It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the section What rights do I have?.
We collect and process personal data about you when you:
- visit and/or register on any websites owned and operated by us (including www.lanecrawford.com, www.lanecrawford.com.hk, and www.lanecrawford.com.cn) (collectively, our Site);
- place an order with us as a guest or as a registered user on our Site;
- use a third-party service offered by service providers such as analytics companies, advertising networks and cooperatives, demographic companies, and any other third party service providers that we choose to collaborate or work with, and we obtain your personal data from those third parties;
- rovide us with your personal data via: our physical stores, Wi-Fi, mobile devices, social media platforms/networks or telephone enquiries, your application for or use of our services or loyalty programmes (such as our Privilege Cards or Private Sales);
- visit our physical stores or any other of our locations and your image is captured by our security CCTV (please refer to our Closed-Circuit Television ("CCTV") Policy); and
- visit our physical stores or any other of our locations, and our data analytics cameras carry out real-time data analyses based on your image for statistical research purposes on an anonymous and aggregated basis as set out in our Data Analytics Policy (see Section 13 below). The only personal data that will be collected and processed and used to analyse pathways throughout the store will be your facial biometric template derived from your facial image (i.e. numeric information describing different facial features).
We process personal data for the following purposes:
To conduct our business and pursue legitimate interests, in particular:
- To provide our services to you, including: responding to any questions you may have, providing you with recommendations on products in our stores or on our Site; maintaining your shopping cart on our Site; assessing your applications with us for any of our services or loyalty programmes; providing our Privilege Card to you; fulfilling any orders you may make with us (including verification and security checks of your details, processing of your payments, shipping products that you have ordered to you, and processing returns or exchanges of products you have purchased); providing free Wi-Fi services to you at our physical stores and providing the Lane Crawford App services to you; personalizing our services to you and enhancing your experience in using our services; and
- We monitor use of our Site and our services (both online and offline), and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
- To analyse trends, usage, browsing and shopping behaviour with us (whether on an individualized or anonymized and aggregated basis), which helps us better understand how you and our collective customer base access and use our Site, stores and services, for the purposes of:
- improving our services;
- to respond to customer desires and preferences;
- measuring the effectiveness of our marketing campaigns;
- conducting marketing activities targeted at external, potential customers (on an aggregated and anonymized basis only); and
- crowdsource data analytics and hackathon activities (on an aggregated and anonymized basis only).
When you give us consent (if required):
- To provide you with direct marketing communications in relation to products, services, events, offers or promotions under the categories stated below, provided by: (a) us or our related companies (including our affiliate and subsidiary companies), (b) business partners, and (c) other third party providers. Such marketing communications may be in various forms, including advertisements, special events notifications or newsletters, and delivered via various methods in accordance with the personal data that you provide to us, such as by email, SMS, WeChat messages, smartphone app push notifications, notifications on your social media pages, in–app messaging or postal mail.
Such marketing communications may market or offer products or services (including special events and promotions) in the following categories: Dining, food and beverages, sports, music, film, television and other entertainment, clothing and accessories, jewellery, luggage and bags, cosmetics, personal health and hygiene, electronics, home furnishings, and housewares, automobiles, transport and travel, hotels, financial services, loyalty and reward programs, media services, entertainment services, social networking services, payment services, on-line advertising services, other e-commerce, information and communications and services, concierge services, and other products and services related to any of the foregoing, which we think may be relevant to you based on information you provide to us (for instance, via your participation in our surveys); and
- To allow you to register for and participate in our events and promotions, including verifying your identity at those events and promotions.
For purposes which are required by law:
- For verification of your identity as required under Chinese laws in order to provide free Wi-Fi service requested by you at our Mainland China physical stores; and
- In response to requests by government or law enforcement authorities conducting an investigation.
We have carried out an assessment on all the data processing activities described above in order to weigh up any privacy implications against our legitimate business interests. You can obtain information on any of our assessmentsby contacting us using the details set out later in this policy.
