PRIVACY POLICY

 

Privacy Policy

Last updated: 1 October 2025

 

China-Hongkong Photo Products Holdings Limited (“CHKP”), its subsidiaries and affiliates, (collectively referred to as “CHKP Group”, “we”, “our”, or “us”) are dedicated to safeguarding the privacy of your personal data. We strive to ensure full compliance with all relevant data protection laws, including the Personal Data (Privacy) Ordinance (“PDPO”) of the Hong Kong Special Administrative Region.

This policy outlines our practices concerning the collection, use, and handling of your personal data.  It also informs you of your legal rights, including your right to make data access requests and data correction requests. By using our websites, applications (including mobile apps), services, or interacting with us, you may share personal data with us. We encourage you to read this policy thoroughly before furnishing us with any personal data.

For the purposes of this policy, our Products and Services encompass a comprehensive range of offerings, including but not limited to: photographic equipment and accessories; skin, hair and makeup care products;  health and wellness products; consumer electronics and household appliances; commercial and professional audio-visual equipment; stationeries and lifestyle goods; repair and maintenances services for photographic, consumer electronics, household appliance, and commercial and professional audio-visual products; photo developing, processing and printing services; document printing and scanning services; imaging solutions; professional audio-visual advisory, custom design and installation services; as well as workshops.

We will communicate any material changes to this policy by posting the updated version on our website. Changes become effective immediately upon posting, unless otherwise stated.  This policy was originally written in English. In the event of any inconsistency between the English version and any translated version, the English version shall prevail.

 

1. How We Collect Personal Data

 

We collect personal data for specific, lawful purposes through fair and legal means.  We only collect data that is necessary, and not excessive, for these purposes.  We may obtain personal data from you in a number of ways, such as:

• when you shop at our stores (both online and offline);
• when you participant in our events or promotions;
• when you apply for or use our membership cards or participate in any of our loyalty or promotion programs;
• when you register an account with us;
• when you participate in any surveys or marketing campaigns;
• when you login to visit our websites, use our mobile applications or view any of our social media pages;
• when you use the wifi services at our stores or events;
• when you contact us whether in person, by phone, by email or via any social media platforms (including our websites), to make enquiries or provide information;
• when verifying your identity; and
• when you subscribe to our marketing or promotional materials.

 

2. Types of Personal Data We Collected

The types of personal data we collect may include but are not limited to:

• basic identification and personal information (such as title, name, gender, and date of birth);
• contact details (such as mailing, delivery address, email address and phone number);
• payment details (such as payment (including billing address) or credit card information);
• login username and password of our websites and membership programs;
• image and audio data (such as photographs, videos, and their associated metadata, which you submit to us for processing, printing, or other services);
• information collected by means of cookies (including but not limited to webpages visited and options chosen); and
• CCTV images (still or video images from security cameras we have in our stores).

It is voluntary for you to provide the personal data requested by us. However, if you fail to provide the required personal data or if the personal data provided is inaccurate or incomplete, we may not be able to provide you with our Products, Services, benefits or to proceed with the requests made by you. 

 

3. Purposes of Collection

 

Your personal data may be used for one or more of the following purposes (“Purposes”):

• communicating with you;
• verifying your identity and any accounts you have with us; simultaneously manage accounts or merge related accounts;
• administering any loyalty or other marketing, promotional or corporate programs that we are involved in, including providing you the benefits you are entitled;
• processing your orders for Products and Services you place with us (such as maintaining your shopping carts, attending to billing payments, refunds and delivery arrangements);
• customizing the information displayed on our shopping website/ apps and social networking/ media platforms to create better user experience;
• designing targeted promotional offers;
• conducting advertising activities, including targeted advertising;
• conducting direct marketing activities;
• fulfilling our obligation to maintain records of processing activities;
• handling enquiries, job applications or complaints;
• meeting legal, regulatory or compliance requirements, dealing with enquiries from law enforcement or regulatory bodies or for the purpose of obtaining legal advice; and
• any other purpose reasonably related to any of the above.

