Persons below the age of 18 may only provide Personal Data to us if they have written permission of 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 accessing and using the Website, you represent and warrant that you already obtained consent from your parent or legal guardian to use the Website and your parent or legal guardian has read, understood and agreed to this 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.gwanna.com (the "Website") (whether through desktop, mobile phone, tablet or other devices) or use our services available to gwanna members via the Website. In this Privacy Policy, "we", "our" and "us" refers to Gwanna., and "you" refers to the user of the Website and the grammatical derivatives of the foregoing shall 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"). Your use of the Website and the gwanna membership services provided via the Website indicates your acceptance of the current version of this Privacy Policy, which may be amended from time to time. You can determine when this Privacy Policy was last revised by referring to the "Last Updated" legend at the top of this page. If you do not agree with the terms of the revised Privacy Policy, you should terminate your use of the Website and the use of the gwanna membership services.
1. HOW WE COLLECT PERSONAL DATA FROM USERS
When you visit our Website, you are not obligated to provide any information to us. Under the PDPO we are the data user for the processing of your Personal Data. We collect Personal Data that you disclose to us when you use the website or our services. For example, you may submit information when you make purchases; when you request information; when you register/sign up for our newsletter, enroll in our loyalty programs, create and/or log in your online account; when you register as our gwanna member and/or log in your gwanna membership account, when you use, enjoy or exercise the rights, benefits and our services for gwanna members or when you participate in any other service offered or available at the Website. Such Personal Data may include your name, address, telephone number, email address, gender, date of birth, credit card information, username and password (for account holder and gwanna member), your personal preference (including but not limited to your interest and your favorite games) ("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 online with other information we hold, as regards transactions and communications collected or processed by any member of the Gwanna 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.
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 send you information about us, our loyalty program and/or to receive the latest news on gwanna branded promotions and products including but not limited to game software, game hardware, game accessories, game premiums, toys and other products. We will send you such information by means of e-newsletters, e-mails, SMS, personal phone calls and by mail or by post. For this purpose, we process your name, email address, mobile phone number, gender, date of birth and shipping address, and an overview of communications we have sent you. We retain your Personal Data for as long as you wish to receive direct marketing communication from us. You can decide not to receive such communications or updates from us at any time by contacting us or by using the unsubscribe option included in each emails.
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 gwanna 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 instance 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 in a quick and simple manner. 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's of the Website, the Internet browser you use, previous/next visited Website 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 question. 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 for as long as legally required and will then be deleted.
When you register an account with us on the Website and become gwanna member, we may ask for your Personal Preference. You are not obliged to provide us with your Personal Preference. 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 your Personal Preference, your fundamental membership rights and benefit and our membership services will not be affected.
Your Personal Data may also be used for the following purposes:
a)Providing our services and products 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 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 disclosure to any legal, regulatory, governmental, tax, law enforcement or other authorities;
e)Administering, maintaining, managing and operating our gwanna membership scheme and providing membership services as available from time to time, including but not limited to processing membership application, verifying the identity of gwanna members, creating, maintaining, managing, operating and customising 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)Process payments and payment instructions;
h)Investigating, preventing or stopping fraud and abuse;
i)For bookkeeping;
3. WHO HAS ACCESS TO YOUR PERSONAL DATA
We use third parties for certain processing activities on our behalf to operate the Website, such as Website hosting, order processing, payment processing, delivery of fulfilment of products or services, delivering content, management of the Website and management of the gwanna membership services. 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 help 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 aforesaid 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. If you are not agreeable to the privacy policy of the relevant third-party vendor, its affiliates and/or its agents, you should not choose the payment solution offered by such vendor, its affiliates and/or its agents.
Now and then, we may organize a lucky draw, prize contest, promotion, marketing or game of chance in co-operation 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 Gwanna and 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 communications.
To facilitate the purposes set out in this Section 2, we may transfer, disclose, grant access to or share your Personal Data with the third parties set out in this Section and you acknowledge that those parties may be based outside Hong Kong 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 to, or do not serve the same purposes as the PDPO.
Where your Personal Data is transferred pursuant to this Section, we take steps to ensure that the third party recipient residing outside of Hong Kong or your home country accord your Personal Data with a standard of protection at least equivalent to the PDPO 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, data/time stamp, and clickstream data. We use this information, which does not identify users, to analyze trends, to administer the Website and to 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, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customers services requests you may have and to monitor and influence public opinion about us. Please note that, if you choose to select that option, your activity on our Website will also be made available to social media websites, platforms or channels such as but not limited to Facebook, Instagram, Twitter, LinkedIn, Pinterest, etc. 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 Gwanna brand) may also be visible to all the visitors of your personal webpage on such personal media channels (such as LinkedIn, Facebook and/or Twitter), 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 on 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 in our Website. For instance, the cookies enable you to place products in your shopping cart and review the contents of your shopping cart. These cookies allow us to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, we may be able to recognize if the you already signed up for our newsletter or if the user is seeing a certain page for the first time. The information these cookies collect is aggregated and therefore anonymous and they cannot track your browsing activity on other websites.
Advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the Website operator's permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.
First party cookies allow us to understand who has visited which page(s), to determine how frequently particular pages are visited and to determine the most popular areas of the Website and to monitor the usage of the Website.
Third party cookies are used for analyzing traffic sources and visitor behavior as well as for controlling access and site features across the Website.
Session cookies are used to store information about your page activities so you can easily pick up where you left off on the server's pages. When you close the internet browser, the session is ended and the cookie is deleted.
Persistent cookies are employed to store your preferences and to recognize you at a subsequent visit.
Not strictly necessary cookies: Only if you have given prior consent, we place cookies that are not strictly necessary for providing the functionalities of the Website. Through such non-strictly necessary cookies we collect information about your use of the Website and remember your preferences. Examples of collected information are pages visited and the length of a user session. Through these cookies we aim to improve your user experience of our Website. If you do not consent to these cookies being placed on your browser, these cookies will be blocked and it will affect the loading speed, functionality and overall experience of the Website.
Most web browsers automatically accept cookies and allow some control of most cookies through the browser settings, though you do not have to. We do not control the use of cookies by third parties other than the agents who provide the web analytics service for the Website. If you wish to disable cookies then 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.
For more information on cookies and how to disable them generally please contact your helpdesk administrator or contact your web browsers support. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.cookies.org or www.allaboutcookies.org
Our Website uses Google Analytics, which is a web analysis service that is offered by Google Inc. (Google). Google Analytics uses cookies to analyze the usage of the Website by users. Google uses aggregated statistical data to give us an insight in the way you use the Website. Google may only provide these data to third parties if Google is required to do so by law, or to the extent third parties processing these data on behalf of Google. You can find more information on Google Analytics here.
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 on this Website 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 safeguard of 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 an gwanna member.
10. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be changed over time without prior notice: users of the Website and gwanna members are advised to regularly review this Privacy Policy for possible changes. This Privacy Policy was last modified as of the date stated above. By accessing or using the Website or creating or logging in your gwanna membership account (as the case may be) each time, you have agreed and accepted (and you are regarded as having agreed and accepted) this Privacy Policy as of the date stated above.
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 we have the right to charge you a reasonable fee for processing and complying with your data access request.
Our contact email:
Email: [email protected]
12. LANGUAGE
If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.