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PRIVACY POLICY 

Last Updated:  19th September 2020

 

We are committed to protecting the privacy, confidentiality, and security of the personal information we hold by complying with the requirements of the Personal Data (Privacy) Ordinance with respect to the management of personal information. We are equally committed to ensuring that our employees and agents uphold these obligations. This Privacy Policy (“Policy”) refers to the collection, processing and use of Personal Data provided to and/or collected when you access our website www.compoundby3spirit.com (the "Website")  or use our product(s)/ design services (Visual Merchandising, Fashion Design, Trend Forecasting) through our Website, including Personal Data that may be shared by our business partner(s). For further information and clarification on our Privacy Policy, you could send us a request through an email to info@compoundby3spirit.com

This Policy does not cover Personal Data that may be collected elsewhere such as offline, or website(s) linking to or from our Website, or third parties and individuals that our Website does not own, control, employ or manage. 

If you do not agree with this Policy, please do not access or use our Website, provide any Personal Data to us, purchase our product(s) or use our service(s). Please read this Policy together with our General Terms and Conditions of Use.

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1. Who collects your Personal Data

​The entities which collect, process, and use the Personal Data are Three Spirit International Ltd., with registered office at 1B, Van Fat Factory Building, 20-22 Ng Fong Street, San Po Kong, Kowloon, Hong Kong SAR, China, and its related entities (collectively referred to as “we”, “us”). “Personal Data” means any personal information that makes it identifiable directly or indirectly to a living individual, such as name, postal address, email address, and telephone number.

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2. Why we collect your Personal Data

​We collect Personal Data with your specific prior knowledge and consent, such as subscribing to our Website or create an account with us. Please note that it is mandatory for you to provide those Personal Data marked with asterisks on the online order form. You may opt not to provide us with certain Personal Data, but in doing so, or if the Personal Data provided is inaccurate, we may not be able to properly process your online order transaction, account opening application, or member subscription or you may not be able to enjoy certain special features we may offer on our Website. When you subscribe to our Website, you need to provide certain Personal Data such as your email address. If you choose not to provide certain Personal Data, we may not be able to process your subscription application. We will use your submitted Personal Data to process your purchase order and for purposes set out in this Policy. We will not disclose any collected Personal Data except where stated herein or otherwise notified in advance. Optional Personal Data like your location, referrer, etc, may also be requested.  If you opt not to provide such Optional Personal Data, it will not affect your use of the Website or the purchase of products on our Website.

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3. Automatic Information​

Our servers may automatically collect automatic, individual, and/or aggregate information about your electronic device (such as phone, computer) used to visit our Website, the website that referred you, Internet Protocol (“IP”) address, type, and configuration of the internet browser of your electronic device, browsing preference such as language settings, font size, geo-location, operating system, and other usage and traffic information.

We use this automatic, individual, and/or aggregate information to analyze trends, gather and prepare statistics or demographic information, and administer our website so we may provide improved online web experiences to our users and visitors. Such information collected will not identify you personally. We may provide such information to our partners about how our users collectively use our Website, so they may provide you with improved web experience.

We may also be legally required to disclose or provide access to our database so to cooperate with the applicable laws, regulations, court order, and/or request from a government authority, which we will provide for those specific requests.

This Policy does not restrict or limit our collection and use of such automatic and/or aggregated information.

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4. Cookies​

When you visit the Website, to distinguish you from other users, we may use cookies to store and track information about your specific computer or electronic device or your activities for the purposes of providing our services to you. 

Cookies are small computer text files that are sent from a website to the browser of your computer or electronic device and are stored on your device. Generally, cookies do not recognize you personally and are not harmful to your device. Cookies are used only for compiling aggregate statistics on the websites that you visit and browse to improve your website browsing experience and provide the website operators with non-personal data or analytical information to help improve the quality of their websites for their users’ website browsing experience. For example, we use cookies to save your device’s browsing preferences and settings. For these reasons we require that you keep cookies enabled when using our Website. Please note that if you choose to disable cookies on your computer or electronic device, you may find that some of the features and functionality of our Website may not work properly. Additionally, our cookies may be accessible by third parties or provided by third parties including, for example, Google via Google AdSense on our Website. We do not have any control over and are not responsible or liable for such third parties’ collection and use of the cookies. Please refer to those third parties’ relevant policies regarding their collection and use of cookies for further information.

