Controller

Praiskon Ltd is the controller and responsible for your personal data (collectively referred to as “HK Praiskon”, “we”, “us” or our in this privacy notice).

Data protection law requires HK Praiskon, as controller for your data:

• to process your data in a lawful, fair and transparent way;
• to only collect your data for explicit and legitimate purposes;
• to only collect data that is relevant, and limited to the purpose(s) we have told you about;
• to ensure that your data is accurate and up to date;
• to ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
• to ensure that appropriate security measures are used to protect your data.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 3rd June 2024. We may periodically update this Privacy Policy. If any significant changes are made, we will provide you with a minimum of two months' advance notice to allow you to exercise your rights, if applicable, before the changes take effect. You will be notified of such changes using the contact information you provided in your most recent correspondence with us.

To ensure that the personal data we hold about you is accurate and up-to-date, we may occasionally ask you to verify and update your information. However, please inform us of any changes to your personal data during your relationship with us by contacting us at: info@hkpraiskon.com.

Third-party links

This website may include links to external websites, plug-ins, and applications. By clicking on these links or activating these connections, third parties may collect or share your information.

We, along with our partners such as Amazon and TikTok, maintain a social media presence to engage with our customers.

Please note, if you decide to enable these connections or share your personal information through third-party websites or social media platforms, we do not have control over these external sites and are not responsible for their privacy practices. Once you leave our website or interact with us on social media, we recommend you review the privacy policy of each website or platform you use.

2. The data we collect about you

Personal data, or personal information, refers to any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer various types of personal data about you, which we have grouped as follows:

• Identity Data: Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and photographs.
• Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
• Technical Data: Includes Internet Protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: Includes information about how you use our website, products, and services.
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.

We refer to the above categories of data in the data subject category tables which are provided below:

We also collect, use, and share Aggregated Data such as statistical or demographic data for various purposes. Aggregated Data may be derived from your personal data but is not considered personal data under the law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data such that it can directly or indirectly identify you, we will treat the combined data as personal data and use it in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data, and biometric data. Additionally, we do not collect any information about criminal convictions and offences.

Failure to Provide Personal Data

If we are required by law, or under the terms of our contract with you, to collect personal data and you fail to provide the requested information, we may be unable to fulfil our contractual obligations (for example, providing you with goods or services). In such circumstances, we may need to cancel a product or service you have with us, but we will inform you if this is necessary at the time.

3. How is your personal data collected?

We use various methods to collect data from and about you, including:

• Direct interactions

You may provide us with your Identity and Contact Data by filling in forms or by corresponding with us via post, phone, email, or other means. This includes personal data you provide when you:

• Subscribe to our services or publications
• Request marketing materials
• Enter a competition, promotion, or survey
• Provide feedback
• Automated Technologies or Interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. This personal data is gathered using cookies, server logs, and similar technologies. Additionally, we may receive Technical Data about you when you visit other websites that employ our cookies. Please refer to our cookie policy for more details.

• Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties and public sources, including:

• Technical Data from analytics providers like Google.
• Contact Data from providers of technical services such as TikTok Ads Manager, a function of the TikTok Business Centre that enables registered entities to analyze ad view data.

How We Use Your Personal Data

We will only use your personal data when permitted by law. Most commonly, we will use your personal data in the following circumstances:

1. When we need to perform the contract we are about to enter into, or have entered into, with you.
2. When it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. When we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, except for sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We aim to give you control over how your personal data is used, particularly regarding marketing and advertising. We have established mechanisms for you to manage your personal data, as detailed in the 'Opting Out' section below.

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what products, services, and offers might be of interest to you. This is how we decide which offerings are most relevant for you (this process is referred to as marketing).

You will receive marketing communications from us if you have requested information, purchased goods or services, or provided us with your details when registering for a promotion, unless you have opted out of such marketing communications.

Third-Party Marketing

We will obtain your explicit opt-in consent before sharing your personal data with any company outside the HK Praiskon group of companies for marketing purposes.

Opting Out

You can stop receiving marketing messages from us or third parties at any time by logging into the website and adjusting your marketing preferences, following the opt-out links in any marketing message sent to you, or by contacting us directly.

Please note that opting out of marketing communications will not affect personal data provided to us due to a product/service purchase, warranty registration, product/service experience, or other transactions.

Cookies

You can configure your browser to refuse all or some cookies or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies, some parts of this website may become inaccessible or may not function properly. For more details about the cookies we use, please refer to our cookie policy.

Privacy Settings

To provide you with the best possible experience of our products and services, we use cookies and similar technologies. For technologies that are not strictly necessary for the operation of our website, we and our partners require your consent.

