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Privacy Policy

JP Malls, a wholly owned subsidiary of Pearl Gray International Limited  (collectively "we", the "Company", "JP Malls" ) respect the privacy rights of visitors to the Company’s website and of individuals who participate in, access or sign up to any of the Company's services, activities or online content (collectively referred to as "Services"). We endeavor to ensure that all our collection, transmission, storage and usage of personal data shall be carried out in compliance with the Personal Data (Privacy) Ordinance, Cap 486 of the laws of the Hong Kong Special Administrative Region ("PDPO").

 
The term "personal data" shall have the meaning ascribed to it by PDPO.
 


PURPOSE OF COLLECTION AND USE OF PERSONAL DATA 


You need not supply any personal data in order to access the Company’s website. When you participate in, access or sign up to any of the Services, personal data is collected from you to enable us to provide you with the Services. You may decline to provide us with the requested personal data, but in such case we may not be able to provide the Services to you. By submitting your personal data you consent to the use of that data as set out in this Privacy Policy Statement.
 
Personal data collected from you may be used by the Company for:
 
•    identifying you and any accounts you hold with us
•    enabling the provision of the Services to you 
•    conducting identity verification and/or credit checks  
•    processing of payment instructions or collection of amounts outstanding from you in relation to the provision of the Services
•    order processing, billing and fulfilment 
•    direct marketing of the Services 
•    direct marketing of the products and services of the Company’s business partners 
•    designing services for you 
•    conducting research, statistical analysis and behavioral analysis
•    conducting program viewership survey and analysis
•    customer profiling and analysing your purchasing preferences
•    customising the Company’s website and its content to your particular preferences
•    provisioning of customer services 
•    handling your complaints and account enquiries
•    fraud prevention and detection
•    auditing
•    making such disclosures as required by applicable laws, rules and regulations 
•    any other purposes directly related to the purpose for which the personal data were originally collected
 


TYPES OF PERSONAL DATA COLLECTED 


Types of personal data collected by the Company may include:
 
1.    Your personal information and contact information such as your name, gender, date of birth, identity card number, telephone number, social media contact, email address, residential address, mailing address, and billing address;
2.    Your business information such as company name and business title;
3.    Your account details, including first and last 4 digits of credit card account numbers, or user accounts; 
4.    Your household income range, and personal interest; and
5.    IP address, real-time geographic location data, browser settings, browsing records, and/or other Internet log information of your computer or mobile device.
 



CONFIDENTIALITY, DISCLOSURE AND SECURITY OF PERSONAL DATA 


The Company does not trade your personal information and contact information for gain without your written consent. All personal data collected and held by the Company will be kept confidential, but where disclosure is necessary for the Company to comply with any statutory obligations or requirements, or for the Company to provide the Services to you or to carry out the original purpose, or a directly related purpose, for which the personal data were collected, those data may be provided to the following parties (whether within or outside Hong Kong):
•    Competent court of law, law enforcement agencies, or other governmental or statutory authorities, institutions or organisations; 
•    Company’s associated companies, contractors, agents, sellers or suppliers of the goods/services, or other service operators, who are involved in the sale and marketing, administration or provision of the Services; 
•    Any other person under a duty of confidentiality to the Company including a member of its group of companies, IT consultants, data processors, auditors, accountants, or lawyers, which has undertaken to keep such information confidential; and 
•    Banks, financial institutions, credit card issuing companies or debt collection agencies. 
Any questions, comments, suggestions or information other than personal data sent or posted to our website, or any part of the site by you will be considered as voluntarily provided to the Company on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development and marketing of services and to meet user needs. 
 
All reasonable efforts are made to ensure that any personal data held by the Company is stored in a secure and safe place.
All personal data which we collect is kept confidential to the best of our ability. You will appreciate however, that we cannot guarantee the security of transmission. 
 


TRANSFER OF PERSONAL DATA OUTSIDE HONG KONG 


If necessary, the Company may transfer the personal data to places outside the Hong Kong Special Administrative Region for carrying out the purposes, or the directly related purposes, for which the personal data were collected. All the transfer of those personal data will be carried out in compliance with the requirements of the PDPO.
 


RETENTION OF PERSONAL DATA 


Unless there is a mandatory legal requirement for us to keep your personal data for a specified period, we will only retain your personal data for as long as is necessary to fulfill the purpose for which the personal data were originally collected.
 



DIRECT MARKETING 


The Company intends to use the personal data collected from you in direct marketing and the Company requires your consent for that purpose. Your name, telephone number, email address, contact address, social media contact, products and service portfolio information, transaction pattern and behavior, browsing records, content viewing habits, and personal interest held by the Company may be used by the Company in direct marketing of the Services which may be of interest to you.
We may contact you by mail, telephone, social media, SMS, text/picture/video message, fax, email. If you prefer not to receive any direct marketing communications from us, you can opt out at any time by updating your preferences through your registered account or a unsubscribe link provided. Upon receipt of your request, we shall cease to so use your personal data without charge to you.
 



USE OF COOKIES 


A cookie is a small text file which is placed onto your computer (or other electronic device) when you access the Company’s website. We use cookies on our website to:
 
•    recognise you whenever you visit this website
•    obtain information about your preferences, viewing and browsing behavior, online movements and use of the Internet
•    keep track of the items stored in your shopping basket and take you through the checkout process
•    carry out research and statistical analysis to help improve our Services and to help us better understand our visitor and customer requirements and interests
•    target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests
•    make your online experience more efficient and enjoyable
•    enable tighter security
 
The information we obtain from our use of cookies may not contain your personal data. Although we may obtain information about your computer or other electronic device such as IP address, browser settings, browsing records, and/or other Internet log information, this may not be able to identity you personally. To the extent that non-personal data is combined with personal data, we treat the combined data as personal data for the purposes of this Privacy Policy Statement. In certain circumstances we may collect personal data about you, but only where you voluntarily provide it by completing an online form, or where you purchase goods from our website or use the Services. 
 
If you want to disallow the use of cookies, you can do so on your own web browser. If you disable cookies, you acknowledge that you may not be able to use some of the functionality of our website.



ACCESSING AND UPDATING YOUR PERSONAL DATA


We prefer to keep personal data of the users who create an online account on our Websites accurate and up to date. To do this, we provide you with the opportunity to update or modify your personal data. Just sign into your account with your email address and password, and you will see an overview page where you can update your information. You may also email to us if you think that personal data that we hold about you needs to be updated.
Upon your written request, we will inform you of the personal data relating to you that we hold and the use and general disclosure of your personal data. We will also give you a copy of the personal data we have retained. There may be a minimal charge for accessing your personal data.
Please send your written request to the email address or postal address provided under the "Questions About Privacy" section below. In your written request, please include your name, address, phone number, and email address so that we may verify whether we retain any personal data about you.



UPDATES TO PRIVACY POLICY


As we continue to offer our customers new and different types of content and services, we may revise this privacy policy to reflect the changes that we have made to our information collection, use or disclosure practices. We will notify you that we have revised our privacy policy by placing a notice on our Websites. Should there be a material change to our information collection, use or disclosure practices, it will be applied only to information collected on a going forward basis.



QUESTIONS ABOUT PRIVACY


If you have any questions, comments or concerns regarding our privacy practices, please email us at JPMalls.com@google.com