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Privacy Policy



1.           Commitment to Personal Data Protection



1.1     KOKUYO Co., Ltd. (“KOKUYO”) takes the privacy of your personal data seriously.  This policy statement provides information on the obligations and policies of KOKUYO under the Personal Data (Privacy) Ordinance (Cap. 486) (“the Ordinance”) and the codes of practice which may be issued by the Privacy Commissioner for Personal Data (“PCPD”) from time to time.


1.2     When KOKUYO collects, uses, stores and handles personal data from you, it is our policy to meet fully the requirements of the Ordinance, which regulates the treatment of personal data in Hong Kong.  Throughout this Privacy Policy, the meaning of the term “personal data” is as defined in the Ordinance.  In dealing with personal data, we will ensure compliance by our staff and personnel with the standards of security and confidentiality prescribed under the Ordinance.  References to “we”, “our” or “us” in this Privacy Policy shall be deemed to be references to KOKUYO, and references to “you” and “your” in this Privacy Policy shall be deemed to be references to “customer” and “user”. 



2.       Collection and Use



2.1     The types of personal data or information collected includes but not limited to: -


          (a) your name;

          (b) your gender;

          (c) your date of birth;

          (d) your nationality and country of residence;

          (e) your marital status;

          (f) your Hong Kong ID number;

          (g) your passport number and place of issue;

          (h) your electronic email address;

          (i) your residential, business and postal mailing address;

          (j) your home and work telephone number(s);

          (k) your home and work facsimile number(s);

          (l) your mobile number;

          (m)             your education level and professional attainments;

          (n) your interests;

 (o)   your credit or debit card number, account information, billing information and other payment services information and expiry date;

          (p) your username, log-in ID number and password (if any);]

          (q) your profile picture (if any);

          (r) your IDs of WhatsApp, WeChat, Facebook, messenger and/or IG (if any);

          (s) your other social media account ID (if any);


2.2     Our servers may automatically collect data about your internet address when you visit us.  This information known as internet protocol (IP) address, that is a number automatically assigned to your computer by your internet service provider whenever you are on the internet.  When you requested pages from our website, our servers may log your IP address and, if applicable, your domain name.  Your IP address is used to help identify you and to gather demographic information about our customers and users.  Our server may also record the referring/exit page that linked you to us; the pages you visit on this site; the website you visit after this site; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this site or a referral site; and other web usage activity and data logged by our servers.  We may also automatically collect information like operating system, date/time stamp, and clickstream data in log files, and link such information and data automatically collected to the personal data or information which have been provided to us by you.  For details of collection of such information please refer to section 7 ‘Use of Cookies and Links to Other Sites’.  


2.3     Your personal data may be collected and/or used for one or more of the following purposes or any purposes directly related to them: -


(a)      to provide our products and services to you, and the benefit and enjoyment for our customers;

(b)     to administer the daily operation of KOKUYO;

(c)      to facilitate the use of the online services available at KOKUYO’s website;

(d)     with your consent, to market and promote KOKUYO’s products and services for our customers’ enjoyment of benefits (e.g. sending you updates on our latest offers and promotions in relation to any of our services and/or products from time to time).  For further details, please refer to section 5 “Subscription of Newsletter/Promotional Materials/Marketing Materials” below;

(e)      to identify and verify customers’ identity;

(f)      to facilitate us in the use of your personal data for purposes relating to special events and/or promotions, and the products and services provided by KOKUYO;

(g)     to provide other customer support(s) (e.g. specific request(s) and/or application(s), or processing complaint(s));

(h)     to satisfy and comply with our legal and administrative obligations and purposes;

(i)      to operate and facilitate any reward, loyalty program(s) and special offer(s) provided by KOKUYO;

(j)      to design, maintain and improve our products and services provided by KOKUYO;

(k)     other purposes directly related to any of the above purposes.


2.4     The provision of personal data or any information is voluntary, however, failure to provide the requested personal data may result in KOKUYO being unable to render services to you in the event that you fail to do so.


2.5     We will not disclose your personal data to any third parties save and except for the requirements and provisions listed out under section 4 “Disclosure or Transfer of Data”.


2.6     If you are under the age of 18, we would strongly recommend you to seek prior consent from a person with parental responsibility for you, e.g. parent or guardian, who may contact us for providing relevant and appropriate personal data to us.



3.       Data Retention



3.1     Unless otherwise agreed, hard copies of any documents containing your personal data that you have provided to KOKUYO become the property of KOKUYO and will not be returned to you.  KOKUYO will destroy any documents it holds in accordance with its internal policy and applicable laws.


