Privacy Policy

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Privacy Policy

Privacy Policy

Our Commitment to Privacy

Techtronic Asia Company Limited (Company Number: 39085), a limited liability company incorporated in the Hong Kong Special Administrative Region of the People’s Republic of China (hereinafter referred to as “Hong Kong SAR”) with the registered office at 29/F, Tower 2, Kowloon Commerce Centre, 51 Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong SAR (hereinafter referred to as “Company”, “our”, “we” or “us”), is committed to protecting the privacy, confidentiality and security of your personal data we collect through our website https://www.packout.com.hk/ (hereinafter referred to as “Website”) and at our Heavy Duty Centers (hereinafter referred to as “HDC”). We pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap 486 of the Laws of Hong Kong SAR) (hereinafter referred to as “PDPO”), the Data Protection Principles contained therein and this privacy policy (hereinafter referred to as “Privacy Policy”). In doing so, we are equally committed to ensuring that all our employees and agents uphold these requirements.

***Please read this Privacy Policy carefully before furnishing us with any information about you or any other person***

This Privacy Policy describes the personal data which we will collect or process when you access the Website or visit our HDC. It explains how your personal data will be used, shared and protected, what choices you have relating to your personal data, and how you can reach us.

For the purpose of this Privacy Policy, “TTI Group Entity” means the Company or any other person or entity directly, or indirectly through one or more intermediaries, controlling, controlled by, or under common control of the Company.

If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

Navigating this Privacy Policy

You can click on the links below to jump to the relevant section:

1. COLLECTION and USE of your personal data

We collect your personal data, that is, information (a) relating directly or indirectly to a living individual, (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained and (c) in a form in which access to or processing of the data is practicable; or such wider definition as provided in the PDPO.

Our Website and HDC are not intended for minors below the age of 18, and we do not knowingly collect personal data relating to a minor.

We set out in the following table the instances where we collect personal data from you, the types of personal data we collect and how we intend to use such data.

When we collect your personal data	Types of personal data	How we use your personal data
Visit the Website	When you visit the Website, we will record each of your visits and will automatically collect the following information: – technical information, including the Internet protocol (hereinafter referred to as “IP”) address used to connect your computer to the Internet, your login information, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform; and – information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed, searched for, filtered or purchased/redeemed, the hyperlinks you have clicked, the websites you visited before arriving at our Website, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the Website.	This information will be stored by us to administer the Website and for internal management, including troubleshooting, data analysis, testing, research, statistical and survey purposes and controlling illegal acts.
Navigating through our Customer Portal (hereinafter referred to as “Portal”)	We will collect your personal details including your name, email address and phone number when you create an account (hereinafter referred to as “Account”) on the Portal and update your personal details on the Portal. We may also collect additional personal data, such as your billing details and shipping address, when you make a purchase, register for product warranty, join our loyalty programme and redeem a gift or souvenir. Separately, if you elect to login your Account through social media (such as Yahoo, Facebook, Google, Line and Twitter), we will also collect information about your social media accounts such as your user ID and profile avatar.	This information is required by us to complete your Account registration and allow you access to our services and functions on the Portal, including without limitation, completing and processing your order or gift redemption request, updating you on the delivery progress, verifying payment status, providing you with information about your purchase history, providing you with our warranty service, operating and facilitating your participation in our loyalty programme and understanding your purchase preference.
Apply for the Asia Leadership Development Program (a program which aims at developing diverse and inspirational future business leaders) (hereinafter referred to as “Program“)	We will collect the following information when you apply for the Program through the Website: – your personal details, including your name, email address, phone number and language proficiency; – your education background, including your level of education and field of study; – personal data contained in your resume attached to your application; and – personal data you provide in the message box in the application form.	This information will be used by us to evaluate your application to join the Program and, should you be offered an opportunity to participate in the Program, to communicate with you prior to and in the course of the Program and to send you our offer terms and Program materials.
Submit online warranty registration	We will collect the following information when you submit a warranty registration on the Website: your personal details, including your name, email address and phone number; and your purchase record, including your purchase location and date of purchase.	This information will be used by us to provide warranty service to you, assist you with issues you may have with your order and provide you updates on the Company, our products and services.
Become a member of our loyalty programme	We may from time to time launch loyalty programmes and amend the membership rules of such programmes. We will collect the following information when you register as a member of the programmes and during your participation in the programmes: your personal details, such as your name, gender, date of birth, nationality, contact details, membership number, username, records of your reward earning and redemption activities, details about your redemption group nominees, photographs and other images, purchase preferences, and any information relating to any special assistance that you require; your payment details, such as card holder name, credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services) and billing and refund information; your interests, preferences, habits and opinions; records of any interactions and correspondence between us, any interactions you have with our staff or representatives and any interactions with us or posts that refer to us on social media; and your responses to surveys, research and contests conducted by us or on our behalf.	This information will be used by us to operate and facilitate your participation in our loyalty programmes, provide awards to you and administer your earning and redemption arrangements, tailor and personalise awards and offers we provide to you, provide member support, facilitate our social interactions and improve our loyalty programmes.
Contact our Jobsite Solutions (hereinafter referred to as “JSS”) team	We will collect the following information when you submit the online form to contact our JSS team: – your personal details, including your name, address, email address and phone number; – your employment details, including your profession/trade and company information; and – personal data you provide in the message box in the form.	This information will be used by our JSS team to contact you regarding, for example, the applications and obstacles you face and solutions to your power tool inventory management.
Submit a contact us form on the Website	We will collect the following information when you submit a contact us form on the Website: – your personal details, including your name, email address and phone number; and – personal data you provide in the message box in the form.	This information will be used by our team to contact you to address your questions, resolve the issues you face and provide your requested support.
Visit our HDC	We will collect your personal data when you visit our HDC, including your name, telephone number, email address and corresponding address.	This information will be used by our team to check stock availability, process your order, verify your payment details and status, provide you with any service you request, (including without limitation, aftersales service) and respond to your enquiry.

