June 15, 2022
We maintain the following privacy principles:
1. We only collect personal data that we believe to be relevant and required to understand your needs and to conduct our business.
2. We use your personal data to provide you with better customer services and products.
3. We may pass your personal data to other members of our group or our respective agents, as permitted by law.
4. We will not disclose your personal data to any external organisation unless we (i) have your consent or (ii) are required by law or (iii) have previously informed you.
5. We may be required from time to time to disclose your personal data to governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority.
6. We aim to keep your personal data on our records accurate and up-to-date.
7. We maintain strict security systems designed to prevent unauthorised access to your personal data by anyone, including our staff.
8. All members of us, all our staff and all third parties with permitted access to your personal data are specifically required to observe our confidentiality obligations.
Notice Of Information We Collect And How We Use It
We collect two types of data about individuals: (1) technical data automatically collected from all visitors to the Site, and individuals that use the Services (“Passive Data Collection”) and (2) information that you or others voluntarily submit to us (“User-Submitted Information”).
Passive Data Collection
We automatically track certain information based upon your behavior on the Site and/or App. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community.
Mobile Device Information
When you download or use our StyleTheory mobile application (“App”), we receive information about your mobile device (but not the native manufacturer unique identifier for your device) for purpose of tracking unique downloads. We register your device, and may use the identifier to send you push notifications about your transactions with our service.
Like most Sites and/or App, we automatically receive and record certain information about our users’ behavior on our Site and/or App and when using our Services. Our servers automatically gather technical information about our Site and/or App traffic and store it in log files. 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 aggregate this information with other pieces of information to analyze trends, to administer and improve the Services, to track users’ movements around the Site and/or App and to make inventory purchasing decisions that will best serve our customer base. Pages of the Site and/or App may also use devices that permit us to count users who have visited those pages and for other related Site and/or App statistics (for example, recording the popularity of certain Site and/or App content and verifying system and server integrity).
We may record your visit to the Services for analysing the number of visitors to our Site and App, general usage patterns and your personal usage patterns and improving your experience. We may gather some of this information through the use of "cookies". Cookies are small bits of information that are automatically stored on your web browser in your computer or mobile that can be retrieved by this Site. Cookies are useful because they allow us to recognise your device and they store information about your use of this Site or App, thus enabling us to provide more useful features to you, to tailor the content of our Site to suit your interests and, where permitted by your marketing preferences, provide you with promotional materials or direct marketing based on your usage patterns.
We will be able to access the information stored on the cookies and record how you use this Site and App. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies or to inform you when they are set. By disabling cookies, you may not be able to take full advantage of this Site and App.
We use clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, you may contact us at email@example.com to request that we remove this information from our database.
Third Party Advertisers
Third party advertising companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this Site and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party web beacon to collect this information. These third party cookies do not collect personally identifiable information.
In order to use some features of the Site and the Services, including without limitation the rental of products from StyleTheory, you must first register with us and create a user name and password. During registration you are also required to give truthful contact and demographic information (including name, email address, postal code and phone number) in accordance with our Terms. We use this information to contact you about the products and Services on our Site in which you have expressed interest.
If you subscribe to our Service, we request certain Personal Information from you on our order form, whether you access the Services from our App or the Site. You must provide contact information (including name, shipping address, telephone number) and financial information (including credit card number and expiration date). Also, in order to assist you, we may also require personal characteristics, such as your height, bust, and dress size.
We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.
Before your order can be processed, we will require that you review and consent to our Terms.
Surveys Or Contests
We may provide you the opportunity to participate in surveys or contests on our site. If you participate, we will request certain Personal Information. The requested information typically includes contact information (such as name and shipping address) and demographic information.
We use this information to notify contest winners and award prizes, to monitor Site traffic, or to personalize the Site (in the case of anonymous information collected in surveys) and to send participants an email newsletter. By participating in a survey or contest you submit to that activity’s terms and conditions, including providing us with permission, if required, to share your Personal Information with sponsors of that survey and/or contest.
If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. StyleTheory stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Third-Party Account Credentials
Communication From Us Or The Site
We use your contact information to communicate with you about StyleTheory and our marketing partners, as described below.
Special Offers And Updates
We will occasionally send you information on Services, products, special deals, and promotions. You can take advantage of promotions by entering the promotion code provided at the time of checkout. Out of respect for your privacy, we present the option not to receive these types of communications. If you would like to opt-out of these emails, you may contact us at firstname.lastname@example.org to request that we remove this information from our database.
