Privacy Policy

GreenBulb Trading Limited (“GreenBulb”, “we” and “us”, as the case may be), its officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data (“Personal Data”, as defined in the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong) collected from you and/or stored and/or transmitted by you to us. Please read the following to learn more about our Privacy Policy Statement (“Statement”) :

1. What this Statement Covers

This Statement covers our treatment of Personal Data that we collect when you are our member, when you subscribe / log-in with us or when you request us for our services. Where GreenBulb’s operations are subject to privacy legislation other than that of the Hong Kong Special Administrative Region (“Hong Kong”), then this Statement shall be applied so far as practicable and consistent with such local legislation.

2. Collection of Personal Data

a.)For the purpose of carrying on GreenBulb’s business, you may be requested to provide your Personal Data when you subscribe / log-in as our VIP member (if applicable), when you visit our websites (including but not limited to this website), when you conduct gift redemption / cash or discount voucher request (if applicable), when you submit any comments or feedbacks to us or when you are required to verify your identity with us.

b.)The Personal Data that you may be requested to provide with us includes but not limited to, inter alia, your name, contact phone no., email address, correspondence address, gender, date and month of birth, age group, payment details, occupation, education and profession, and/or personal interests.  Once you subscribe with us and sign in to our web pages, you are not anonymous to us.

c.)Our web servers may also collect Personal Data relating to your online session or your browser including your IP address, cookie information and the page you requested, for the purpose of providing aggregated, anonymous, statistical information on the server’s usage.

d.)All Personal Data will be collected on a voluntary, open and fair basis.

3. Purpose for Collection of Personal Data

GreenBulb will collect your Personal Data for the following purposes :

a.)for the provision of products or services and facilities by GreenBulb / its service providers (who are engaged by us to assist with providing you our services) to you;

b.)for carrying out your instructions or responding to your enquiry;

c.)for direct marketing purpose, including designing further products and services for you and marketing products or services in which GreenBulb shall be involved;

d.)for forming part of customer data base necessary for the operation by GreenBulb; and/or

e.)for observing any legal, governmental or regulatory requirements of Hong Kong or other relevant jurisdiction including any disclosure or notification requirements to which GreenBulb or other class of data recipient, are subject.

4. Accuracy

GreenBulb will take all practicable steps to ensure that the Personal Data so collected are accurate. However, your efforts to provide accurate Personal Data upon subscription of / log-in with GreenBulb’s services and thereafter to update GreenBulb of any change of your Personal Data are always welcome.

5. Personal Data Sharing and Disclosure

Unless GreenBulb hears from you to the contrary upon subscription / log-in or receives subsequent notice from you, GreenBulb may, where such disclosure is necessary to satisfy the purpose for which the Personal Data was collected, provide such Personal Data to the following parties :

a.)employees and officers of GreenBulb;

b.)the brands traded, operated or owned by GreenBulb;

c.)contractors/sub-contractors, service providers and agents of GreenBulb; and/or (if applicable)

d.)the court or regulatory body with subpoenas, court orders or for the purpose of legal process.

6. Access and Correction

1.)You have the right to know :

a.)the privacy policy of GreenBulb;

b.)whether GreenBulb holds any of your Personal Data; and

c.)the kind of Personal Data being held by GreenBulb

2.)You have full control and ability to correct or edit your Personal Data at any time, including whether you want us to contact you about VIP promotional offers and new products and services.

3.)You may request your right of access or right of correction by writing to us via e-mail to hello@sonarpen.com or via mail at Unit 3A, 11-13 Luk Hop Street, San Po Kong, Kowloon, Hong Kong (attention to Marketing Department) or via fax to (852) 2770 1465. GreenBulb will, upon satisfying itself of the authenticity and validity of the access or correction request, make every endeavor to comply with and respond to the request within the period set by the statutory requirement.

7. Security

Data security is our top priority. We strive to ensure that your Personal Data will be protected against unauthorized or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Data. Encryption technology, such as SSL, may be employed for the transmission of Personal Data collected online. Also, our web servers are protected by data security measures and our systems are monitored to prevent any unauthorized access.

8. Retention of Personal Data

Your Personal Data will only be retained for as long as is necessary to fulfill the original purpose for which it was collected , unless contrary to any applicable statutory requirement.

9. Amendment to this Statement

a) We may amend this Statement from time to time. If we make any substantial amendments in the way we use your Personal Data, we will notify you by posting a prominent announcement on this Website. You agree that such posting will constitute sufficient and adequate notice to you of the amendments.

b.)You agree that your continued use of our products or services after such amendment will constitute your acceptance of and agreement to be bound by the modified Statement.

10. Direct Marketing

GreenBulb may contact you from time to time with a view to providing the latest information on our products and services / VIP program. If you do not wish to receive these updates, you may click the unsubscribe link as shown in our electronic promotional materials; or write to us via e-mail to hello@sonarpen.com or via mail at Unit 3A, 11-13 Luk Hop Street, Kowloon, Hong Kong (attention to Marketing Department) or via fax to (852) 2770 1465. In accordance with the statutory requirements, GreenBulb will honor your request not to use your Personal Data for the purposes of direct marketing. Unless otherwise instructed as per the above, GreenBulb may use any of your Personal Data collected in the normal course of our business for marketing purposes.

11. Contact Us

If you have any questions regarding this Statement, please email us at hello@sonarpen.com.

Notes:

By accessing this Website, you agree to comply with the Statement set out above.

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