Privacy Policy

1. Our Commitment to Privacy

This Privacy Policy demonstrates the commitment of Techtronic Industries Co. Ltd. (the “Company”) to protect the privacy of individuals with respect to personal data and is designed to assist you in understanding our policies and practices in relation to the collection, use, retention, transfer of and access to personal data.

2. What is Personal Data

When used in this Privacy Policy, the term “personal data” has the meaning given to it in the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong, the “Ordinance”), which refers to any data-

1. relating directly or indirectly to a living individual;
2. from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
3. in a form in which access to or processing of the data is practicable.

By way of example, this may include, but is not limited to your name, employer, job title, telephone number, fax number, address and email address.

3. Collection of Personal Data

When you visit our web site, we will record your visit only and will not collect any personal data from you unless otherwise stated. Cookies used (if any) in any part of our web site will not be deployed for collecting personal data. For your information, Cookies are small pieces of data that can be stored in users' hardwares for the purposes of obtaining configuration information and analysing users' viewing habits. They are commonly used to track your preferences in relation to the subject matter of the web site and make your online experience easier and more personalized. However, if you would like to disable or block Cookies from our website you can do so via your browser settings.

When you contact us, we may collect personal data from you. Refusal to provide such information may render us unable to handle the application or request you are making, or may otherwise defeat the objectives of your visit.

4. Security

All personal data you provide to us is secured on our web site with restricted access by authorized personnel only. We utilize specific software for data transmission so as to protect your data by encrypting it in a format that ensures its privacy is secured from unauthorized access or disclosure, accidental loss, alteration or destruction. In addition, we adopt contractual or other means to prevent any personal data transferred to our data processor (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use.

5. Use of Personal Data Collected

By providing your personal data to us, upon your consent we may use and retain such data for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time (the “Purposes”):

1. providing our services and processing your enquiries and feedback;
2. processing of any benefits arising out of or in connection with the services;
3. operation and service surveys;
4. providing contacts and business details in response to enquiries and complaints;
5. incorporating into our user disclosure;
6. auditing;
7. enabling us to comply with our obligations to interconnect or other industry practices; and
8. other related purposes.

If you no longer wish us to use your personal data for the above intended use, you may at any time inform us by sending your request in writing to the Corporate Communications Enquiries at the addresses provided below.

6. Retention/Accuracy of the Information

We retain records of your dealings with us for the Purposes. Our general policy is to retain your personal data no longer than is necessary for the fulfilment of the Purposes.

We will take reasonable steps to ensure the accuracy of your personal data held by us. If we note that the personal data is inaccurate, we will not use such data and will notify any third party to which your personal data has been transferred regarding the same.

7. Sharing and Disclosure of Information

Upon you consent, the Company may transfer or transfer (whether in Hong Kong or abroad, as applicable) your personal data to:

1. any agent, contractor or other third party service provider who provides telecommunications, collection, credit reference, security, credit, banking, financial, or other professional services, to the Company;
2. any company amongst  the Company, its subsidiaries in Hong Kong or abroad (the “TTI Group”), as well as TTI Group’s local distributors in Hong Kong;
3. any of our actual or proposed assignees or transferees of our rights (whether in Hong Kong or abroad); and/or
4. any person or entity to whom the Company is under an obligation to make disclosure under the requirements of any laws, rules, regulations, codes of practice or guidelines issued by any regulatory or other authorities, for any or all of the Purposes.

8. Use of Personal Data for Direct Marketing

When we collect your personal data, we will also ask your written consent to:-

1. use your personal data for direct marketing of power tools, outdoor and floor care and Appliances goods and/or services provided by us, our agents or our subsidiaries, in relation to the services and marketing of powertools, outdoor and floor care goods and/or service offered by any company within TTI Group; and
2. transfer your personal data to (i) any agent, contractor or other third party service provider who provides telecommunications, collection, credit reference, security, credit, banking, financial, or other professional services, to the Company; (ii) any company within TTI Group; (iii) any of our actual or proposed assignees or transferees of our rights (whether in Hong Kong or abroad); and/or (iv) any person or entity to whom the Company is under an obligation to make disclosure under the requirements of any laws, rules, regulations, codes of practice or guidelines issued by any regulatory or other authorities, for direct marketing purpose stated in (a) above.

We may not so use or provide your personal data to another party unless we have received your written consent.  If you no longer wish us to use and/or provide your personal data for the above direct marketing purposes, or if you wish to give selective consent to the kinds of personal data, the classes of marketing subjects and the classes of data transferees, you may at any time inform us by sending your request in writing to the Corporate Communications Enquiries at the addresses provided below.