Separately, we may collect information about you from other sources, for example, from third parties we work closely with including our business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies.

We endeavour to only collect personal data which is necessary and adequate but not excessive for the purpose of collection. It is generally voluntary for you to provide the personal data requested by us. However, failure to receive the personal data marked with an asterisk (*) on the relevant forms may result in the Company being unable to process your Account enrolment on the Portal, complete your order, provide the service you request or may otherwise defeat the objectives of your visit.

Other than the specific uses of your personal data set out in the table above, personal data provided by you may also be used and retained by us (in electronic form and/or hard copy form or in any appropriate manner) for the following general purposes, for other purposes as shall be agreed between you and us or as required by law from time to time:

to provide you with information about the Company and our products and/or services;

to carry out our obligations arising from contracts entered between you and us;

to investigate complaints and suspicious transactions;

to prevent and detect crimes;

to satisfy our legal obligations;

to understand your preferences and behaviours in order to offer you a better user experience by the use of cookies and data sorting and analysis (please refer to the sections “2. Use of COOKIES” and “3. DATA ANALYTICS” below); and

to provide marketing materials to you, if you have given the necessary consent regarding direct marketing (please refer to the section “4. DIRECT MARKETING” below).

2. Use of COOKIES

Our Website uses cookies to distinguish you from other users of our Website. This helps us provide you with a good experience when you browse our Website and allows us to improve our Website.

Most of the cookies we use are “session cookies”. Other cookies remain on your device until you delete them. These cookies allow us to recognise your browser at the next visit.

As far as personal data is processed, we carry out such processing on the basis of our interest to improve the Website for our users. We only process pseudonymised data in this regard upon your visit of our Website. You can delete cookies on your device at any time and once they are deleted we cannot process any information contained in a cookie.

You can further adjust your browser so that you are informed about the setting of cookies and only allow cookies on an individual basis, exclude accepting cookies for specific cases or in general, and activate the automatic deletion of cookies when you close your browser. The functionality of the Website may be restricted when cookies are deactivated.

3. DATA ANALYTICS

We and/or our authorized service providers may use cookies, pixel or other technologies to offer you a better and faster user experience or to show you advertising, as detailed below.

a) Google Analytics

The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyse your use of our Website. The information generated by the cookie about your use of this Website will be transferred to a Google server in the United States. We use Google Analytics with the extension “_anonymizeIp ()”, so that the IP addresses transferred to Google are only processed in a shortened version in order to exclude that they are directly related to you. Google will use these data for the purposes of evaluating your use of the Website, compiling reports on website activity for our Website and providing further services related to the Website and internet usage. Google may also transfer these data to third parties, provided that it is required by law or insofar as third parties process these data on behalf of Google. Google will not associate your IP address with any other data held by Google. You can also prevent the installation of the Google Analytics cookie in the settings of your browser software. That said, if you do this, you may not be able to use the full functionality of our Website. Furthermore, you can object to data collection and storage for Google Analytics for the future at any time via Google’s browser plug-in.

