Privacy policy
This Privacy, Security and Cookies Policy ("Privacy Policy") applies to the processing of data collected from you when you use our website located at www.ventana-sportswear.com (the "Website") (whether through desktop, mobile phone, tablet, or other devices), use our services available to Ventana members via the Website or any other mobile applications made available by Ventana Consultancy Company Limited and its affiliates (the “Apps”), and purchase our products from our official stores at third-party online platforms (collectively, “Services”). In this Privacy Policy, "Ventana Sportswear", "we", "our," and "us" refers to Ventana Consultancy Company Limited and its affiliates, and "you" refers to the user of the Services, with the grammatical derivatives of the foregoing to be construed accordingly.
We use and process your Personal Data (as defined below) in accordance with the provisions of this Privacy Policy, the Personal Data (Privacy) Ordinance (Cap 486, Laws of Hong Kong) ("PDPO"), and Macau's Personal Data Protection Act (“PDPA”). Your use of the Services indicates your acceptance of the current version of this Privacy Policy, which may be updated from time to time. Any update of the Privacy Policy will be published on the Website and/or Apps. We will provide you with prior notice or request your prior consent for the changes in the way in which we process your personal data if it is legally required. You are strongly recommended to review the Privacy Policy on the Website regularly to keep yourself informed of the latest update of the Privacy Policy. Any changes to the Privacy Policy will be effective upon posting of the same on the Website and/or Apps. If you do not agree with the terms of the revised Privacy Policy, you should terminate your use of the Services.
Subject to Section 9 of the Privacy Policy, persons below the age of 18 may only provide Personal Data to us if they have written permission from one of their parents or their legal guardians who has read, understood and agreed to this Privacy Policy. If you are below the age of 18, by using the Services, you represent and warrant that you already obtained consent from your parent or legal guardian to use the Services and your parent or legal guardian has read, understood and agreed to this Privacy Policy.
1. HOW WE COLLECT PERSONAL DATA FROM USERS
You are not obligated to provide any information to us. We collect Personal Data that you disclose to us when you use the Services. For example, you may submit information when you make purchases; when you request information; when you register/sign up for our newsletter, elect to receive marketing communications, create and/or log in your online account; when you register as a Ventana member and/or log in your Ventana membership account, when you use, enjoy or exercise the rights, benefits, and our services for Ventana members, or when you participate in any other Services. Such Personal Data may include your name, address, telephone number, email address, gender, date of birth, credit card information, username, and password (for account holders and Ventana members), your personal preference (including but not limited to your interest and your favorite sports) ("Personal Preference"), and other information about you (collectively, "Personal Data"). We then use the Personal Data to create a user profile. In this context, we may combine the Personal Data you give us with other information we hold regarding transactions and communications collected or processed by any member of the Ventana group and authorized subcontractors. We also automatically collect certain data about your use of the Website, such as log files, cookies, browser type, and other computer or device information as described below.
The provision of your Personal Data is voluntary. However, if you do not provide us with certain Personal Data, we may not be able to provide you with our Services.
2. PURPOSE OF PROCESSING PERSONAL DATA
We may use data from you for a number of purposes:
If you have elected to receive direct marketing communications from us, your Personal Data may be used by us to contact you or send you information about us, our membership program, the latest news on Ventana branded promotions and products, including but not limited to apparel, footwear, sports gear, and other related products, and/or benefits, gifts, and/or information relating to promotions to be offered or launched by Ventana or jointly with its promotion partner(s) from time to time. Further, as Ventana also retains service providers for sending direct marketing communications, you agree to us providing your Personal Data to our retained service providers for the aforesaid purposes. Ventana intends to use or provide such Personal Data for direct marketing communications, and it may not use or provide your Personal Data unless Ventana has received your consent to such intended use or provision. We and/or our retained service providers will contact you or send you such information by means of e-newsletters, e-mails, SMS, personal phone calls, mail and/or post. For such direct marketing communication purposes, we may use and process your name, email address, mobile phone number, gender, date of birth, shipping address, and an overview of communications we have sent you, as well as provide the same to our retained service providers. You can decide not to receive such communications or updates from us and withdraw your consent to our provision of your Personal Data at any time by contacting us by email or using the unsubscribe option included in each email.
Your Personal Data may also be processed by us for the technical and functional management of the Website. When you visit the Website and/or use, enjoy, or exercise the rights, benefits, and services for Ventana members, administrators of our Website process technical data linked to the use of the Website to enable us to deliver the functionalities of the Website. With this technical data, the administrators of the Website can manage the Website, for example, by resolving technical difficulties or improving the accessibility of certain parts of the Website. By this way, we ensure that you can continue to find the information on the Website quickly and simply. For this purpose, we use cookies, as discussed in Section 7, and process technical data like the IP-address of your computer, the visited webpage of the Website, the Internet browser you use, previous/next visited Websites, and the duration of each visit/session. We may retain technical data for as long as legally required for this purpose.