We send newsletters, usually by email. If you would like to opt-out of these emails, you may contact us at email@example.com to discontinue newsletters.
Messages About The Service And Your Account
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Based upon the Personal Information you provide us, we will send you a welcoming email to verify your username and password. We will communicate with you in response to your inquiries, to provide the services you request, to update you on the status of your requests, to manage your account, and to provide the best customer service possible.
If you download and use our App, and have enabled push notifications on your mobile device, we may send you alerts and notifications through push notifications, for example, to communicate shipping status for goods you rent. You can opt out of these transactional messages by changing the settings on your mobile device.
We use third party software to verify your identity and address, in order to ensure proper shipping and billing procedures for your rental.
We may provide you the opportunity to participate in our user generated content feature. If you participate, we will request and display certain Personal Information. The requested information typically includes your Full Name, the product you rented historically and the image you submitted.
We use this information to create content for the app and maybe for marketing purposes. By participating and uploading an image you submit to that StyleTheory’s Terms (https://www.styletheory.co/hk/apparel/terms) (and please check your applicable region and its Terms) including providing us with permission, if required, to share your Personal Information with third party service providers.
DISCLOSURE OF PASSIVE OR USER-SUBMITTED DATA
StyleTheory engages in marketing and promotional activities with carefully screened brands, or, “Partners,” which we think will appeal to our user base. We may make our user list available to Partners so that you may receive catalogs, product information, or promotions from our Partners. If you prefer we don’t use your information for partner promotions, please contact us at firstname.lastname@example.org. We also may send or permit Partner promotions via email. You may opt out of such promotional emails or Partner mailings by unsubscribing thru emailing us at email@example.com.
From time to time, Partners may also be provided with non-identifying or aggregate information indicating the demographic information of users on our Site, buying behavior, and opportunities to market to select segments of our customer base indirectly. When we share aggregate user data, we do so in a way that it cannot be linked with a user's Personal Information.
As Required By Law / Certain Business Transactions
We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains. This may include responding to legal requests from jurisdictions outside of Hong Kong, where we have a good faith belief that the response is required by law in that jurisdiction.
To Protect Rights
Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms, or our other agreements; take precautions against liability; protect the rights, property, or safety of StyleTheory, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.
Tracking Technologies And Tailored Advertisements / Choices
StyleTheory also partners with advertising companies to place our advertising on publisher sites on the Internet. These advertising companies collect anonymous information about your visits to our Site by placing and reading cookies on the device you use to access our web site. The cookies do not collect or use Personal Information. These tracking technologies are used to analyze user behaviors in the aggregate. They are used to analyze and optimize our App or Site, measure conversion, and tailor content to interests.
Links To Other Sites
Access To Personally Identifiable Information
Should you require us to change or delete your account, you may make a request through our in app chat. We will store all data until it is no longer needed to provide our services or until we have received and completed a delete request, whichever comes first.
When your account is deleted, all identifiable personal information e.g. date of birth, identification card, email and phone number will be removed. Data that has been sent to 3rd party systems e.g. billing systems or customer service tools will also be removed. If you wish to take a temporary break from the service you may opt to pause your subscription via the app.
The time taken to fully delete your account can take up to 9 months. To make a request to delete your account please use our app to access Profile > My Account > Delete Account.
The security of your information is important to us, including, but not limited to, the Personal Information collected via the Site and/or App. We use reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information. We keep Personal Information no longer than necessary for legitimate business purpose or as required by law.
As part of securing personal data stored on our servers, we restrict access to Personal Information to StyleTheory employees, contractors and agents who need to know that information in order to operate, develop or improve the Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or the Site and/or App or by providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.
If a security systems breach occurs, we may post a notice on our homepage (styletheory.co) or elsewhere on the Site and/or App and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. This notice paragraph applies to users of Services and the Site and/or App.
Change Of Ownership
In the event of a change in ownership, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to, another entity, we reserve the right to transfer all of your Personal Information, including email addresses, to that entity. We will use reasonable efforts to notify registered users of any such transfer to an unaffiliated third party (by a posting on our homepage, or by email to your email address that you provided to us, as chosen by us in our discretion).
