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Privacy Policy

The protection of personal data is very important to us. For this reason, we continuously analyze all processes of personal data processing and ensure their compliance with applicable data protection legislation, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (SAR) and, where applicable to EU data subjects, Regulation (EU) 2016/679 (GDPR).

Your personal data is processed as a controller by our company VENTURO COMMERCE LIMITED, with its registered office at UNIT 2904-05, 29/F UNIVERSAL TRADE, CTR 3 ARBUTHNOT RD CENTRAL, HONGKONG. You can contact us at any time by e-mail: [email protected].

1. For what purposes, on what legal basis, and for how long do we process and store your personal data?

We process personal data for the purposes listed below. The legal basis for the processing of personal data is determined by the nature of the purpose of processing, which is also decisive for determining the retention period of your personal data. If in any area the retention period of personal data is determined by years, it begins on January 1 of the calendar year following the year in which we started processing your personal data for the given purpose.

Order and Purchase of Goods through the E-shop

If you are interested in purchasing Goods offered in our portfolio through our E-shop, we have to process your personal data in the Order or later made available during the contractual relationship, in order to accept and properly process your Order, to give you a discount, to deliver the ordered Goods, handle any complaint or perform other activities and actions related to it.

Legal Basis: Performance of a contract. Retention: For the duration of the contract and subsequent statutory warranty periods.

Customer Account

Ordering Goods in our E-shop is possible after creating your own Customer Account, through which you can realize any future Orders, while the data about them will be stored in your Customer Account.

Legal Basis: Pre-contractual and contractual relations. Retention: For the duration of the account registration.

Direct Marketing

If you have already purchased Goods from us in the past, we are interested in offering you the possibility of purchasing other similar Goods in our portfolio. For this reason, we will send you offers of such similar Goods.

Legal Basis: Legitimate interest in increasing E-shop sales. Retention: Until you object to direct marketing.

Advertising and Newsletter

If you opt in to receive updates, news, and specialized newsletters, we will process your email for marketing communications.

Legal Basis: Consent. Retention: 2 years or until consent is withdrawn.

Affiliate Program

We track traffic originating from our affiliate partners to attribute sales credit correctly. We do not process sensitive data, but only the referrer ID and order volume to settle partner commissions.

Legal Basis: Legitimate interest. Retention: As long as required to clear financial audits.

Accounting and Taxes

As an accounting entity, we keep books and process financial records (invoices, receipts) to satisfy tax and financial regulation duties.

Legal Basis: Fulfillment of legal obligations. Retention: 5 years from the beginning of the year following the accounting year.

Cookies (Essential & Non-Essential)

We use essential cookies to maintain E-shop functionality and security. We use non-essential (analytical/marketing) cookies to enhance your experience and target advertisements.

Legal Basis: Legitimate interest for essential cookies; Consent for non-essential cookies.

2. To whom do we disclose and transfer your personal data?

We protect personal data and do not disclose or provide them to third parties, with the exception of our contractual partners who process personal data on our behalf as processors and ensure the protection of personal data according to our instructions. These are mainly web hosting and cloud providers, logistics carriers, email delivery engines, and accounting/IT support providers. Regulated professions like lawyers and auditors act as independent controllers. If mandated by law, we also provide data to public authorities.

3. What are your rights as a data subject?

Under the GDPR, you have the following rights which you can exercise by emailing [email protected]:

  • Right of Access: You have the right to request confirmation of data processing and to receive a copy of your personal data.
  • Right to Rectification: You can request immediate correction of incorrect or incomplete personal data.
  • Right to Erasure ("Right to be Forgotten"): You can request data deletion when it is no longer needed, consent is withdrawn, or processing is unlawful.
  • Right to Restriction: You can request that we restrict processing to storage only in dispute cases.
  • Right to Object: You can object to processing based on legitimate interests, including direct marketing.
  • Right to Portability: You can receive your data in structured, machine-readable format to transmit to another controller.
  • Right to Withdraw Consent: If processing is based on consent, you have the right to withdraw it at any time.

4. Filing a complaint

If you believe your personal data rights have been violated, you have the right to lodge a complaint with the regulatory authority:
Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong
Unit 1303, 13/F, Dah Sing Financial Centre, 248 Queen's Road East, Wanchai, Hong Kong
Website: www.pcpd.org.hk

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