Wherever we require your consent under applicable law, you will always be able to withdraw any consent provided to us. We shall cease to use your personal data for the purpose in respect of which you have withdrawn your consent, but we may still use, process, store and transfer your data for other purposes, such as those set out above. Specifically, in the case of customers from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) contacting our Privacy Officer at firstname.lastname@example.org or sending your request by post to; Privacy Officer, Lane Crawford, 30F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong, or (b) in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.
Where permitted by law, you have the right to ask us for a copy of your personal data; to correct , delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, if you are located in the EEA you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests assessment, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are located in EEA: If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.)
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at email@example.com or by writing to Privacy Officer, Lane Crawford, 30/F, One Island South, 2 Heung Yip Road, Wong Chuk Hang, Hong Kong. You may also access, verify or update your personal data by logging into the Site or completing the “Customer Information Renewal Form” at one of our stores.
The data controllers are LCJG Limited, and its related companies; contact details can be found in the section How do I get in touch with you above.
Where we process registration data, we do this for as long as you are an active user of our Site and it is required for business and legitimate interests or legal requirement.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.
(Applicable if you are located in EEA only) Where we process personal data for site security purposes, we retain it for 7 years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for 7 years from your last interaction with us.
We will not keep the images captured by our analytics cameras for more than 1 day, and such images will be anonymized and aggregated before any use of the same for the purposes stated in How do we use this information, and what is the legal basis for this use? section above.
We place conspicuous notices in Lane Crawford stores to inform customers we prohibit unauthorised photography, sound and/or video recording for commercial use, private gain, use in press or media, or for promotional purposes in our stores. We reserve the right to remove offenders from our premises.
We permit photography, sound and/or video recording where the images/recordings are solely for personal use and are not published or reproduced in print or electronically for commercial use, private gain, use in press or media, or for promotional purposes.
Permitted photography, sound and/or video recording are subject to the following conditions:
(1) no photographs or video and/or sound footage is taken of staff members or other customers without express permission of the staff member or customer;
(2) flash and tripods are not used without written permission;
(3) customers refrain from taking photographs, and recording sound and/or video footage and/or leave the premises if;
- they are causing concern to any staff member or a nuisance to other customers;
- our staff reasonably believe the customer is causing an obstruction or compromising safety or security in any way;
- our staff reasonably suspect that photography, sound and/or video recording are for commercial use, private gain, use in press or media, or for promotional purposes.
If a customer has queries in relation to the photography policy, he/she may contact the Store Manager.
This section outlines the policies and procedures regarding the use of data analytics cameras in Lane Crawford stores. Data analytics cameras are used in our stores to generate anonymous and aggregated data for statistical research purposes, such as demographics analysis and traffic flow analysis within our stores. The anonymised and aggregated data will be used by us to help improve our services.
The only personal data we may collect is facial biometric templates derived from a facial image captured by the analytics camera (i.e. numeric information describing different facial features), which will be collected and used and processed by the analytics camera for the purposes stated above (namely, to analyse traffic flow within our stores for statistical research purposes). No video footage, images or other personally identifiable data shall be stored. All analysis conducted by the data analytics cameras based on the footage will be done in real time. Security measures are in place to prevent unauthorized access to the data analytics system.
The facial biometric templates collected using the analytics camera will be securely deleted within 24 hours of being collected, and only the aggregated and anonymised data will be retained.
Data subjects are explicitly informed that the data analytics cameras are in operation in applicable areas by notices reading “analytics cameras in operation”. We place conspicuous notices at the entrance to any monitored area and fix further notices inside the area. Notices are also posted to alert customers if the analytics cameras themselves are very discreetly located. No analytics cameras are installed in places where people have a reason to expect privacy.
The facial biometric templates collected using the analytics camera will only be disclosed to our third party service providers who operate the analytics cameras for the purposes stated above (namely, to analyse traffic flow within our stores in order to generate anonymous and aggregated data for statistical research purposes). All use or transfer of data derived from the analytics cameras will be on an anonymised and aggregated basis, such that you cannot be identified or re-identified.
If a customer has queries in relation to the operation of the data analytics cameras or in relation to privacy issues of his/her personal data, he/she may contact our Privacy Officer at firstname.lastname@example.org or by post to: Privacy Officer, Lane Crawford, 30F, One Island South, 2 Heung Yip Road Wong Chuk Hang, Hong Kong.