We at Distinctive Action Limited also known as Invisible Company (collectively "we", the "Company”) value your personal data and privacy. We pledge to comply with the requirements of all applicable data protection laws and regulations in relation to personal data protection.
The terms of this privacy statement (“Privacy Statement”) may be updated, revised, varied and amended from time to time as we deem necessary and the most current version will be the one available on our website www.invisible-company.com ("Website"). We will obtain your consent for changes to the terms of this Privacy Statement if such consent is required by applicable law. Any reference in these terms to "we", "us" and "our" is a reference to the Company. Please read this Privacy Statement carefully to understand how we will handle your personal data.
Unless your express consent is required by applicable law, by providing us with your personal data, you are accepting the terms of this Privacy Statement and consenting to our collection, retention, disclosure and use of your personal data, including the transfer of your personal data overseas, as specified in this Privacy Statement. Further, we will only use and transfer your data for direct marketing purposes as specified in this Privacy Statement. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Statement as updated from time to time on our Website. Any amended Privacy Statement will be posted on our Website. By continuing to use our Website, place orders on our Website and/or use any of our services after the Privacy Statement has been amended, you hereby agree to be bound by the terms of such amended Privacy Statement. You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.
In the event of any discrepancy or inconsistency between the English and other local language versions of the Privacy Statement, the English version will prevail.
How and when do we collect personal data and what do we collect?
- Sources of personal data
The types of personal data that we collect will depend on the nature of your dealings with us. We may collect personal data from you by the following channels:
- when you purchase goods and services from us or use services or products offered by us;
- when you use the Website, other websites operated by our affiliates (if any) or our official page on social media sites;
- when you correspond with us;
- when you interact with us on our social media, including our Website and accounts on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest, and Google+ (collectively, “Social Media”), such as liking our posts, commenting on our posts, private messaging us on our Social Media
- when you register for membership of any of our customer or sales and marketing programs owned, managed, and/or controlled by us;
- when you register to use or enter information into, any of our interactive services (for example, our blogs and forums); and
- when you register to attend any of our events.
- Types of personal data we collect
We may collect from you the following information which may contain personal data as defined under applicable data protection laws and regulations:
- account or order registration information, including your name, gender, date and month of birth, age group, title, contact numbers (telephone, fax, mobile), postal address, and email address;
- billing information, transaction, and credit card information (if you make a purchase from us);
- shipping information (if you make a purchase from us);
- records of correspondence between you and us; and
- optional information about your marital status, occupation, personal monthly income, personal or professional interests, demographics, experiences with our products and services, and contact preferences in order to provide you with further information about our products and services.
All information we collect about you may be combined with other information we hold about you.
Please take note that most of the goods and services, information, and sales and marketing materials provided on our Website or by other means are not directed towards minors as defined by applicable laws in your jurisdiction. If you are a minor under applicable laws in your jurisdiction, you must obtain the consent of your parent or guardian before providing us with any of your personal data.
- Sources of personal data
How do we use personal data?
We collect, retain and use personal information about you for the following purposes:
- Process your order for our product and services, process or collect your payment for the order;
- Deliver or perform the products or services, process or collect your payment for the order;
- Provide you with supporting services and functions related to your user account, such as saved items in cart, wish list, brand or product notifications;
- comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law;
- ensure our Website function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Website;
- to offer you with our products and services, including sending you marketing and promotional materials, event information and e-shopping items relating to our products and services;
- to conduct joint promotion events including notifying you of sales and marketing offers and sending you sales and marketing materials relating to the promotional offers or events of our affiliated, associated, related, subsidiary companies and/or companies under the common control of our ultimate holding company and independent commercial entities ("Business Partners"), which may be located outside your jurisdiction;
- to process your application for membership (if any) under any of our programmes and maintaining and managing your membership (if any);
- to provide you with rewards, promotions, lucky draws, giveaway, initiatives, vouchers or services under any of our programmes;
- to handle and follow up with customer service calls, enquiries and complaints;
- to send you administrative notices and communications relevant to your use of our Website and to respond to your enquiry or request;
- to perform research or statistical analysis or tracking in order to improve our goods and services and for sales and marketing purposes;
- to verify your identity and your eligibility to participate in our programmes;
- to obtain statistics about users of our Website to analyse site usage in order to help its further development;
- manage the administrative and business operations of the Company and complying with internal policies and procedures;
- improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
- to make such disclosures as required by law.
