Data Privacy Policy

Thank you for visiting [https://www.vileda.hk] (“Website”). Freudenberg Household Products Limited (hereinafter also referred to as “we”, “us”, or “our”) takes the protection of the personal data you provide to us very seriously. We process the personal data in accordance with the requirements of Personal Data (Privacy) Ordinance, Cap 486 of the laws of the Hong Kong SAR (“Ordinance”). This Data Privacy Policy (“This Policy”) supplements our General Terms and Conditions for the Use of the Website (the “General Terms”). Your use of the Website is therefore governed by both this Policy and the General Terms. This Policy is only applicable to the Website and not to any other websites or applications to which it is possibly linked. The Policy applies to all visitors, users, and others who access and use the Website (hereinafter also referred to as “you”, “your”, “user”, or “users”).

By "personal data", we mean any data/information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an Internet Protocol (“IP”) address, device identification or other online identifier.

This Policy explains what personal data we collect, how we protect and process personal data, and your rights in relation to your personal data. It also governs the collection, use and disclosure of your personal data. You are highly recommended to familiarize yourself with this Policy and our practices with regard to the collection and/or usage of your personal data first and proceed with accessing or using the Website thereafter. After reading through the Policy, you may choose not to access or use the Website. If you do not wish for your personal data to be used in the ways described within this Policy then you should not access or use the Website or use the services, functions, or features offered from time to time on the Website. If you proceed with the registration, it shall be deemed that you have read through, understood and consented to the contents herein. Contents underlined are important information in need of your special attention, understanding and consent. 

I. Collection of Personal Data

We collect personal data from you through our interactions with you and through the Website, including but not limited to cookies, pixel tags or beacons and similar tracking technologies to collect and store certain information when you use, access, or interact with our services on the Website. In other words, some of the personal data are provided by you directly, whereas some are collected by us through your interactions, use and experiences with the Website. The personal data we collect depends on the context of your interactions and the choices you make, including your privacy settings and the features you use. 

When you access or use the “Contact us” interface of the Website, we may collect the following information, which may be considered to be personal data when combined with other information about you, and therefore hold your personal data, including but not limited to:- 

• name, e-mail address, mobile phone number and your message(s) to us; 
• technical information, including the IP address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and location information; and
• information about your visit, including the dates and times you use the Website, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

You have choices when it comes to the feature you use and the personal data you share. When we ask you to provide certain personal data, you are entitled to decline. Some of the features may require certain personal data to provide you with the service. If you choose not to provide such data, you cannot use that feature. 

II. Protection of Data

We keep the personal data provided to us in strict confidence. In order to protect your personal data from unauthorised or accidental access, processing, erasure, loss or use, we have made reasonable endeavors and take all practicable steps to implement technical and organizational measures which shall be improved in line with technical progress, such as Transport Layer Security provided by the operating system. However, due to the nature of the Website and the network environment where the Website is operating, the personal data provided is not 100% secure. We cannot guarantee the absolute security of your information and/or personal data. Moreover, we are not responsible for the security of information and/or personal data you transmit to us over networks that we do not control, including the internet and wireless networks.

You should also pay attention to protect the personal data provided to us. 

We are committed to protecting your privacy. Internally, only people with a business need to know personal data, or whose duties reasonably require access to it, are granted access to your personal data. Such individuals will only process your personal data on our instructions and are subject to a duty of confidentiality. Externally, we have taken reasonable steps to ensure that any third party with whom we share your personal data will provide the same or comparable protection as stated in this Policy.

The Website’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

III. Purpose of Personal Data Collection

We collect and use the personal data provided by you for the following purposes and any purposes directly related to the following purposes:

• Understand your needs and handle your enquiry(ies);
• Provide service to you through the Website, including but not limited to offer access to product documentations and guidelines of using the products of us, our associated companies (as defined under the Companies Ordinance (Cap. 622) and our affiliate. 
• Develop the Website, which includes securing, troubleshooting, providing support, improving the products and services;
• Send administrative messages and important notices to you, such as communications about the amendment of the General Terms, and the update of this Policy, etc.; 
• Advertise and market products and/or services to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers;
  Operate our business, which includes data analysis, auditing, meeting legal obligations and ensuring compliance, developing workforce, doing research, conducting marketing campaigns, and internal data management and synergy, etc.
• Identify preferences, characteristics, habits or consumption choices of users of the Website, and assess your interest in our products and services.
• Comply with the applicable laws and regulations, legal process, enforcement, order or judgment from a competent Court, and/or respond to requests from government authorities for lawful purposes, including but not limited to safeguarding national security, assisting law enforcement, and protecting public interest; 
• Carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers, acquisitions, sale, liquidation, dissolution, or other transformations and for the execution of such transactions or process; and
• Conduct customer research or satisfaction surveys and obtain user feedback(s) from you.
  ​​​​​​​(collectively “Data Purposes”)

IV. Personal Data Processing

We process your personal data for the Data Purposes in compliance with the legal obligation to which we are subject to under the Ordinance. We will only process personal data when we reasonably assess it is necessary for the purposes of the legitimate interests pursued by us or a third party to whom it may be necessary to disclose certain personal data. 