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5. How we use, share and process your Personal Data​

We use, store, and/or share your Personal Data with our third-party service providers in order to conduct our business activities, such as:

  • Enhance or improve the user experience of our Website or help improve performance on our product(s) or service(s) offered through our Website;

  • Register, verify, process, and maintain your account with us;

  • Process, verify, operate, manage, administer and maintain membership for our Website’s users;

  • Inform you of changes to our Policy, and General Terms and Conditions of Use or respond to your inquiries;

  • Send an email or other marketing communications about our Website or other news, promotional sale alert, our products, and services;

  • Detect, investigate, identify, protect and prevent against fraudulent transactions or other illegal or misuse of our Website which may violate this Policy, our General Terms, and Conditions of Use;

  • Enforce our Policy, our General Terms, and Conditions of Use; 

  • Allow our engaged third party social media providers (Facebook, Twitter, Instagram), IT contractor(s), website analytic service provider(s), data processor(s), and other service providers to provide specific services for or to our Website to host contents on our Website, process Personal Data for our Website, process purchase order transactions, provide delivery and technological support to us, conduct maintenance of our services, data banks, databases, and database management systems;

  • Disclose to potential and/or confirmed purchaser(s) or assignee(s) as part of any reorganization, merger, and acquisition, transfer, or sale of our business;

  • Comply with or as permitted by any applicable laws, regulations, order, or a lawful request from government authority or court.  If we receive a subpoena affecting your privacy, unless there are any prohibitions/ restrictions under applicable laws, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either;

  • For any other directly related purposes.

Without prejudice to the foregoing, the following is a non-exhaustive list of other entities that we may store, share, or transfer your collected Personal Data in accordance with this Policy:

  • Google Analytics (Anonymous version)

  • Google Tag Manager

  • Google DoubleClick for Publishers

  • Google AdSense

  • Google Adwords

  • Google Sign-in (iOS/Android)

  • Facebook (SDK for iOS/Android, App Events/Analytics, AudienceNetwork)

  • Google Firebase (Cloud Messaging, Performance Marketing, etc.

Because of the nature of our business, we may need to transfer your Personal Data to third parties as noted above in connection with the purposes set out in this Policy who are outside of Hong Kong. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. We also process your Personal Data for the technical administration of the Website. Your Personal Data will be processed by our employees and engaged third-party service providers mentioned above as the persons in charge of the processing. Other information regarding the sphere of communication and dissemination of your Personal Data shall be provided to you in specific areas of the Website. Your Personal Data will be stored and kept for the time necessary to fulfill the purposes for which such data was collected and in compliance with the principle of necessity and proportionality and in accordance with this Policy.

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6. Third-Party Websites​

Our Website may contain links to third-party websites, advertisers, or services that we do not own or control. We assume no responsibility for the content, privacy policies, or practices of any third party websites, advertisers, or services or their use of your Personal Data. If you access a third-party website from our Website, you do so at your own risk, and you understand that neither this Policy, our Terms and Conditions of Use, nor our Terms and Conditions of Sale apply to your use of such third-party websites. We encourage you to review the privacy policies and terms of use of any third-party website, advertisers, or services that you visit or use before providing your Personal Data to those third parties. We shall not be liable for your activities taken on or with those other third party websites, advertisers, or services.

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7. Third-Party Access to your Personal Data​

Without prejudice to Clause 6, we endeavor to protect your Personal Data from being accessed by third parties and we may employ external maintenance personnel or use a third-party service provider(s) to help us provide website, information technology, and/or data processing services or host our materials. These are third party entities that may have custody or access to your Personal Data. It is necessary that you permit such third parties to access your Personal Data to the same degree and extent that you authorize us to do so. For greater certainty, every authorization you grant us in this Policy, you agree to also grant the same to any third party that we may hire, contract, instruct, or otherwise retain services for the purpose of operating, hosting, maintaining, repairing, improving, preserving or otherwise for our Website or its underlying files or systems, for data processing on our behalf, provide technical support and/or conduct maintenance of our servers, data banks or database (as the case may be). 

