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ÉMIGRÉ PRIVACY POLICY

Last Modified Date: 5 APR 2022
 

Hurbanot Ltd. trademark owner of Émigré a Hong Kong limited liability company (“Émigré” "Hurbanot", "we", "us" or "our") recognises the importance of protecting your Personal Data (as defined hereunder). This Privacy Policy ("Policy") describes how Émigré collects, processes, uses, disseminates or makes available your personal data via Émigré website (www.emigre.travel), including Émigré mobile applications (collectively, "Website") and other means (i.e, social media, cookies, etc.).

1. What Is Personal Data? For the purpose of this Policy, Personal Data means and includes your name, phone number, address, email address, online identifiers and any other data which, directly or indirectly, can identify you.

2. Personal Data We Collect

2.1 Information Voluntarily Provided To Us. We collect your Personal Data and other information when you visit our Website, place orders, make purchases, sign up or create an account with us, when you interact with our customer service for support or giving us a feedback, when you visits our retail/pop-up stores, or when you subscriber/participate in our survey/review or marketing activities (e.g., subscribing to our newsletter/mailing list, participating in our loyalty programs, contests and sweepstakes, etc.). The Personal Data obtained and collected by us includes:

  • Contact information (i.e, your name, phone number, postal address, email address, birthday and any other personal data).
  • Details of purchase/order your made and your purchase history.
  • Your payment information, such as billing address, credit card information and other information required for placing order or to complete the purchase.
  • Your consumer behaviours and habits.
  • Information and reason of contacting our customer service, and communication content between you and our customer service.
2.2 Information Automatically Collected By Us. When you visits our Website, or when you interact with our emails or advertisements on our Website, or other sites, certain information are automatically collected by cookies or other tracking technologies:
  • Internet protocol (IP) address and other device identifiers.
  • Your login information, browser type, browser plug-in types, operation system, time zone setting.
  • Information about your visit of our Website pages (e.g, products you searched or viewed for, the amount of time you spend on each page, crashes and download errors and response times).

For more details, please refer to the Emigre Cookies Policy for more details. You may adjust your browser settings to decline cookies or limit certain tracking. However, such change, adjustment or limitation may impact your experience of certain services/features on our Website, or you may not be able to take full advantage of our offerings.

2.3 Information Collected From Third Party Sources. We also obtain and collect certain of your information from third party sources, including social media, third party apps and similar technologies. The information may include your name, user name, postal address, phone number, email address, demographic information, habits, preference, interests and any other publicly-observed data.

2.4 Combination of Information. We may combine the information we collect, obtain or receive from and above you set forth in clauses 2.1 to 2.3 above.

3. How We Use Your Personal Data

3.1 To Perform A Contract With You. We use and process your Personal Data to perform a contract with you and carry out our contractual obligations, including processing the order(s) you have placed and the payments, or take step that you have requested to enter into a contract.

3.2 For Our Legitimate Interest. We use and process your Personal Date for our legitimate interests, and our interests are not overridden by your interests, fundamental rights or freedoms. Our legitimate interests include:

  • To manage your registered account(s) or membership with us.
  • To run and develop our business activities.
  • To pursue and conduct general marketing and promotional activities.
  • To provide you with our customer services, such as after-sale service, answering your queries, and providing you with the required products, services or information.
  • To invite your feedback in order to improve our products, service and Website.
  • To conduct research, review and analysis.
  • To manage and administer our accounts and record.
  • To prevent or detect fraud and abuses of our Website.

3.3 Based On Your Consent. In addition, based on your consent, we also use and process your Personal Date for other marketing purpose:

  • To communicate with you on updates about our products.
  • To deliver the type of product that may be of interest to you, including tailored advertisements.
  • To personalise and customising your Website experience.

4. Who And How We Share Your Personal Data

We do not sell your Personal Data. We do share your Personal Data as follows:

4.1 Authorised Personnel. Within Émigré, only the duly authorised personnel would have access to your Personal Data as necessary to perform duties for the purposes set forth in clause 2 above.

4.2 Other Third Parties. In addition, we share your Personal Data to the following third parties:

  • Service Providers, including service providers for (a) web hosting, analytics and related services, (b) payment processing, (c) order fulfilment and shipping, (d) fraud protection and credit risk reduction, and (e) marketing services on our behalf. The service providers are obligated contractually not to use, share or disclose your Personal Data unless as necessary to perform the services on our behalf or to comply with the applicable laws and regulations.
  • Business Partners with whom we may collaborate in offering offer products.
  • Advertising Partners, who will be allowed to set cookies or other tracking tools to collect information regarding your activities on our Website. We may also share with them certain selected personal information, such as purchase records and demographic information. They may use the information collected for "interest-based advertising" and "online behavioural advertising, i.e, to deliver tailored or targeted advertisings to you on other websites.
  • Trusted Third Parties, where disclosure is necessary (a) to protect the security or integrity of our databases or our Website; (b) for legal proceedings (e.g, legal action against pirated, counterfeit or unauthorised products) and to take precautions against legal liability; (c) in connection with the management of our business and operations; (d) in the event of a sale, merger, reorganisation, change of control or any other similar event, to the extent permitted by applicable law; or (e) as required by applicable law or regulations, to the extent compatible with this Privacy.