For more information about Google Analytics, please refer to this link. If you visit our Website via a mobile device, you can disable Google Analytics by clicking this.

As far as personal data is processed in this regard, we carry out such processing as part of our legitimate interest for own marketing purposes. We safeguard your interests by anonymizing your IP address upon collection so that you are not identifiable.

b) Meta Pixel

We use the Meta Pixel provided by Meta Platforms, Inc. (hereinafter referred to as “Meta”) on the Website.

This allows user behaviour to be tracked after they have been redirected to the provider’s website by clicking on a Facebook advertisement. This enables us to measure the effectiveness of Facebook advertisements for statistical and market research purposes. The data collected is anonymous to us. However, this data is stored and processed by Meta. Meta may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Meta’s Privacy Policy. You can allow Meta and its partners to place advertisements on and off Facebook. A cookie may also be stored on your computer for these purposes.

You can object to the collection of your data by Meta Pixel, or to the use of your data for the purpose of displaying Facebook advertisements by contacting Meta.

Meta is certified under the Privacy Shield Agreement which guarantees compliance with European data protection legislation.

c) Google Tag Manager

With Google Tag Manager, website tags can be administered via an interface. Google Tag Manager solely implements tags. It does not place any cookies and no personal data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If certain websites are deactivated at domain or browser level, all tracking tags remain in place to the extent that they are implemented by Google Tag Manager.

d) Google Ads

Google Ads inserts a cookie or a pixel on your computer or on your mobile device if you are directed to our Website via a Google advertisement. These cookies will not be applicable after 30 days and are not intended for personal identification. If you visit certain pages of our Website and the cookie is still active, both we and Google will be able to see that you clicked on the advertisement and were forwarded to our Website. We, as well as all other clients of Google Ads, receive different cookies. The cookies affected by our Google advertisements can therefore not be followed beyond our internet service.

The information obtained from the conversion tracking serves to compile statistics on the conversion for us. We learn about the total number of users who clicked on an advertisement and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.

If you do not wish to take part in conversion tracking, you may deactivate the conversion cookie in the settings of your browser. More information on this can be obtained from Google’s Privacy Policy. You may also adjust your settings for Google advertising in the Google settings.

e) Crazy Egg

We use Crazy Egg provided by Crazy Egg, Inc. on the Website to help us analyse your use of our Website. Crazy Egg may collect information such as how you navigate around the Website and what you have clicked on. Crazy Egg may also use first-party cookies (small text files that are stored locally on your computer) for one or more of the following purposes: to help identify whether you are a first-time visitor or have previously visited, to assess usage patterns and perform traffic analysis, to identify preferences, to analyze trends, and to assess advertisement performance. Crazy Egg does not collect personally identifiable information. For more information, please refer to Crazy Egg’s Privacy Policy available at https://www.crazyegg.com/privacy. You may opt out of the tracking by Crazy Egg by following the instructions at https://www.crazyegg.com/opt-out.

4. DIRECT MARKETING

We may from time to time use your personal data in order to send you marketing materials about, including without limitation, our products, services, campaigns, events, promotions and loyalty programme updates, by electronic means (email, SMS and/or other media whether now known or available in the future), phone call, and/or by direct mail. The dispatch of such direct marketing communications may be undertaken by third-party service providers.

In addition, subject to your consent, we may transfer your personal data to other TTI Group Entities such that they can share with you their marketing materials by electronic means (email, SMS and/or other media whether now known or available in the future), phone call, and/or by direct mail. In any case, we will not share your personal data with third parties for gain.

You may opt out of receiving direct marketing communications at any time by contacting our Data Protection Officer using the contact information set forth in Section 11 below. We will then stop, and request other TTI Group Entities to stop, sending any further marketing materials to you. Please note that you may continue to receive direct marketing communications for a short period after changing your preferences while we and/or other TTI Group Entities are updating our systems.

