Xtep International Holdings Limited
Data Privacy and Security Policy
This policy ("Policy") sets out how Xtep International Holdings Limited ("Xtep", "we", "our" or "us") collects, uses, stores and handles personal data.
A. Our Commitment
We are committed to protecting the privacy of the personal data ("Personal Data") we hold. To ensure that you can make informed decisions and feel confident about providing your Personal Data to us, we outline in this Policy our practices and the choices you have concerning the collection and use of your Personal Data.
B. What We Collect
The types of Personal Data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of Personal Data may include (without limitation) the followings:
- your personal information (e.g. your name, gender and date of birth);
- your contact information (e.g. telephone numbers, mailing addresses, email addresses and fax numbers);
- your business information (e.g. company name, business title and associated contact information);
- your interests, personal preferences or comments;
- information when you use our websites or other services or products (e.g. behavioural information, location information, browser details, IP addresses).
Certain Personal Data (e.g. relating to your personal information and contact information) are required for specific services and if you fail to supply such Personal Data as requested from each specific service, we may not be able to deliver you the services or products. By providing your Personal Data to us, you acknowledge that such provision is fair and reasonable in the circumstances.
C. Purposes of Collection and Usage
The purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:
- for the supply of any services, products, facilities and/or other subjects (together, the "Services") which we or any of our subsidiaries, holding companies, joint ventures and associated companies (together, "Xtep Group") may offer to you, or you may require from us, from time to time;
- for use of the online services available at any of the websites of Xtep Group and/or through other telecommunication channels;
- with your consent, for marketing or promoting any of the Services of Xtep Group (e.g. sending you updates on our latest offers and promotions in relation to any of our Services from time to time);
- with your consent, for promoting and soliciting donations or contributions for charitable or non-profit making causes;
- for sale or purchase of any of the Services of Xtep Group and/or for management or other related services;
- for identification and verification purposes in connection with any of the Services that may be supplied to you;
- for communicating with you by email, mail, fax, phone or other means, including contacting you regarding your enquiries;
- for making disclosures when required by law, regulation, or court order of any jurisdiction and/or as requested by any government, regulatory or law enforcement authority or administrative organisation, which may be within or outside The Hong Kong Special Administrative Region of the People’s Republic of China ("Hong Kong");
- for establishing legal claims or defences, obtaining legal advice, and/or exercising, defending and/or protecting the rights or properties of any member of Xtep Group, including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or property of any other person could be damaged by such interfering activities;
- for the use by any member of Xtep Group in connection with any of the above purposes and/or any of the Services that any member of Xtep Group may offer or supply to you from time to time; and/or
- for any other incidental or associated purposes relating to the above, or any other purposes as specified in a personal information collection statement when your Personal Data is being collected, or any other purposes which you may from time to time agree.
We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes (or purposes as specified in a personal information collection statement when we collect your Personal Data) without your prior consent.
D. Disclosure and Transfer
To facilitate the purposes mentioned under "C. Purposes of Collection and Usage", we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Hong Kong, and your Personal Data may be transferred within or outside Hong Kong. These third parties may include the followings:
- any member of Xtep Group;
- any agent, contractor or third-party service provider who provides administrative, distribution, data processing, telemarketing, telecommunications, computer, or other services to or support the operation of Xtep Group’s business (including its/their direct marketing activities);
- medical professionals, clinics, hospitals, insurers and/or loss adjustors;
- any person, government or law enforcement authority or administrative organisation; any person under a duty of confidentiality to any member of Xtep Group (including accountants, legal advisers or other advisers);
- any actual or proposed assignee or purchaser of all or any part of the business and/or asset of Xtep Group; and/or charitable or non-profit marking organisations.
The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above.
E. Direct Marketing
If we intend to use your Personal Data (including your name and contact details) collected from you for direct marketing purposes (e.g. to send you marketing communications about news, offers or promotions in relation to the Services or Activities of Xtep Group), we will first obtain your consent (or an indication of no objection) before doing so.
If we intend to provide your Personal Data (including your name and contact details) collected from you to third parties for their use in direct marketing, we will first obtain your consent (or an indication of no objection) before doing so.
You may opt-out from receiving marketing communications from us at any time, free of charge by:
- following the opt-out instructions contained in the communications, or
- write to us at the address listed in "K. How to Access or Correct Your Personal Data or Contact Us".
F. Our Commitment to Children's Privacy
Protecting the privacy of children is our primary concern. Hence, we will not knowingly collect or maintain Personal Data in our database from persons who are under 16 years of age without prior consent from a parent or guardian.
Cookies contain information about you and your preferences. Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.
We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your Personal Data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.
If you use the WiFi available at our properties, we may collect your location data (if you have consented to this on your device). We may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information we receive from third parties to provide you with better service and, where you have consented to receive direct marketing, we may provide you with targeted advertisements, content, features, deals and offers in relation to the classes of marketing subject as set out in the relevant personal information collection statement when your Personal Data is being collected.
If you interact with us on social media platforms (for example if you "Like" our Facebook Page), we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform's rules but we are not responsible for how the platform operators collect and handle your Personal Data. We are not responsible for what third parties post on our social media accounts.
H. Data Retention
Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above after which it will be destroyed.
I. Data Security
In order to ensure the correct use and to maintain the accuracy of the Personal Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Personal Data, we have implemented various internal policies (including physical, electronic and management measures) to safeguard and secure the Personal Data we collect. For example, where we collect Personal Data online, we use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Personal Data.
Our websites have firewalls in place, which should protect the Personal Data collected from you against unauthorised or accidental access. However, complete confidentiality and security is not yet possible over the internet, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorised access to your password. Make sure you sign out from your account when finished particularly when using a shared computer.
J. Other Websites
In order to anticipate your needs, our websites may contain links to third party sites that are operated under different privacy practices.
All such websites are independent from our websites. We have no control over the contents of such other websites or their privacy policies or compliance with the law. You should therefore be fully aware the provision of such links does not constitute an endorsement, approval, or any form of association by or with Xtep Group. We have no control over Personal Data that is submitted to these other websites. You should remain alert when you leave our websites, and read the privacy statements of other websites.
K. How to Access or Correct Your Personal Data or Contact Us
You are entitled to access or correct any Personal Data relating to you held by us. If you wish to obtain a copy of any of your Personal Data or if you believe that the Personal Data relating to you which we collect and maintain is inaccurate, please write to us at the address below.
A request for access to Personal Data, correction of Personal Data, or for information regarding policies and practices and kinds of Personal Data held by Xtep may be sent to us at the following address:
Xtep International Holdings Limited
Investor Relations and Corporate Communications Department
Unit A, 27/F, Tower A
Billion Centre, 1 Wang Kwong Road
Kowloon Bay, Kowloon, Hong Kong
In accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong), we have the right to charge a reasonable fee for the processing of any data access request.
This Policy may be amended from time to time. You may access and obtain a copy of this Policy, as amended from time to time, at www.xtep.com.hk so that you are always informed of the way we collect and use Personal Data.
This Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.