Last updated on 25 January 2022.
Slotine respects your privacy and commit to protecting it through our compliance with the practices described in this statement.
This statement is additional to our fiduciary duties as lawyers regarding confidentiality.
This statement describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website or other digital properties, communications, or forms that link or refer to this notice (our “Website”). This statement applies to the personal data collected through our Website, regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.
Please read this statement carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time. Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the statement periodically for updates.
- DATA WE MAY COLLECT ABOUT YOU
- HOW WE COLLECT ABOUT YOU
- COOKIES & AUTOMATIC DATA COLLECTION TECHNOLOGIES
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURE OF YOUR PERSONAL DATA
- CONSENT TO PERSONAL DATA TRANSFER
- YOUR PERSONAL DATA USE CHOICE
- ACCESSING AND PROTECTING YOUR PERSONAL DATA
- DATA SECURITY
- CHILDREN’S ONLINE PRIVACY
- CHANGES TO OUR PRIVACY NOTICE
- CONTACT INFORMATION
- DATA RETENTION
1. Data we may collect about you
We collect and use different types of data from and about you including:
- Personal data that we could reasonably use to directly or indirectly identify you, such as your name, postal address, email address, telephone number, user name or other similar identifier, or social media accounts (“personal data”).
- Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Website (including date and time), products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call us.
If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.
2. HOW WE COLLECT DATA ABOUT YOU
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you create an account, subscribe to our service, search for a product, place an order, participate in discussion boards or other social media functions on our Website, or survey, and when you report a problem with our Website.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Data Collection Technologies).
- Third parties or publicly available sources. We may receive information about you from third parties including, for example, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, background checks service providers, data brokers, or aggregators.
3. Cookies and automatic data collection technologies
- Estimate our audience size and usage patterns.
- Store your preferences so we may customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
You may refuse to accept browser cookies by activating the appropriate setting on your browser.
Our Website pages and e-mails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.
4. HOW WE USE YOUR PERSONAL DATA
We may process your personal data for our legitimate interests including the following legitimate interests:
- Present our Website and provide you with the information, products, services, and support that you request from us.
- Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements (for accounting purpose for instance).
- Fulfil the purposes for which you provided the data or that were described when it was collected.
- Notify you about changes to our Website, products, or services.
- Ensure that we present our Website content in the most effective manner for you and for your computer.
- Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
- Improve our Website, products or services, marketing, or customer relationships and experiences.
- Enable your participation in our Website’s interactive, social media, or other similar features.
- Protect our Website, employees, or operations.
- Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
- Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
We may use non-personal data for any business purpose.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with:
- Suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization). We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
- Background checks service providers when required for compliance purpose before entering into a contract with you.
- To fulfil the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
- For any other purposes that we disclose in writing when you provide the data.
We may share non-personal data without restriction.
6. CONSENT TO PERSONAL DATA TRANSFER
We are based in Hong Kong, a Special Administrative Region of the People’s Republic of China. We may process, store, and transfer the personal data we collect, in and to a jurisdiction outside your own, with different privacy laws that may or may not be as comprehensive as your own.
If you are located in the EEA, we have implemented additional (technical, contractual and/or organizational) measures to secure the transfer of your personal data to jurisdictions that the European Commission does not consider to provide the same privacy protections as in the EU. You can learn about these safeguards or, as the case may be, obtain a copy by contacting us at email@example.com.
By submitting your personal data or engaging with our Websites, you consent to this transfer, storing, or processing.
7. YOUR PERSONAL DATA USE CHOICES
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- Marketing from Slotine. If you do not want us to use your contact information to promote our own products and services, or third parties’ products or services, you can opt-out by checking the relevant box located on the form where we collect your data or at any other time by logging into the Website and checking or unchecking the relevant boxes to adjust your account profile’s user preferences, or by sending us an email with your request to firstname.lastname@example.org. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message.
Our Website may, from time to time, contain links to and from the websites of our partner networks, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.
8. ACCESSING AND CORRECTING YOUR PERSONAL DATA
You can access, review, and change your personal data by sending us an email at email@example.com to request access to, correct, or delete personal data that you have provided to us.
9. DATA SECURITY
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.
10. Children’s Online Privacy
We do not direct our Website to minors and we do not knowingly collect personal data from children under 16 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at firstname.lastname@example.org.
11. CHANGES TO our privacy notice
We will post any changes we may make to our privacy notice on this page. If the changes materially alter how we use or treat your personal data we will notify you through a notice on the Website home page. Please check back frequently to see any updates or changes to our privacy notice.
12. CONTACT INFORMATION
Our data protection officer is Maeva Slotine.
Our office is located at Units 2001-02, 20/F. Keen Hung Commercial Building, 80-86 Queen’s Road East, Wanchai, Hong Kong.
You have the right to make a complaint at any time to the relevant statutory bodies, including the Privacy Commissioner for Personal Data (PCPO), the statutory body which oversees the enforcement of personal data issues in Hong Kong. We would, however, appreciate the chance to deal with your concerns before you approach the PCPO so please contact us in the first instance.
Where you have provided your consent to the collection, processing, or transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, contact us at email@example.com.
14. DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.