3.2     Personal data will be retained only for such period as may be necessary for carrying out the purposes stated in this policy or as otherwise specified at the time of collection.  Practical steps will be taken to ensure that personal data will not be kept longer than necessary and KOKUYO will comply with all relevant statutory and regulatory requirements concerning the retention of personal data. 


3.3     Subject to legal requirements, your Personal Data will be retained by us after deactivation of the relevant service until you request us in writing to erase your own Personal Data from our database or to terminate your membership of the Website (if applicable).



4.       Disclosure or Transfer of Data



4.1     Personal data held by KOKUYO will be kept confidential but may disclose or transfer the personal data where it is necessary to satisfy the purpose, or directly related purpose, for the following purposes: -


(a)      to provide and facilitate products and services to you by KOKUYO’s staff and personnel;

(b)     to facilitate the purposes mentioned under section 2 “Collection and Use”;

(c)      to satisfy and comply with any statutory or contractual obligations or as required by court of law.  In addition, personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned personal data are exempt from the provisions of data protection principle 3 of the Ordinance.


4.2     We may transfer, disclose, grant access to or share your personal data with third parties located within or outside Hong Kong, and your personal data may be transferred, stored and processed within or outside Hong Kong.  Third parties may include, but not limited to, third-party suppliers, external service providers, IT and data operators, agents, affiliates, associates, members of KOKUYO, who have been duly authorized by us to use such personal data.


4.3     By using our services, you are deemed to have agreed to, consented to and authorized us to disclose and/or transfer your personal data under the requirements and provisions stated above, as well as to any transfer, disclosure and use of your personal data outside of Hong Kong.  Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.


4.4     KOKUYO will act its best to ensure compliance with the Ordinance by providing guidelines to and monitoring compliance of the relevant parties listed above.  However, KOKUYO cannot control how third parties use your personal data and assumes no responsibility for the privacy protection provided by such third parties.



5.       Promotion and Direct Marketing



5.1     We may from time to time communicate to you with newsletters, promotional and marketing materials and information, either verbally or in writing, based on the personal data that you have provided to us.  We may use your personal data in direct marketing, and we require your consent which includes an indication of no objection for that purpose.


5.2     We may use your personal data, those stated in Clause 2.1 hereinabove, for the marketing and promotion of the following items, including but not limited to: -


(a)   all products and services provided by us, including latest news, offers and promotions in connection to our products and services;

(b)   special events hosted by us, including but not limited to, courses, workshops, road shows, member of club event, product launches, lucky draws and competitions;

(c)   reward, loyalty, membership, club or privileges program related products and services;

(d)   special offers, including coupons, discounts, group purchase offers and promotional campaigns;

(e)   products and services offered by our affiliates and corporate clients (the names of such affiliates and corporate clients can be found in the relevant advertisements and/or marketing or promotional materials for the relevant products and services, as the case may be);

(f)   donations and contributions for charitable and/or non-profit making purposes;

(g)   to generate customers’ preferences and market trends and derive insights; and

(h)   to use advertising services and products by marketing agencies and social media platforms for marketing and promotional purposes.


5.3     The items stated in Clause 5.2 provided or solicited by us and/or: -


          (a) our affiliates, branches and subsidiaries;

          (b) external service provider(s) for the provision of items stated in Clause 5.2; and

          (c) charitable and non-profit making organizations.


5.4     In addition to marketing the items stated in Clause 5.2 hereinabove, we also intend to provide your personal data to all and/or any persons stated in Clause 5.3 for use of marketing those items stated in Clause 5.2, and we require your written consent which includes an indication of no objection for that purpose.


5.5     We may also use personal data to analyze our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products, services and offers that we present to you.  This may involve us combining personal data that we hold about your use of our services with information that we have collected about your web usage in order to derive these insights and establish market trends.


5.6     You have the right to ask us not to process your personal data for direct marketing purposes.  You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your personal data.  You can also exercise the right at any time after we have collected and used your personal data for direct marketing purposes by: -


 (a)   following the opt-out instructions contained in the relevant communications, for example, you may choose to unsubscribe for such materials by clicking on the automatic link appearing in each e-newsletter/message and follow the instructions and procedures contained thereunder, filling out and returning the hard copy of the instruction for opt-out or contact our customer service representative by email to



6.       Personal Data Access and Correction



6.1     You have the right to request access to your personal data in accordance with the provisions of the Ordinance.  Your right of access includes the right to obtain a copy of the personal data KOKUYO holds about you.  A charge will be made to cover the cost of photocopying personal data supplied in response to a data access request.


