", "us", “our”) operates the E-Comm Service, and is the data controller. The E-Comm Service enables customers to purchase products and services from us or from participating businesses (“Partners”). DFI is an affiliate of DFI Retail Group Holdings Limited (“DFIHL”), the ultimate publicly-listed parent company for the DFI Retail Group of companies (“DFI Retail Group”). Personal data we collect about you will be used in line with this Privacy Policy.
3. How do we collect data?
Your personal data will either be provided by you, or will be collected by us, DFI Retail Group or our Partners, or captured automatically when you access or use our E-Comm Service. For example, we collect your personal data when you create a User Account, browse or make purchases through the E-Comm Service, and when you send us emails.
4. Are you over 18?
The E-Comm Service is only intended for people over the age of 18, However, if you are under the age of 18, you may only use the E-Comm Service or apply for a User Account if this has been authorised by your parent or legal guardian and you have obtained their consent to use our E-Comm Service or apply for a User Account.
5. What information do we collect about you?
It may be necessary for you to provide us with certain personal data in order for you to use our E-Comm Service. We will let you know when such data is essential. All other personal data is up to you to provide or not, as you prefer.
(a) Your User Account
If you register for a User Account to use our E-Comm Service, some of the personal data we may collect about you includes:
- your telephone number, which we will use to complete your registration and send authentication codes via SMS to verify your identity.
- your full name, gender, month and year of birth, education history, marital status, email address. This information helps us provide you with better personalized recommendations for products and promotions, but is not mandatory. You may choose not to provide this information to us. Doing so will not affect the basic functions of the E-Comm Service.
- account status and activities relating to your User Account.
(b) When you make purchases using the E-Comm Service
If you use the E-Comm Service to make online purchases, some of the personal data we may collect about you includes:
- your product searches on the E-Comm Service, to provide autocomplete functionality or to provide you with information about products related to your search. Please note that your search results do not constitute personal data unless we combine it with other information about you which would allow us to identify you. If we do so, we will treat your search keywords as your personal data and store and secure your personal data as described under this Privacy Policy. We may also use this personal data to improve our services.
- your shopping preferences and choices with respect to favourites, purchases, follow/bookmarks and share functions offered on the E-Comm Service. While using the E-Comm Service, you may indicate your interest in certain products and brands, and share this information with us or our third party Partners through the E-Comm Service.
- your transaction history or payment details when you purchase anything through our E-Comm Service. When you place an order through the E-Comm Service, you will be required to provide the recipient’s full name, address and mobile phone number. The order form will set out your identification information (for example your photo or video, your name, telephone number etc.), the recipient’s address (or installation address for applicable products), the products/services you purchase, the order number, time of order, payment amount and payment method. We collect this information (“Order Information”) in order to complete and secure your transaction, to allow you to review your order, and to provide related customer services to you. We also use Order Information to verify your identity, confirm the transaction, process payment and complete delivery, assist you with queries about your order and provide other after-sales services. Further, we use Order Information to detect irregular activities to protect your transactions and User Account.
- your identity, Order Information and contact information in order to verify your identity when you request any after-sales services and dispute resolution services. If you send general enquiries or complaints to us, we may use your Order Information and any information you provide to our customer service representatives (including through any surveys) to provide services to you and make improvements to our services.
(c) When you visit our E-Comm Service
We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies (for example, we may use Google Analytics – to learn how Google Analytics collects and processes information, please visit: “How Google uses information from sites or apps that use our services”) to automatically collect information about:
- your visits to our E-Comm Service, such as your browsing history, how long you stay on our E-Comm Service, and how often you visit;
- your location information as provided by your mobile phone or other device when you interact with our E-Comm Service, including your IP address and general geographic location (including GPS location and WLAN access point, Bluetooth and other connectivity information); and the device that you use to browse our E-Comm Service (e.g. your operating system, type of device, browser type and version, language preferences, resolution, internet service provider ID (PLMN), mobile application crashes and other system activity, and third party sites you were using before interacting with our services).
You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.
(d) When we provide additional services
We may offer the additional services described below to better personalize products and services offered to you and improve your shopping experience, and request that you provide additional personal information by granting permission for the E-Comm Service to access your devices’ location information, camera/webcam, photo album, microphone and address book. If you do not provide the information described below, or revoke permissions granted, your use of the basic functions of the E-Comm Service will not be affected, however you may not be able to receive the additional services. Please note that your decision to revoke permissions will not affect information previously collected and used based on your prior authorization.
Personalized recommendation service based on location information. We collect your location information to determine your location to recommend goods or services available in your area. We will only collect information about your geographical location at specific points in time, and will not combine information about your location collected over different points in time to establish a trail of your movement. For example, we may recommend supermarkets or stores nearest to you.