If we use your personal data in any direct marketing communications, you have the right to request that we provide you with the source of that personal data. We will provide you with the source of personal data unless it is impracticable or unreasonable to do so.

5. SHARING of your personal data

Personal data you provide to us may be disclosed or transferred (whether in Hong Kong SAR or abroad) to:

Category	Transferee
Among TTI Group Entities	Your personal data may be transferred to relevant persons in another TTI Group Entity.
Persons/other offices within the Company	Your personal data may be transferred within the Company.
Product delivery	Your personal data may be transferred to delivery service providers for sending to you the goods you order.
Payment	Your personal data may be transferred to our banks, credit card issuers, payment gateways or payment service providers to verify your payment details and status.
Other professional service providers	Your personal data may be transferred to agents, contractors and other third-party service providers who provide telecommunications, collection, credit reference, security, financial or other professional services to us.
Data processor	Your personal data may be transferred to agents, contractors or other third-party service providers which provide data processing, data storage and data analytics services to the Company. In that case, the Company will adopt contractual and/or other means to ensure the data processors will take all practicable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and (ii) ensure that personal data will not be kept longer than necessary.
Parties and their representatives in a transaction	In the event the Company and/or any of the TTI Group Entities is involved in a merger, acquisition or due diligence exercise, your personal data may be transferred to a relevant outside party to the extent such data is reasonably required to decide on matters relating to the acquisition or merger. Examples of relevant outside party include the counterparty, their financial advisors, bankers and lawyers. Your personal data may also be transferred to new owners of the business.
Government departments, regulatory bodies and courts	Your personal data may be transferred to government departments, regulatory bodies and courts, to the extent permitted or required by applicable laws, rules, regulations, codes of practice or guidelines or pursuant to a court order.

6. PROTECTION of your personal data

All personal data you provide to us is secured on our Website or stored on our secure servers with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorized access or disclosure, accidental loss, alteration or destruction.

In addition, we will adopt contractual or other means to prevent any personal data transferred to our data processors (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorised or accidental access, processing, erasure, loss or use, if we are to engage any data processor.

However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7. RETENTION of your personal data

We aim to retain your personal data no longer than is necessary for the fulfillment of the purposes of collection unless a longer retention period is required or permitted by the PDPO or other applicable laws.

We reserve the right to close a dormant Account (i.e. an Account with no activity such as a purchase made on the Website for two years or more) and personal data connected to such Account will be discarded within reasonable time after the Account closure.

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.

8. ACCESS to and CORRECTION of your personal data

As a data subject, you are entitled to assert the rights of a data subject at any time. In particular, you have the right to:

obtain information about whether or not and, if applicable, to which extent we process personal data concerning you;

access information, in particular, the following information: stored data concerning you, purpose(s) of the processing, categories of data, recipients to whom we disclose data or duration of storage in the case of processing of personal data concerning you;

require us to correct any personal data without undue delay which is inaccurate or incomplete;

ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;

require us to delete or cease the collection, processing or use of your personal data without undue delay;

withdraw your consent given to us concerning the processing of your data at any time;

require the processing of your personal data be restricted; and

receive the personal data concerning you which you had provided to us in a structured, standard and machine-readable format, and to transmit these data to another controller.

If permitted by law, we may charge a reasonable fee for personal data access request.

If you would like to exercise any of the above rights, please contact our Data Protection Officer using the contact information set forth in Section 11 below.

9. THIRD-PARTY WEBSITES

The Website may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. We do not assume any responsibility or liability for any of those websites, Those websites may have their own privacy policies, and we do not assume any responsibility or liability for those policies. We recommend you carefully reading those policies before you submit any personal data on those websites.

10. CHANGES to the Privacy Policy

We reserve the right to update, revise, modify or amend this Privacy Policy from time to time. We therefore ask you to review this Privacy Policy frequently. Changes and clarifications will take effect immediately (unless otherwise stated) upon their posting on the Website.

11. QUESTIONS, complaints and feedback

If you have any enquiries, suggestions, requests or complaints in respect of this Privacy Policy, please feel free to contact our Data Protection Officer at:

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

Email:
[email protected]

Toll-free Phone number:
800-906-149

Effective Date: 2023-02-01