9. Access to and Correction of Information

Under the Ordinance, you have the right to:

1. check whether we hold any of your personal data;
2. access your personal data held by us;
3. require us to correct any personal data which is inaccurate; and
4. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.

We may charge a reasonable fee for the processing of any personal data access request. All requests for access to or correction of personal data or information regarding policies and practices and types of personal data held should be in writing and addressed to our Legal Counsel to the addresses provided below.

10. Your Consent

By using our web site and providing your personal data to us, you expressly consent to our collection and use of your personal data in accordance with this Privacy Policy. We will post any changes to our privacy policy on our web site. We are not responsible for the practices employed by web sites linked to or from ours nor the content or information contained therein.

11. Contact Address at TTI

Legal Officer
Phone number : +852 2402 6888
Fax number: +852 2413 5971
E-mail address: hklegal@tti.com.hk

Privacy Officer
Phone number : +852 2402 6888
Fax number: +852 2413 5971

E-mail address: privacy@tti.com.hk

29/F, Tower 2
Kowloon Commerce Centre
51 Kwai Cheong Road
Kwai Chung, New Territories, Hong Kong, China

South Korea Specific Section

The following section is an addendum to Privacy Policy Statement and should be read in conjunction with Privacy Policy Statement.  This addendum applies only to users residing in South Korea and describes the policies and practices of the Company in relation to the collection, use, retention, transfer of and access to personal data of its users residing in Korea.  This addendum may be amended or updated from time to time.

Items of Personal Data Collected, Purposes of Collection and Use, and Method of Collection

Items of personal data collected: Your name, your trade, your employer/company information, job title, telephone number, fax number, address and email address.

Purposes of collection and use: (a) providing information of our products and/or services to you; (b) processing any benefits, enquiries and complaints arising out of or in connection with the products and/or services; (c) providing marketing materials, promotions, and advertising; (d) processing your enquiries and feedback; (e) other related purposes for which you have otherwise made it available to us or to the public; and (f) such other purposes as shall be agreed between you and us or required by law from time to time.

Period of Retention of Personal Data

In principle, we will promptly destroy your personal data in our possession once we achieve the purposes of collection and use of your personal data.

You may also at any time request to delete your personal data or withdraw your consent to the collection and use of your personal data by contacting our Privacy Officer. The contact details of our Privacy Officer are shown above. In such case, the Company will destroy your personal data in a timely manner.

If any personal data is required to be retained under applicable law, such information will be retained for the period and purpose as prescribed by law.

 

Sharing and Disclosure of Personal Data

The Company shares your personal data with one or more of the TTI Group affiliates and third parties as described below:

Name of Recipient	Purpose of Retention and Use by Recipient	Items of Personal Data Transferred	Period of Retention and Use by Recipient
Techtronic Industries Korea Limited	(a) providing information of our products and/or services to you; (b) processing any benefits, enquiries and complaints arising out of or in connection with the products and/or services; (c) providing marketing materials, promotions, and advertising;(d) processing your enquiries and feedback; (e) other related purposes for which you have otherwise made it available to us or to the public; and (f) such other purposes as shall be agreed between you and us or required by law from time to time.	Your name, your trade, your employer/company information, job title, telephone number, fax number, address and email address	No longer than is necessary for the fulfillment of the purpose of retention and use by Recipient set out herein

Delegation of Processing of Personal Data

One or more third-party service providers perform functions relating to the processing of personal data of users in South Korea on behalf of the Company as described below:

Name of Party	Description of Function
Amazon Web Services	web hosting
Rocket Science Group	MailChimp software for email marketing

 

Process and Method of Destruction of Personal Data

The process and means of destroying your personal data are as follows.

1. Procedure

For personal data that is requested to be deleted, the data will be destroyed immediately upon request.

If we achieve the purposes of collection and use of your personal data, we will destroy these records (paper or electronic) after a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period).

Such personal data will not be used for any purpose other than the purpose permitted under the applicable laws and regulations.

In case any item(s) of personal data is required to be retained for a period beyond the period of retention and use as prescribed by applicable law, to the extent technically possible, such information item(s) will be stored or maintained separately from other items of personal data.

2. Method

The personal data that has been printed on paper will be shredded through the use of document shredder or incinerated.

The personal data stored in electronic file form will be deleted by using technical means that will not allow data recovery.

 

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