Last modified: [25 January 2018]

 

1. Introduction

• At A2 INFANT NUTRITION LIMITED, we recognise the importance of your privacy. Our Privacy Statement sets out details of how we collect, process, share, use and disclose any personal data you provide to us when you use our website located at Hong Kong. This statement applies to other companies related to A2 INFANT NUTRITION LIMITED. In this statement, “we“, “our” and “us” refers to A2 INFANT NUTRITION LIMITED, a New Zealand company (Registration No.: 1014105), together with our parent and affiliates, and “you” refers to the user of the website.
• We use and process your personal data (as defined below) in accordance with the provisions of this Privacy Statement, the Personal Data (Privacy) Ordinance (“PDPO“) in Hong Kong and other applicable laws.
• This Privacy Statement is incorporated into and form part of the Legal Disclaimer that you have agreed to prior to using the website or our services.
• We may update our Privacy Statement from time to time. These updates will form part of this Privacy Statement. When our Privacy Statement is updated, it will be published on this website. By continuing to use our services after any changes to this Privacy Statement, with or without notice from us, you are agreeing to the revised Privacy Statement.

1. Information we collect

• “Personal data” is a defined term under the PDPO, which means any data which directly or indirectly identifies you as an individual, or is capable of doing so. When you visit our website, you are not obligated to provide any information to us. However, if you do, our collection and use of your information will be governed by the terms of this Privacy Statement.
• We collect personal data that you knowingly disclose to us, for instance, you may submit information when you make purchases, when you request information, when you register/sign up for our newsletter, when you create your online account or when you participate in any other services provided on our website.
• The types of personal data we collect may include, but is not limited to:
  • contact information such as your name, email address, mailing address, telephone number, and fax number;
  • unique identifiers such as your HKID and passport number;
  • billing information such as your credit card number, bank account information, and billing address; and
  • demographic information such as age, gender, nationality, marital status, preferences, education background, and employment history.
• From time to time, we may collect personal data:
  • when you give it to us directly or when you use our products and services;
  • when you knowingly give us information when entering into one of our promotions or contacting us via our website or phone, including by email; and
  • by cookies, log files browser type and other computer or device information. A cookie is a small amount of information transferred to the hard drive of your computer which can identify your web browser but not you. You can disable your web browser from accepting cookies as you wish. If you do, you can still access our website, but not all services may be available.

1. Accuracy of information

Please be aware that you are responsible for ensuring all personal data you provide is accurate and complete.

1. Why we collect your information
   • We may from time to time collect data from you for a number of purposes:
     • to provide our services and goods to you;
     • to keep a record of our dealings with you;
     • for customer service, verification of your identity, security, fraud-detection, archival and backup purposes in connection with the provision of our services through the website;
     • to provide you with promotional materials or other information about us in accordance with Section 8;
     • to help us develop new services and improve our existing services;
     • to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services;
     • to meet 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 and/or our affiliates anywhere in the world, including making disclosure to any legal, regulatory, governmental, tax, law enforcement or other authorities (whether in or outside Hong Kong);
     • to allow you to participate in surveys and other activities about our products and services;
     • to create aggregate data (which does not identify you) to provide to our related companies and potential stakeholders; and/or
     • to fulfill any other purposes directly related to 1(a) to (i) above.
   • When you contact us outside of our website or email communications, we may use your personal data to answer your question. For this purpose, it may be necessary for us to process your name, your contact information, your correspondence with us about your question and any other personal data you have provided us with and which is required to answer your question. Your data will be kept in our systems for as long as legally required and will then be deleted.
   • It is your decision whether or not to provide any personal data to us. However, if you choose not to provide us with some or all of your information, there might be circumstances where we may not be able to render our services to you, for example, to respond to your request.
2. When we disclose and share your personal data
   • We will not disclose any personal data about you, but on the condition that such disclosure is necessary to satisfy the purpose for which we collect your data, we may share your information with the following parties:
     • our subsidiaries, holding companies, associated companies, or affiliates, or any companies controlled by, or under common control with us;
     • any person or company who is acting for or on behalf of us, or jointly with us, in respect of the purpose or a directly related purpose for which the data was provided;
     • any other person or entity who is under a duty of confidentiality to us and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
     • agents, contractors, manufacturers, suppliers and other service providers engaged by us to assist with providing you our services, including data processing service providers, customer service, sales agents, mail processing service providers and information technology service providers;
     • any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureaux, or collection agencies, security agencies, necessary to establish and support the payment of any services being requested;
     • law enforcement agencies, regulatory authorities, government departments and related organizations, courts and tribunals, as required or authorised by applicable laws;
     • any proposed or actual participant, assignee or transferee of all or any part of our operation or business; and
     • any organisations who manage our business and corporate strategies (and for such purposes), including those involved in a transfer or sale of all or part of our assets or business and those involved in managing our corporate risk and funding functions.
   • We may from time to time also use aggregate non-identifying information about our customers to better design and improve the services we offer. This information will not identify any individual in particular.
3. What this Privacy Statement does not apply to
   • You need to be aware that this Privacy Statement applies to dealings with us, including dealings via our website or in respect of our website services, but does not apply to any third party websites which you access using a link from ours. In this case the privacy policy of the owner of the other website (if any) will apply. You should review the privacy policy for those third party websites to understand the ways in which your personal data may be used by those third parties.
   • We cannot and do not make any warranty or representation as to the practices of any linked websites in the handling of your personal data. In particular, this Privacy Statement does not apply to information collected:
   • through third party services (including any third party websites) that you may access through our services; or
   • by other companies and organisations who advertise their services on our services.
4. How we transfer, store and secure your information
   • We will take reasonable steps to ensure that all information we collect or use is accurate, complete and up to date.
   • We will take reasonable steps to protect your personal data we hold from misuse, interference and loss and from unauthorised access, modification and disclosure. In particular, we utilize and use a variety of 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.
   • Your personal data is stored in a secure environment and is accessed only by authorised personnel for permitted purposes. While we have put in measures to ensure your personal data is safe and secure, no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Hence, we cannot guarantee the security of any information that you provide to us or receive from us over the Internet. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.
   • You should note that we operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your personal data is used and stored may not be in your jurisdiction.
   • By giving us your personal data, you consent to the transfer of your personal data to places outside Hong Kong to carry out the purposes, or directly related purposes, as described in this Privacy Statement.
5. Advertising / Direct Marketing
   • Except to the extent you have already opted out or in future opt out, we may also use your personal data for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services. Such products and services (of ours or third parties) include the following:
     • our a2TM branded products and services in relation to (i) fresh milk; and (ii) formula milk products; and
     • the products and services of our affiliate and subsidiary companies and business partners in relation to (i) fresh milk; and (ii) formula milk products; and
   • We will honour your request for us to not use your personal data for the marketing purposes noted above.  If you wish to make such a request, please follow the procedure specified under “How to make a request” section below.
   • For the avoidance of doubt, this consent is separate from and independent of your services registered with us. Accordingly, it can be withdrawn at any time as per this Privacy Statement without reference to the duration of the services, and will survive the termination or expiration of any applicable service contracts.
6. How to make a request

If you wish to access personal data which we hold about you or contact us regarding this Privacy Statement or any privacy-related matters, please contact us via email at privacy@a2milk.com.

1. General
   • The English version of this Privacy Statement shall prevail over any Chinese version (if any) which is provided for information purposes only.
   • If you wish to contact us regarding this Privacy Statement or any privacy-related matters, please contact us via email at privacy@a2milk.com.