You are not obliged to provide the personal data as may be required by us. However, we may not be able to provide you with our products and services or our Business Partners' information, sales and marketing materials if you do not provide us with the requested data.
Your receipt of marketing materials
As noted above, we may, from time to time, send you sales and marketing materials and information regarding our or our Business Partners' products and services as stated in paragraphs 2.1 and 2.2 based on your name and contact details that you have provided to us. However, we will not use your personal data unless we have received your consent. Suitable measures are implemented to make available to you the option to "opt-out" or “opt-in” as required by applicable law of receiving such sales and marketing materials at the time you provide us with your personal data.
Please note that you can object to such use of your personal data at any time. If you do not want us to retain your personal data for this purpose, you should do so by choosing the "opt-out" option in the relevant membership subscription or registration form, or by choosing to unsubscribe from any marketing email we have sent to you, or by emailing us at email@example.com, specifying that you wish to "opt-out".
Will your personal data be given to other persons?
We do not sell, rent or trade your personal data to or with third parties including our Business Partners. However, your personal data may be disclosed or transferred by us to the third parties described below:
- third party suppliers of goods and services (whether in your jurisdiction or abroad) engaged by us to assist with providing you our services (including marketing analysis and research, data entry, management of our customer database, distribution of our sales and marketing materials, products rewards, vouchers and customer service) ("Third Party Service Providers"). Our Third Party Service Providers are under a duty of confidentiality and contractually bound to use your personal data in connection with the purposes specified at paragraph 2 above, and not for their own purposes (including direct marketing); and
- competent court of law, law enforcement agencies and/or regulatory bodies for compliance with applicable laws and regulations and protection of our legal rights.
Accuracy and Retention of your personal data
We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.
Personal data is stored for the duration required for the processing purposes for which it was collected, except where retention for a longer duration is required by law. We will not keep personal data longer than is legally permitted pursuant to applicable data protection laws and regulations. We will purge unnecessary personal data from our system in accordance with our internal procedures.
Protection of your personal data collected is a priority for us. We will always strive to ensure that your personal data will be protected against unauthorised access. We are based in Hong Kong. Your personal data may be accessed by us or transferred by us to and accessed by the third parties listed in paragraph 4, in Hong Kong or elsewhere in the world. Such personal data are only accessible by us or the personnel of the third parties listed in paragraph 4 for the purposes listed in paragraph 2, who will be instructed to observe confidentiality duty and the terms of this Privacy Statement when accessing such personal data.
Although we will do our best to protect and secure your personal data, we cannot guarantee the security of your personal data transmitted over the internet or any telecommunications networks.
- Links to other websites
To provide you with more information, our Website may provide links to other websites. Your personal data may be collected on these other websites when you visit them or make use of their services. Where and when you decide to click on any advertisement or hyperlink on our Website which grants you access to another website, your personal data may be exposed in these other websites.
This Privacy Statement is only applicable to our Website and we are not responsible for the third party websites or for any personal data you submit to such other websites via our Website. Please ensure that you read the privacy policies of such other websites.
Data access and correction
You have the right to, at any time, request access to, make a copy of, and request us to make correction of, or demand the cessation of the continued collection, processing, and use, or to delete your personal data stored in our records. To exercise your rights, please email us at firstname.lastname@example.org.
In the event that you wish to exercise your right as set out above, we may request you to provide personal details in order to verify your identity. We will endeavour to respond to your request in accordance with requirements under applicable data protection laws and regulations, and we may charge you a reasonable fee for complying with your access request as permitted under applicable laws.
If you have any queries about our Privacy Statement, please email us at email@example.com
This Privacy Statement and your use of this Website shall be governed in all respects by the law of Hong Kong Special Administrative Region (“Hong Kong”), and the parties hereto irrevocably submit to the non-executive jurisdiction of the Hong Kong court.
- Nothing in this Privacy Statement shall limit your rights under applicable laws.
- The provisions of this Privacy Statement shall be severable, and if any provision, or part-provision, of this Privacy Statement shall be held or declared to be illegal, invalid, or unenforceable, such illegality, invalidity, or unenforceability shall not affect any other provision, or part-provision, of this Privacy Statement, and the remainder of this Privacy Statement, disregarding such illegal, invalid or unenforceable provision, or part-provision, shall continue in full force and effect as through such illegal, invalid, or unenforceable provision, or part-provision, had not been contained in this Privacy Statement.
- In the event of any discrepancy between the Chinese version (if available), the Spanish version (if available), the Japanese version (if available) and the English version of this Privacy Statement, the English version shall prevail.