To the fullest and maximum extent as permitted under applicable law, you agree not to hold us liable for action(s) undertaken by such third parties, even where we may normally be held vicariously liable for their actions, and you must take legal actions against them directly should they commit any tort or other actionable wrongdoing against you.

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8. Marketing & Communication​

Your Personal Data may be used by us to provide you with information about special offers and discounts on products and services to be provided or sponsored by us.  We cannot use your Personal Data for such purpose unless we have received your consent or indication of no objection which you can provide through the tick-box(es) located on the online order form. When subscribing as a member or opening an account on the Website, you will also be given the option to opt-in to receive our promotional or direct marketing materials and/or updates. You have the right to withdraw your consent to any use of your Personal Data for purposes of commercial or direct marketing at any time thereafter by opting-out through the unsubscribe links available at the bottom of our emails/communications, logging into the Website, or third party social networks and adjusting your user preferences in your account profile by unchecking the relevant boxes. You may also contact us by sending your request to our address or send an e-mail to info@compoundby3spirit.com

Please allow ample time for us to process your request. However, please note that even if you opt-out from receiving marketing communications, we may need to send you service-related communications and may need to keep information we have collected about you for record-keeping, research, and other purposes.

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9. Security of Information​

We use SSL and TLS certificates to help secure our Website to prevent the loss of Personal Data, illegal or improper utilization, and unauthorized access. However, please note that it is essential for the safety of your Personal Data that your device is equipped with tools such as constant antivirus updates and that your internet provider provides a connection ensuring a secure data transmission through firewalls, spam filters, and similar measures.  You understand and agree that no transmission of data over the internet is guaranteed to be completely secure or confidential.  It is in our interest to keep our website secure, but we recommend that you use anti-virus software, firewalls, and other precautions to protect yourself from security threats.

 

10. California Consumer Privacy Act  (please stay tuned for revision)

 

11. EU’s General Data Protection Regulation Policy (please stay tuned for revision)

 

​12. Collection from children

​This Website is not intended for children under the age 18 and we do not knowingly collect Personal Data from such children. Children under the age of 18 should not use or attempt to use our Website or send Personal Data to us. In the event that we learn that we have inadvertently gathered Personal Data from a child under the age of 18, we will take reasonable measures to erase such information from our records. Parents who believe that we might have any information from or about a child under 18, may submit a request to info@compoundby3spirit.com and request that such data be removed.

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13. Amendments

​We may amend this Privacy Policy from time to time. The amended version will be published on our Website in place of the previous version. We will also include the date that the currently displayed Privacy Policy took effect to help you determine whether there have been any changes since you last used the Website. Changes in this Privacy Policy become effective as soon as the changes are published onto the Website. If you continue to use our Website after the changes become effective, it represents your agreement to be bound by such changes. If you do not agree with the revised or updated Privacy Policy, you must immediately cease using our Website, product(s), and service(s).

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14. Validity

​If any of the provisions in this Privacy Policy is held to be invalid or unenforceable for any reason by a court of competent jurisdiction, such provision(s) shall be deemed as severed from this Policy. Such invalidity shall not in any way affect the enforceability and/or validity over the remaining provisions of this Policy, which shall continue in full force and effect.

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15. Accessing and Correcting your Personal Data

​Any inquiries about your rights under this Privacy Policy, or any other matters regarding your privacy, can be directed to info@compoundby3spirit.com. You have the right to request access to, update, and/or correction of your Personal Data held by us. If you wish to make such a request, please contact us by the above email and marking “Attention: Personal Data Access / Correction Request” on your correspondence. Depending on the scope of the request, we may impose a reasonable administrative fee for complying with such a request. All requests shall be made in writing in the English language.

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16. Governing Law

This Policy is governed and construed in accordance with the laws of Hong Kong Special Administrative Region (“Hong Kong”) without application of conflict of laws rules.  Any dispute arising directly or indirectly, interpretation, or enforcement of this Policy will be submitted to the exclusive jurisdiction of the Courts of Hong Kong.

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