Additional features based on cameras / webcams. You can use this additional feature to complete video shooting, picture taking, QR code scanning and other functions.
Additional features based on picture uploading. After granting permission for the E-Comm Service to access photo albums on your device, you may use this feature to upload your photos to change your avatar, communicate with customer service representatives, and for verification purposes. We may use the photos uploaded by you to identify goods or services you wish to purchase, or use comment so other messages containing photos uploaded by you.
Additional features based on voice technology. After granting permission for the E-Comm Service to access the microphone on your device, you can contact customer service representatives and interact with the customer service bot. We will record your conversation to respond to your customer service or dispute resolution requests.
(e) Other information
We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback) to better understand you and/or improve our services.
6. How do we use your information?
We will only use your personal data for the purposes set out below.
(a) Account administration
To help administer and maintain your User Account, including:
- creating and updating your User Account;
- verifying your identity;
- creating a single profile about you, including combining your information with any other personal data already held by us or any members of the DFI Retail Group;
- providing you with a log-in ID for your User Account to access our E-Comm Service;
- maintaining, updating, administering and processing a record of your activities on our E-Comm Service, including any purchases or orders made by you through our E-Comm Service for any products or services (“Orders”) and any points or rewards in relation to any rewards programme;
- completing transactions, including processing or facilitating payments;
- sending you updates about new features and benefits relating to our E-Comm Service;
- seeking your views and feedback via voluntary surveys and questionnaires so we can better understand you and/or improve our service; and
- enabling features that allow you to personalise your User Account on our E-Comm Service, such as bookmarking your favourite products or brands.
(b) Customer support
To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services, and to assist you with any delivery, refunds, returns or exchanges for any Orders.
(c) Marketing
While you use the E-Comm Service we will display marketing, offers and promotional materials ("Marketing Communications") within the E-Comm Service mobile App and website (including in the Notifications section of the E-Comm Service). We may also directly send Marketing Communications to you (“Direct Marketing”) if you choose to receive them. Please see the section on Direct Marketing below for more information on Direct Marketing.
(d) Personalisation
To create personalised Marketing Communications tailored to your interests and/or preferences, and to provide you with the best possible personalised customer experience in relation to our E-Comm Service and your User Account. We may also use data analytics tools to determine whether our or any DFI Retail Group members’ offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, and/or to customise the content and types of offers, products, and services that we present to you.
(e) Optimisation and improvements
We may use your personal data to understand and improve our E-Comm Service, or our Partners’ operations, or our DFI Retail Group members’ operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us, our Partners, and DFI Retail Group members to enhance services or products, develop new features and benefits, and amend business, marketing and strategic operations and plans.
(f) Legal and administration purposes
We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or as requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.
(g) Online purchase
To administer, process and manage your Orders, including any delivery, arrangement for collection, refunds, returns or exchanges.
7. Who do we share your information with?
To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymised or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your personal data) with third parties who may or may not be located overseas, as detailed in this section. By using our E-Comm Service, or applying for a User Account, you agree to allow us to share your personal data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your personal data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.
(a) Partners
If you create a User Account with us, your personal data may be shared with our Partners to facilitate the processing of payments and delivery, conduct risk analysis of your User Account, and related services and transactions, as well as for data analytics purposes in order to improve their operations, services or products.
Please be aware that our Partners may themselves directly collect personal data from you if you give it to them when you purchase any goods or services at their store, or if you register with them as a customer. The handling of your data collected by our Partners will be governed by the relevant Partner’s separate privacy policy (and not this Privacy Policy), and we are not involved or responsible for the collection and handling of such data.(b) DFI Retail Group
Your personal data may be transferred to any DFI Retail Group members for any of the purposes we have set out above. However, we will not provide your personal data to any DFI Retail Group member in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.
(c) Service providers
Your personal data may be shared with our or any DFI Retail Group members’ service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate our E-Comm Service, to conduct identity verification, data analytics/processing, process Orders and payments, arrange delivery, conduct marketing activities, to help aggregate and anonymise the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on behalf of our DFI Retail Group members, for any of the purposes set out above.
We only use trustworthy service providers, who are under an obligation to protect and maintain the confidentiality of your personal data and to only use your personal data in accordance with the purposes outlined in this Privacy Policy.
(d) Professional advisors and assignees
When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.
(e) Government and regulatory authorities
This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
(f) DFI Banners
DFI operates various DFI Banners as defined in the E-Comm Service Terms and Condition. Your personal data may be shared among the DFI Banners to facilitate the processing of payments and delivery, conduct risk analysis of your User Account, and related services and transactions as well as for data analytics purposes in order to improve DFI operations and our service offering to you.
