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Privacy Policy

Privacy Policy of PopSquare

Last updated: 15 May 2019

This policy explains what, how, and why of the personal information we collect when you visit our website(s), or when you use our Services.  This policy also explains how we use and disclose the information we collected.  We take your privacy extremely seriously, and we never sell the personal data to any third parties.

If you choose to use our Service, then you agree that we will collect and use of your personal information in relation with this policy. The personal information that we collect are used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

 

Compliance with the Personal Data (Privacy) Ordinance (Cap. 486)

We, as a data controller and also a data processor, will use our effort to comply with the requirements of the Personal Data (Privacy) Ordinance and ensure that the personal data we have collected are accurately, securely kept and used only for the purpose as they are collected for.

All our staff who handle identifiable personal data would take extra precaution to ensure that the relevant laws on personal data (privacy) and our guidelines are complied with and that effective security mesaures are adopted to protect personal and sensitvie data concerning a wide specturm of data subjects such as our clients, business parties, job applicants, etc.

 

Commitment to General Data Protection Regulation (GDPR)

We take data protection and people’s privacy very seriously and we are comitted to comply with the GDPR.

  

Type of Data and Means of Collection 

  • Traffic data when you approach our kiosks within 1 meter and 4 meters through camera
  • Product pick-up data when you pick-up product on our kiosks by image through camera
  • Demographics data including gender and age range when you approach our kiosks in 1 meter through camera
  • Clickstream data when you provide to us via our kiosk screen
  • Your mobile number when you provide it to us via our kiosk screen
  • Your personal identifiable information, including but not limited to your name, email address, phone number, postal address, location when you fill in our survey, fill in our membership registration form, or place an order for any of our products or services
  • Log data on our website(s) when you use or visit our websit(s) via your browser’s cookies. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

 

 

The Use of Data

The data that we collect will be used to operate our Service, to improve our Service, to understand the traffic around the kiosks, to understand different product popularity, to personalize your experiences, for internal research study, to process your order and to send you special offers on our products we think you may be interested. You can object to the use of your data as described above at anytime.

 

Storage of Data 

The data is processed at Data Processor’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact us by email: privacy@popsquare.io 

The image data collected from the cameras are hosted in the cloud platforms as provided by the third-party service providers. Our third-party service providers are committed themselves to comply with the GDPR. For more details, please check:

https://www.microsoft.com/en-us/trustcenter/privacy/gdpr/gdpr-overview
https://www.linode.com/compliance

 

Retention Period: 

The data is kept for the time necessary to provide the service, or stated by the purposes outlined in this document. You can always request that the Data Controller suspend or remove your personal data and ensure that the personal data we collected are accurately, securely kept and used only for the purpose as they were collected for. All image data will be kept for and deleted after 60 days.

 

By way of an exception, personal data may be kept for a longer period as required by the laws archiving purposes in the public interest or for reasons of scientific or historical research, and we will ensure appropriate technical and organisational measures are put in place (such as anonymisation, encryption, etc.) as usual.

 

 

Sharing of the personal data:

The data may be accessible to certain types of persons in charge, involved with the operation of the Service and the websites (system administration, sales, marketing, legal) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed. The updated list of these parties can be provided upon request.

 

Rights of the data subjects under GDPR

In compliance with GDPR, you have the below rights in order to protect your privacy as long as the type of data can represent your identity.

Right to be forgotten
Individuals may request to delete all personal data on that individual without undue delay.

Right to object
Individuals may request to prohibit certain personal data uses.

Right to rectification
Individuals may request that incomplete data be completed or that incorrect data be corrected.

Right of access
Individuals may request to view the data we have collected on the individual.

Right of portability
Individuals may request that personal data held by on organization be transported to another.

Please contact us at privacy@popsquare.io for such a request.

 

Security of the personal data  

We value your trust in providing us your personal data, thus we take reasonable precautions and take appropriate secruity measures to follow the industry best practices to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data, and following organizational procedures and modes strictly related to the purposes indicated.

The image data as collected from the cameras at the kiosks will be encrypted, transmitted to and hosted in the cloud platforms as provided by the third-party service providers. Our third-party service providers are committed themselves to comply with the GDPR.

We will take reasonable steps to ensure that these companies clearly identify themselves and handle your information appropriately. However, please note that these external parties are not operated by us. We strongly advise you to review the Privacy Policy in their websites. We have no control over, and shall assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

https://www.microsoft.com/en-us/trustcenter/privacy/gdpr/gdpr-overview
https://www.linode.com/compliance 

 

Links to Other Sites

Our website(s) may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

 

Changes to This Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

 

Unsubscribe

If you do not wish to receive our newsletter or promotional email, you may click on a link named “unsubscribe” which is embedded in the email sent by us in order to not receive future messages from us.

 

Direct Marketing

We will use your personal data to send you marketing offers, information surveys and invitations through e-mails, text messages, phone calls and postal mail.

In order to optimise your experience at our kiosks, we will provide you with relevant information, recommended products, send you reminders of products that you have picked at our kiosks and send you personalised offers.  

You may inform us any time that you no longer wish to receive our marketing offers and information by clicking on “Unsubscribe” through the links as indicated in our e-mails.

 

How to contact us

If you have any questions about our privacy policy, the data we hold on you, or you would wish to report a complaint if you feel that we have not addressed your concern in a satisfactory manner, please do not hesitate to contact our Privacy Compliance Officer at:

Email us at: privacy@popsquare.io

Call us at: +852 3188 7418

Write to us at: Unit 611 & 612, 6/F, Lakeside 2, No. 10 Science Park West Avenue, Science Park, Shatin, Hong Kong