 

4. Data Collection from Digital Platforms

 

You may note that certain data may be collected in your use of our digital platforms:

• Cookies: Our website use cookies - small text files stored on your device – to enhance your experience by remembering your preferences.
• Use of Cookies: We use cookies to analyze website traffic and user behavior.  This data is aggregated and statistical, not identifying you personally, and helps us to improve our websites and services. 
• Managing Cookies: You can configure your browser to refuse cookies.  Note that disabling cookies may limit your use of some website features. 
• Pixel Tags: We may use invisible pixel tags on our pages to track visits.  These work with cookies; disabling cookies makes the visit anonymous.
• Analytics Tools: We use tools like Google Analytics to understand website usage. Google Analytics will store and use the information which we are not responsible therefor. You are invited to familiarize yourself with Google’s privacy policy or if applicable, the privacy policy of other tool providers to find out how they use Cookies, storage and use of the information.

 

5. Direct Marketing

 

We may, from time to time and only with your prior consent, use your personal data to send you marketing materials about, including without limitation, our Products, Services, offers, promotions, campaigns and events.

You may opt out of receiving direct marketing communications at any time by post or by email to our Data Protection Officer, the contact details are set out at the end of this policy. In the case of direct marketing email, you may opt out by following the steps set out in the email.

 

6. Security of Personal Data

 

We take reasonably practicable steps and implement internal protocols to protect your personal data from unauthorized access, loss, or misuse.

The personal data is stored securely with access restricted to authorized personnel only. We use encryption for data transmission. When we use external data processors, we employ contractual measures to ensure they provide equivalent security for your data.

Our IT systems are maintained by in-house staff and selected third-party service providers. The third-party service providers do not have access to personal data except for troubleshooting under our direct supervision. 

 

7. Data Accuracy and Retention

 

We take all reasonably practicable steps to ensure the accuracy of the personal data held by us.

We 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 applicable laws and regulations. Once the retention period expires, we will securely delete or anonymize your personal data so that It can no longer be associated with you.  

 

8. Data Disclosure and Transfer

 

To operate our business and provide you with our Products and Services, we may need to share your personal data with third parties.  Any sharing of your data will be connected to the Purposes as set out in Section 3.  We may transfer tour data to the following types of parties:

• Service Providers: We engage trusted companies to help us run our business and provide services to you.  These partners include IT support vendors, marketing agencies, delivery and logistic companies, and data management specialists.  These providers may contact you on our behalf to fulfill the Purposes as set out in Section 3.
• Government and Regulatory Authorities: We may be required to disclose your information to government, legal, regulatory, or law enforcement authorities that have legal jurisdiction over our operations.
• Professional Advisors: When necessary, we may share your data with our professional advisors, including lawyers, accountants, financial advisors and insurers. 

We may also transfer your personal data within CHKP Group for any of the Purposes we have set out in Section 3 above.  This includes allowing any CHKP Group company to conduct direct marketing on behalf of another CHKP Group company.  However, no CHKP Group company will use your personal data to send you direct marketing materials about its own products or services unless we have obtained your prior consent.

 

9. Your Rights: Access and Correction

 

Under the PDPO, a Data Subject is entitled to make data access or data correction requests. All such requests shall be sent by either post or email to our Data Protection Officer, the contact details are set out at the end of this policy.

We will response within 40 calendar days of the submission of the request and may charge a reasonable fee for processing an access request.

 

10. Links to Other Websites

 

Our websites may contain links to third-party sites (“Linked Sites”).   We are not responsible for the contents or the privacy practices of these Linked Sites.  We advise you to review their privacy policy when you visit them.

 

11. Children’s Privacy

 

We do not knowingly collect personal data from anyone we know to be under the age of 18.  If you are under the age of 18, you should use our website or mobile applications only with the involvement of a parent or guardian and should not submit any personal data to us.

 

12. Contact Us

 

If you have any questions concerning this Privacy Policy or our privacy practices, you may contact our Data Protection Officer by either post or email.

 

By Post:
China-Hongkong Photo Products Holdings Limited

8^th Floor, Tsuen Wan Industrial Centre

220-248 Texaco Road, Tsuen Wan

New Territories
Hong Kong
Attn: Data Protection Officer

 

By Email: privacy@chinahkphoto.com.hk