6.2     You may also exercise your right of correction by writing to KOKUYO’s customer service representative at the address listed below, specifying the personal data obtained through the data access request mentioned above which needs to be corrected.


6.3     Satisfactory proof and explanation of the inaccuracy is essential before KOKUYO will correct the personal data. We may request you to provide personal details in order to verify and confirm your identity.  Please note that HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate.


6.4     Upon satisfying of the authenticity and validity of the correction request, KOKUYO will comply with and respond to the request as required under the Ordinance.


6.5     Requests for access to personal data held by KOKUYO should be made by email or telephone: -


          Customer Service Representative of KOKUYO


          Address:      8/F., The Sun's Group Centre, 200 Gloucester Rd., Wanchai, HK



7.           Use of Cookies and Links to Other Sites



7.1     When you access our website, we record your visits.  The server will also record the domain name, server address, track the pages you visit, store such information in “cookies” and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files.  All these are done without you being aware that they are occurring.  We may link such information and data automatically collected in the above manner to the Personal Data which have been provided to us by you.  We generally use such automatically collected information and data to estimate the audience size of the website, gauge the popularity of various parts of the website, track your movements on the website and number of entries in our promotional activities and special events, measure traffic patterns of how you use the website and administer the website.  Such information may also be used by us for the purpose of marketing our goods and services.  Such automatically collected information and data will not be disclosed save and except in accordance with section 4 “Disclosure or Transfer of Data”.


7.2     If you do not agree to the use of these cookies, please disable them by following the instructions for your browser or use cookies setting disabling tools.  Please note that some of the services will not function if cookies are denied.


7.3     This website contains links to other sites that are operated by third party companies with different privacy practices.  You should remain alert when you leave our site and read the privacy statements of other websites.  We have no control over personal data that you submit to or receive from these third parties.  We have no control over the contents of such other websites or their privacy policies or compliance with Hong Kong laws and/or laws in other jurisdictions.


7.4     Disclaimer:  We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our website and recommend that you check the policy of each website you visit and contact its owner or operator if you have any concerns or questions.  In addition, if you linked to this website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party website and recommend that you check the policy of that third-party website and contact its owner of operator if you have any concerns or questions.



8.           Security



8.1     The security of your personal data is paramount to KOKUYO, and we strive to ensure that your personal data will be protected against unauthorized access.  We have implemented appropriate electronic and managerial measures in order to safeguard, protect and secure your personal data.


8.2     All personal data provided by you are only accessible by the authorized staff and personnel of KOKUYO or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing your personal data.  You should safeguard your unique username, login-ID and password by keeping them secret and confidential and shall never share these details with anyone (where applicable).


8.3     We use third-party payment gateway service provider to facilitate electronic transactions on the website.  Regarding sensitive information provided by you, such as credit card number for completing any electronic transactions, the browser on the website and third-party payment gateway communicate such information using secure socket layer (SSL) technology.


8.4     Personal data, whether stored in electronic form on computers or in hard-copy form will be accessible only by authorized staff and personnel.  Information that is stored in document form is kept in secure, locked offices to prevent access by unauthorized persons.   


8.5     Further to section 4 of the Privacy Policy, your personal data may be transferred outside Hong Kong, including to countries with a lower data protection than Hong Kong.


8.6     Please note that no method of transmission or storage of data, including without limitation transmission over the Internet and storage by electronic means, is completely secure and safe.  Therefore, we cannot guarantee full protection of your personal data against unauthorized access.  You are encouraged to protect against unauthorized access to your password.  Make sure you sign out from your account when finished particularly when using a shared computer. 



9.       Changes in this Privacy Policy



9.1     We reserve the right to update, revised, modify and/or amend this Privacy Policy in the following manner at any time as we deem necessary and you are strongly recommended to review this Privacy Policy frequently.  If we decide to update, revise, modify and/or amend this Privacy Policy, we will post those changes to this website and/or other places we deem appropriate so that you would be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.



10.     Contact



10.1   A request for access to personal data, correction of personal data, or for information regarding policies and practices and kinds of personal data held by KOKUYO may be sent to us via: -



          Customer Service Representative of KOKUYO


          Address:      8/F., The Sun's Group Centre, 200 Gloucester Rd., Wanchai, HK


Last Updated: 9th November 2020​

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