5. Transfer of Personal Data

5.1 Outside Of The Origin Country. Your Personal Data may be transferred outside of the country from which it was originally collected and may be shared both intra-group and with third parties located in other jurisdictions, which may not have similar data protection laws. All such transfers of Personal Data will be pursuant to the applicable data protection laws.

5.2 Outside Of EEA. For residents in the European Economic Area ("EEA"), we implement appropriate safeguards for the transfer of your Personal Data outside of the EEA, such as an appropriate data transfer agreement (based on the EU Commission Standard Contractual Clauses for the transfer of data to third countries (Article 46, 2., (c) of the GDPR, as of 25 May 2018)) or binding corporate rules (Article 47 of the GDPR as of 25 May 2018). All Personal Data so transferred should have adequate protection in accordance with applicable data protection rules.

6. Security And Retention

6.1 Security. We place great importance on and are committed to protect the security of your Personal Data. We take appropriate technical and organisational measures to protect your Personal Data against accidental loss, unlawful or accidental destruction, alteration, unauthorised disclosure or access. However, there is no electronic transmission or storage of information is 100% secure. While we will use commercially reasonable effort to protect your personal information, we cannot guarantee its absolute security and any transmission of your personal information through the internet is at your own risk. For the best possible protection of your personal data and information, we recommend that your device should be protected (i.e, the latest antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (i.e, firewalls and anti-spam filtering).

6.2 Retention. We retain your Personal Data for the time necessary to achieve the purposes set forth in this Policy, and in any event within the legal limitation periods under the applicable laws.

7. Your Rights With Respect To Your Personal Data

You have the rights to:

  • Get a copy of your Personal Data.
  • Access, correct and update your Personal Data.
  • Restrict our use and processing of your Personal Data.
  • Object our use and processing of your Personal Data for direct marketing and other purpose based on a "legitimate interest".
  • Request to delete your Personal Data.
  • Withdraw a consent given to us previously
  • Not to be subject to a decision based solely on automated processing.
  • Make a complaint against us with your local data protection supervisory authority.

You may exercise any of these rights by sending an email to us at info@emigre.travel with a subject of "Personal Data Right". We will take step to verify your identity, please provide us with your name, email address and evidence of your identity. We may also contract you asking for certain information for verification purpose. We will honour your above requests free of charge, however, to the extent permitted by law, we reserve the right to charge a reasonable fee or not to act on the request in case of the request is manifestly unfounded or excessive.

8. Links To Social Media Platforms And Other Sites

8.1 Social Media Platforms. Our Website contain social media plug-ins, including Instagram, Facebook, Linkedin. If you interact with these plug-ins, your activity on our Website will also be made available to those social media platforms. We do not have control of these social medial platforms and do not endorse or make any representations about the third party websites/applications, we are not responsible for their privacy practices or content. We encourage you to read the privacy policies of such social media platforms with which you interact.

8.2 Other Sites. Our Website may also contain hyperlinks to other third party website/applications which are not controlled or operated by us. The hyperlinks are for your reference and convenience only. We do not endorse or make any representations about the third party websites/applications, and are not responsible for their privacy practices or content. We encourage you to read the privacy policies of any website/application you visit before you visit the website/application or provide your Personal Data to them.

9. Children's Privacy Protection

We are concerned about the safety of children when they use internet. Our services and Website are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. Children should obtain their parent's consent before giving out their personal information. If we are made aware of that personal information of a child under the age of 13 (or the age of 16 in certain EU member countries) are collected without verifiable parental consent, we will delete such information from our files as soon as possible and cease and terminate the child's register account/membership. If you are concerned of your child's use of our Website, we recommend you to use web-filtering technology to supervise your child's access to our Website.

If you learn that your child has provided us with personal information without your consent, please alert us at info@emigre.travel with a subject of "Children's Privacy Protection".

Cookies

Please refer to Émigré Cookies Policy

Last Modified Date And Change

This version of Policy is last modified and effective on 5 Apr 2022 We may from time to time change or modify our Policy to reflect changes to our privacy practices. If there is any modification or change, we will update the latest version which will be effective from the Last Modified Date. For any material changes, we will post a prominent notice on our Website, and where required by applicable law, we may also notify you of such material changes and seek your consent.

Questions And Concerns

If you have any queries, concerns, complaints, feedback or comments regarding this Policy, please contact info@emigre.travel. We will endeavour to respond to your request and resolve your concerns as soon as possible.