When you contact us other than through the Website or email communications, we may use your Personal Data to answer your questions. For this purpose, we process your name, your contact information, your correspondence with us about your question, and all other Personal Data you provide us with and which is required to answer your question. Your Personal Data will be kept in our systems until it is no longer needed for any purposes set out in this Privacy Policy or directly related purposes (or for as long as legally required) and will then be deleted.
When you register an account with us on the Website and become a Ventana member, your mobile number and/or email address, first and last names are required for such purpose. We may also ask for your gender, date of birth, and district information. If you do so, it would help to improve our membership services and enhance your experience in using the Website and enjoying the membership rights, benefits, and services. If you opt not to provide us with such information, your fundamental membership rights and benefits and our membership services will not be affected.
Your Personal Data may also be used for the following purposes:
a. Providing the Services to you, including but not limited to administering, maintaining, managing, and operating our services and products, managing, processing, and fulfilling your transactions and orders via the Website;
b. Collating management information and statistical data;
c. Organizing our prize contests, lucky draws, events, competitions, marketing promotions, and/or games of chance which you may participate in and announcing and distributing the related prizes to the winners;
d. Meeting disclosure obligations and other requirements imposed by or for the purposes of any laws, regulations, rules, regulations, codes of practice, or guidelines (whether applicable in or outside Hong Kong) binding on us including making disclosures to any legal, regulatory, governmental, tax, law enforcement, or other authorities;
e. Administering, maintaining, managing, and operating our membership scheme and providing membership services as available from time to time, including but not limited to processing membership applications, verifying the identity of members, creating, maintaining, managing, operating, and customizing membership accounts, recording your transactions/orders, distributing coupons, and membership benefits and discounts, providing updates, details, and information about the membership scheme from time to time and investigating suspicious transactions and orders;
f. Attributing the content you post;
g. Processing payments and payment instructions;
h. Investigating, preventing, or stopping fraud and abuse;
i. For bookkeeping;
j. Fulfilling any other purposes directly related to (a) to (i) above.
3. WHO HAS ACCESS TO YOUR PERSONAL DATA
We use third parties for certain processing activities on our behalf to operate the Website and in the provision of Services, such as Website hosting, order processing, payment processing, delivery of products or services, delivering content, management of the Website, management of the membership services, and management of promotional activities held at our retail stores. To the extent these third parties have access to Personal Data in order to execute these processing activities, we have taken the required organizational and contractual measures to ensure that Personal Data provided by us to these third parties is exclusively processed for the purposes mentioned above. These third parties are not authorized to send you any information about products and services from other companies without your permission.
You acknowledge and agree that we may engage third-party payment processors for the purpose of processing your payments made via the Website from time to time. The Personal Data, which contains your payment information including but not limited to your credit/debit card number, holder's name, and CCV that we collected, will be passed to such payment processors, their affiliates, and/or their agents (if necessary) solely for the aforementioned purpose. The handling of your Personal Data by such third-party vendors, their affiliates, and/or their agents (if necessary) will be governed by their respective privacy policy.
Now and then, we may organize a lucky draw, prize contest, promotion, marketing, or game of chance in cooperation with a third party. In such a case, this will be stated clearly on the Website. If you elect to participate in such a prize contest, event, or games of chance, your Personal Data will (to the extent required) be made available to these third parties, to the extent of necessity.
In accordance with applicable laws, we may also release Personal Data in special cases in order to comply with any requests from law enforcement and government agencies, to enforce the terms of use of the Website and other agreements, and to protect customers and others. We may do so when we believe in good faith that disclosing this information is otherwise necessary or advisable, including, for instance, to identify, contact, or bring legal action against someone who may be causing injury to or interfering with the rights or property of our company, another user, or anyone else that could be harmed by such activities.
We may share your Personal Data with entities which belong to the Ventana Group, which may reside outside Hong Kong or your home country. For the purpose of this Privacy Policy, an affiliate of Ventana means a company or any other entity or person (as the case may be) which controls, is controlled by, or is under common control with Ventana.
We may transfer Personal Data to an affiliate or third party as part of a transfer of business assets through a merger or an acquisition. Should this happen, notice will be provided to you by posting on the Website or through other forms of communication.
To facilitate the purposes set out in this Section 3, we may transfer, disclose, grant access to, or share your Personal Data with the third parties set out in this Section 3, and you acknowledge that those parties may be based outside Hong Kong, Macao, and your home country (including in the United States and within the European Union) and that your Personal Data may be transferred to places where the data protection laws are substantially different from, or do not serve the same purposes as the PDPO or PDPA. Where your Personal Data is transferred pursuant to this Section 3, we take steps to ensure that the third-party recipient residing outside of Hong Kong or your home country accords your Personal Data with a standard of protection at least equivalent to the PDPO or PDPA and, as required, the laws of the jurisdiction where you reside. We also require that such third parties keep your Personal Data confidential.