StyleTheory and the Site and/or App are not directed toward individuals under the age of eighteen (18), and we request that such individuals do not provide Personal Information through our Site and/or App. Additionally, we do not knowingly collect or maintain Personal Information from anyone under the age of 18, unless or except as permitted by law. If we learn that Personal Information has been collected from a user under 18 years of age on or through the Site and/or App, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 18 who has registered on the Site and/or App or you believe has otherwise provided Personal Information to StyleTheory, please contact StyleTheory at firstname.lastname@example.org to have that child’s account terminated and information deleted.
Notice To Customers And Other Individuals Relating To The Personal Data (Privacy) Ordinance (the “Ordinance”)
Supply Of Information
From time to time, it is necessary for customers and various other individuals to supply us with data in connection with various matters regarding their spending and usage.
Failure To Supply
Failure to supply such data may result in StyleTheory being unable to provide services.
General Course of Collection
It is also the case that data are collected from (i) data subjects in the ordinary course of the continuation of StyleTheorying Services or (ii) Data may also be generated or combined with other information available to StyleTheory or any member of its group including its affiliates, subsidiaries, associated entities and any of their branches and offices (together or individually).
Purpose of Use
The purposes for which data may be collected are provided under our Basic Principles and their use, which should not conflict with the collection principles, are more broadly set out as follows:
(i) for and/or related to the Services as described in our Terms and/or Site and/or App;
(ii) designing Services or related products for data subjects’ use;
(iii) analysing how data subjects access and use StyleTheory’s services including services available on StyleTheory’s Site and/or App from time to time;
(iv) advertising and marketing services, products and other subjects (including in connection with direct marketing as detailed herein or generally;
(v) determining the amount of indebtedness owed to or by data subjects;
(vi) the enforcement of data subjects’ obligations, including without limitation the collection of amounts outstanding from data subjects and those providing security or guarantee for data subjects’ obligations;
(vii) meeting obligations, requirements or arrangements, whether compulsory or voluntary, of StyleTheory or any of its group to comply with, or in connection with:
(a) any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future (“Laws”);
(b) any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies within or outside Hong Kong existing currently and in the future and any international guidance, internal policies or procedures;
(c) any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental bodies (together the “Authorities” and each an “Authority”) that is assumed by, imposed on or applicable to StyleTheory or its group
(viii) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information by StyleTheory and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
(ix) conducting any action to meet obligations of StyleTheory to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;
(x) meeting any obligations of StyleTheory to comply with any demand or request from the Authorities;
(xi) purposes relating thereto.
Provision Of Data
Data held by StyleTheory relating to a data subject will be kept confidential but StyleTheory may provide such information to the following parties (whether within or outside Hong Kong) for the purposes set out herein:
(i) any agents, contractors, sub-contractors, service providers or associates of ours (including their employees, directors, officers, agents, contractors, service providers, and professional advisers);
(ii) any third party service provider who provides administrative, telecommunications, computer, payment, debt collection or other services to StyleTheory in connection with the operation of its business (including their employees, directors and officers);
(iii) any Authorities;
(iv) any person under a duty of confidentiality to StyleTheory which has undertaken to keep such information confidential;
(v) in the event of default, to debt collection agencies;
(vi) any person to whom StyleTheory or its group is under an obligation or required or expected to make disclosure for the purposes set out herein ;
(vii) any actual or proposed assignee of StyleTheory or participant or sub-participant or transferee of StyleTheory’s rights in respect of the data subject;
(b) platform, marketing channel, distribution channel, third party reward, loyalty, co-branding or privileges programme providers or merchants, advertisers and after sale service providers as appropriate for different level of information and stage;
(c) external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that StyleTheory engages for the purposes herein.
Such and all information above information may be transferred to a place outside Hong Kong.
Use Of Data In Direct Marketing
Where a data subject has given consent for StyleTheory to do so, StyleTheory may use the data subject’s data to provide the data subject with direct marketing. In this connection, please note that:
(i) StyleTheory may use the following categories of data for its direct marketing purposes:
(a) the name, contact details, products and services portfolio information, transaction pattern and behaviour, transaction location, financial background and demographic data of a data subject held by StyleTheory from time to time; and
(b) information relating to the data subject’s use of StyleTheory’s Site and/or App from time to time, whether through cookies or otherwise;
If a data subject does not wish StyleTheory to use or provide his data to other members of its group for use in direct marketing as described above, the data subject may exercise his opt-out right by 11. In accordance with the terms of the Ordinance, StyleTheory has the right to charge a reasonable fee for the processing of any data.
Personal Data (Privacy) Ordinance (Cap. 486) (“the Ordinance”)