By clicking 'Accept all cookies', you consent to the use of all such technologies and the related data processing.

Under 'Personalize', you can choose the specific purposes and partners to whom you wish to grant consent and confirm your choices by clicking 'Save'.

You can revoke or change your consent at any time with future effect by adjusting and saving your preferences.

Purpose of the Technologies:

Necessary: These technologies provide essential functionalities, such as page navigation, without which the website cannot operate properly.
Preferences: These technologies store information to tailor the website to your preferences, such as your preferred language.
Statistics: We use statistical tools to understand how our customers use our website, enabling us to improve our services and website experience.
Marketing: These technologies allow us to recognize you across partner sites and the broader internet, display personalized advertising, and measure the effectiveness of our advertisements. For personalized advertising, usage profiles are created which may be supplemented by other data.

For data processing by our partners, information may be transferred to third countries outside New Zealand that might not offer the same level of data protection as New Zealand. In such cases, we ensure compliance with data protection standards through EU standard contractual clauses and, where applicable, an adequacy decision by the EU Commission, such as the Data Privacy Framework.

Change of Purpose

We will only use your personal data for the purposes for which it was originally collected, unless we determine that another use is compatible with the original purpose. If you would like an explanation of how a new purpose is compatible with the original one, please contact us.

If we need to use your personal data for an unrelated purpose, we will inform you and provide an explanation of the legal basis that permits this new use.

Please note that, in accordance with applicable laws, we may process your personal data without your knowledge or consent if required or permitted by law.

4. Disclosures of Your Personal Data

We may need to share your personal data with third parties if we decide to sell, transfer, or merge parts of our business or our assets. Similarly, if we acquire or merge with another business, the new owners may use your personal data in the same manner as described in this privacy notice.

We require all third parties to respect the security of your personal data and to handle it in accordance with the law. Our third-party service providers are not permitted to use your personal data for their own purposes and may only process your data for specified purposes in line with our instructions.

5. International Transfers

We may share your personal data within Praiskon Ltd., which can involve transferring your data internationally.

Many of our external third parties are located outside the European Economic Area (EEA), which requires the transfer of your personal data outside the EEA.

When transferring your personal data outside the EEA, we ensure a similar level of protection by implementing at least one of the following safeguards:

• We only transfer your personal data to countries that have been deemed to provide an adequate level of protection by the European Commission. For more details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• For certain service providers, we use specific contracts approved by the European Commission, ensuring that personal data receives the same level of protection as it does within Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• When using providers based in the US, we may transfer data to them if they are part of the Privacy Shield framework, which requires them to provide similar protection for personal data shared between Europe and the US. For more details, see European Commission: EU-US Privacy Shield.

6. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. Additionally, we limit access to your personal data to employees, agents, contractors, and third parties who have a business need to know. They will only process your personal data according to our instructions and are bound by a duty of confidentiality.

We have established procedures to address any suspected personal data breaches and will notify you and any relevant regulatory authorities if we are legally required to do so.

7. Data Retention

How long will you use my personal data for?

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including meeting any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for processing your data and whether we can achieve those purposes by other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us.

By law, we must retain basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease to be customers for tax purposes.

In certain circumstances, you can request that we delete your data (see the "Request Erasure" section below for more information).

In some cases, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For more information on these rights, please visit the ICO website.

Your rights include:

• Request Access: You can request access to your personal data.
• Request Correction: You can request correction of your personal data if it is inaccurate or incomplete.
• Request Erasure: You can request the deletion of your personal data.
• Object to Processing: You can object to the processing of your personal data.
• Request Restriction: You can request the restriction of processing of your personal data.
• Request Transfer: You can request the transfer of your personal data to another party.
• Withdraw Consent: You have the right to withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not typically have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under these circumstances.

What we may need from you

We may request specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it. We may also contact you for further information regarding your request to expedite our response.

Time limit to respond

We aim to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or if you have made several requests. In such cases, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to address your concerns before you approach the ICO, so please contact us first.

9. Glossary

Lawful Basis

Legitimate Interest: This means the interest of our business in managing and running our operations effectively to provide you with the best service and a secure experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the potential impact on you, unless we have your consent or are otherwise required or permitted by law. For further information on how we assess our legitimate interests against any potential impact on you concerning specific activities, please contact us.

Performance of Contract: This refers to processing your data when it is necessary for the execution of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Compliance with Legal or Regulatory Obligations: This involves processing your personal data when it is necessary to comply with a legal or regulatory obligation to which we are subject.

10. Your Legal Rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.