4. LOG FILES
As with most websites and online platforms, we automatically gather non-personally identifiable information and store it in log files through the Website. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify users, to analyze trends, administer the Website, and gather demographic information about our user base as a whole. We do not link this automatically collected information to personally identifiable information.
5. SOCIAL MEDIA WEBSITES, PLATFORMS, OR CHANNELS
Finally, if you publicly post about us or communicate directly with us on social media websites, platforms, or channels including but not limited to Facebook, Instagram, Twitter, LinkedIn, Pinterest, etc., we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customer service requests you may have and to monitor and influence public opinion about us. In addition, your activity on our Website will also be made available to the said social media websites, platforms, or channels for the aforementioned purposes. If you choose to share our Website through such social media websites, platforms, or channels, your personal data (such as your name and the fact that you are interested in our Ventana brand) may also be visible to all the visitors of your personal webpage on such media channels, depending on your account settings. Your use of such social media websites, platforms, or channels is governed by the terms and conditions (including the privacy policy) of the applicable social media websites, platforms, or channels. We are not responsible for the processing of Personal Data or the privacy policy of such social media websites, platforms, or channels. Our General Terms and Conditions and this Privacy Policy are not applicable to the use on such social media websites, platforms, or channels.
6. LINKS TO OTHER WEBSITES
On the Website you will find a number of links to other websites. Although these websites are selected with care, we are not responsible for the processing of your Personal Data through these websites. Our General Terms and Conditions of use and sale and this Privacy Policy are therefore not applicable to the use of such websites. You shall only access or continue to use such websites and/or provide your personal data to/via such websites if you agree with the terms and conditions and privacy policy of such websites. Your access and use of such websites and provision of any personal data to/via such websites shall be at your own decisions and risk.
7. COOKIES ON THE WEBSITE
The Website uses cookies. Cookies are small pieces of data sent by the Website and they are stored by your browser on your computer's hard drive so that we are able to recognize your browser when you return to the Website. Cookies can collect data on the use of the Website such as which pages are visited and the duration of a user session. When you use the Website, the cookie sends data to us. On our Website, we use strictly necessary cookies, performance cookies, functionality cookies, advertising cookies, first-party cookies, third-party cookies, persistent cookies, and session cookies. Strictly necessary cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like shopping baskets or e-billing, cannot be provided. Performance cookies collect anonymous information about how you use the Website and the pages that you have visited, for instance which pages you go to most often, and if you get error messages from web pages. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. This information is only used to improve how our Website works. Functionality cookies remember your selection and choices to improve your experience on our Website. Advertising cookies collect information about your browsing habits to make advertising relevant to you and your interests. First-party cookies allow us to understand who has visited which page(s), to determine how frequently particular pages are visited and to monitor the usage of the Website. If you wish to disable cookies, you can do so by re-adjusting your browser settings. Please note that if you disable all or some of the cookies you may not be able to register with or use all features of our Website.
8. HOW WE PROTECT PERSONAL DATA
We treat the security of your Personal Data seriously. We utilize appropriate administrative, technical, and physical safeguards and security measures to protect the Personal Data you provide during our provision of the Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use and any other unlawful forms of processing. We use several security techniques including secure servers, firewalls, and encryptions as well as physical safeguards at the locations where the data are stored. For example, when you are logged in and fill in forms or access your data on the Website, a secure connection is used (http via SSL, also known as HTTPS). The data you enter is automatically encrypted before it is sent. All the data is protected and only available to authorized personnel and subcontractors. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
9. MINORS PROVIDING PERSONAL DATA
You must be 18 to establish an account with us and/or register as a Ventana member.
10. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be changed over time without prior notice: users of the Website and Ventana members are advised to regularly review this Privacy Policy for possible changes. This Privacy Policy was last modified as of the date stated above. Unless otherwise required by the applicable laws and regulations, you will be deemed to have accepted and agreed to the revised Privacy Policy then in effect by accessing or using the Website or creating or logging in your Ventana membership account (as the case may be) each time.
11. CONTACT – RIGHT TO ACCESS AND CORRECT PERSONAL DATA
If you have any questions, comments, or complaints about us or how we process your Personal Data or in case you wish not to be contacted by us for direct marketing purposes anymore, please contact us at the email below. Also, upon request, we will provide you with a summary of any personally identifiable information collected and retained by us regarding you. You may modify, correct, or update your Personal Data or request to have your Personal Data removed from our database. We will only send copies of Personal Data to the email address on file for the visitor name associated with it. Under the PDPO or PDPA, we may have the right to charge you a reasonable fee for processing and complying with your data access request.
Our contact details are:
Email: onlineshop@ventana-sportswear.com
12. LANGUAGE
If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.