8. Aggregated and anonymised data
Aggregated or anonymised data that does not include any personally identifiable information may be used by us, our Partners, our DFI Retail Group members or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.
9. Direct Marketing
If you have agreed to receive offers and promotions from us, we may use your personal data to send you Direct Marketing via email, app push notifications, SMS, post, telephone and such other direct means of communications that you may provide to us (“Contact Points”),in connection with:
the latest news, events, updates, offers, contests and promotions;
the latest news, events, updates, contests, promotions, offers, products, services and rewards offered by us including DFI Banners, our Partners, or our DFI Retail Group members, which relate to our E-Comm Service, reward programmes, retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications; and/or
any seasonal events, lucky draws and contests or other promotional activities.
Before providing you with Direct Marketing via your Contact Points, we will ask for your consent. You can choose at any time not to receive any Direct Marketing via your Contact Points by informing us of this choice or setting your communication preferences within the E-Comm Service and/or your mobile device. Please see the section on Your rights below.
10. Can our Partners and affiliates send you marketing materials?
We will not provide your personal data to our Partners or our DFI Retail Group members for them to send you marketing materials unless you allow this.
If any of our Partners or DFI Retail Group members wish to directly send you any Direct Marketing regarding their own products and services directly, then they must obtain your separate consent for this. We are not involved in any Direct Marketing done directly by our Partners or DFI Retail Group members that is unrelated to the E-Comm Service. However, we may send Marketing Communications to you on behalf of our Partners or DFI Retail Group members, subject to your consent and in accordance with Direct Marketing section above. If you agree to receive any Direct Marketing directly from our Partners or DFI Retail Group members, then please carefully read our respective Partners’ or DFI Retail Group members’ own privacy policies.
11. How do we keep your information secure?
We take the confidentiality and security of your information seriously. We take all reasonable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification. All transactions under the terms and conditions of this Privacy Policy are based on the encryption of data exchanged between you and us on our secure E-Comm Service.
12. How long do we keep your data for?
We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it on our servers.
If your User Account is inactive for three (3) months or longer, we reserve the right to remove your personal data from your User Account. If you subsequently attempt to log into your User Account, you may need you to re-verify your identify or re-enter your personal details to continue using the E-Comm Service.
13. Your rights
(a) Access and correction
You have the right to access and correct your personal data held by us, at any time, by sending an email to our Data Protection Officer at personaldata@dfiretailgroup.com.
In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.
(b) Opt-out of Direct Marketing
At any time, you can ask us to stop using your Contact Points to send you Direct Marketing, or you can customise how you would like to receive Direct Marketing from us. You can exercise your rights to do this by:
- changing your settings on your User Account; or
- changing your settings on your mobile device; or
- following the unsubscribe instructions in the Direct Marketing we send to you; or
- otherwise contacting us to inform us to stop using your Contact Points for Direct Marketing.
We will stop using your Contact Points to send you Direct Marketing in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration or servicing of your User Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you. In addition, while you use the E-Comm Service we will continue to display Marketing Communications within the E-Comm Service mobile App and website (including in the Notifications section of the E-Comm Service) – if you do not want to view any such Marketing Communications within the E-Comm Service, then you should immediately cease using the E-Comm Service and inform us to delete your User Account.
We are not involved or responsible for any marketing materials sent directly by our Partners or DFI Retail Group members that are unrelated to the E-Comm Service. If you would like to stop receiving any marketing materials from our Partners or DFI Retail Group members, then please contact them directly in order to unsubscribe from their mailing lists.
14. Online tracking technology
Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website or mobile application.
We use cookies and other similar identification technologies such as web beacons, ETags and pixel tags on our E-Comm Service, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our E-Comm Service; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our E-Comm Service; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our E-Comm Service and the websites of our Partners and DFI Retail Group members.
You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.
15. Links to other sites
Our E-Comm Service may contain links to other third party websites and applications, including those of our Partners and our DFI Retail Group members (“Third Party Sites”). We do not own or control, and are not responsible for, the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our E-Comm Service, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.
16. Information you provide about others
Please ensure that you are legally authorized to share with us any information that contains personal data of another person.
17. How do we manage updates to this policy?
From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by emailing you at the email address you provided us, and/or by posting a notice of these changes on our E-Comm Service. Following such update, if you continue to access or use the E-Comm Service, then the updated Privacy Policy is deemed to be agreed by you and will apply to you. If you do not agree with the updated Privacy Policy, please stop using our E-Comm Service.
18. How to contact us
If you have any questions or comments concerning this Privacy Policy, you can contact our Data Protection Officer at personaldata@dfiretailgroup.com.