(I) Personal Data Retention

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy. When assessing these periods, we carefully examine our need to collect personal data at all, and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law. Please note that after de-registration of the Website, your personal data may still be retained by us, to the extent it is strictly in accordance with our aforesaid personal data retention policy.

(II) Disclosure of Personal Data to Third Parties

At times we may disclose personal data for Data Purposes to:-

• our associated companies, affiliated companies or companies we have interest in, including their respective contractors, affiliates, employees or representatives; 
• our strategic partners, including their respective contractors, affiliates, employees or representatives;
• service providers entrusted by us to provide services instrumental to the Website and our product on a strict need-to-know basis;
• third-party analytics companies, research companies or search engine providers that assist us in the improvement and optimization of our services;
• competent government authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us; and
• any relevant parties to which we shall disclose so as to serve the Data Purposes.

(III) Personal Data Transmission

Subject to the applicable laws and regulations, with a view to fulfilling Data Purposes, we may use and/or transfer your personal data to:-

• our associated companies, affiliated companies or companies we have interest in, including their respective contractors, affiliates, employees or representatives;
• our strategic partners, including their respective contractors, affiliates, employees or representatives; 
• service providers entrusted by us to provide services instrumental to the Website and our product on a strict need-to-know basis;
• third-party analytics companies, research companies or search engine providers that assist us in the improvement and optimization of our services;
• competent government authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us; and
• any relevant parties to which we shall disclose so as to serve the Data Purposes.

V. Accuracy of the Personal Data

You are responsible for ensuring the accuracy of the information and personal data you provide to us. Inaccurate information and personal data will affect the information you receive when using the Website and our services.

Also, if you give us information about another person, then you confirm that you:

• Give consent on his/her behalf for the collection and/or processing of his or her personal data;
• Can receive any notices on his/her behalf; and
• Warrant that you have obtained his/her consent for us or have the right to allow us to collect, store and/or otherwise use his/her personal data.

VI. Your Rights to Your Personal Data

You reserve the right to 

• ascertain whether we hold any of your personal data;
• request access to your personal data retained by us free of charge; and
• request the deletion, blocking of inadmissible your personal data and the correction of your personal data. 

We may respond to your request for access or correction of your personal data within 40 days after receiving the same. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests, we shall notify you, keep you updated and respond to your request as soon as practicable. 

If you have any questions or suggestions about this Policy or our practices about handling personal data, or wish to access or correct your personal data, you may reach us by letter or email at the following address:

Freudenberg Household Products Limited
To the attention of Customer Service Team
8/F., Manley Tower, 828 Cheung Sha Wan Road, Cheung Sha Wan, Kowloon, Hong Kong
E-mail: customerservice.hk@vileda.com 

Freudenberg Home and Cleaning Solutions GmbH
To the attention of Data Protection Officer
Im Technologiepark 19, 69469 Weinheim, Germany
E-mail：data_privacy@fhp-ww.com 

VII. Governing Law and Jurisdiction

This Policy shall be construed and governed by the laws of Hong Kong. Any dispute arising out of, relating to or connected with the General Terms, this Policy, or your use of any part of the Website, shall be resolved through amicable negotiation, failing which, either party is entitled to submit the dispute to the Hong Kong Court for resolution.

VIII. Miscellaneous

We may modify or update this Policy from time to time without notice. If we believe this Policy is modified in a material way, a notice will be posted on the Website along with the updated data privacy policy. The user’s continued use of the Website will be deemed acceptance of the updated policy. In the event you refuse to accept such changes, we reserve the right to terminate your use of the Website.

In case the provisions herein contradict the applicable laws and regulations, the provisions in the applicable laws and regulations shall prevail.

Your use of our Website, products and services, and any disputes arising from them, is subject to this Policy as well as our General Terms. Please review our General Terms, which explain other terms governing the use of our products and services.

This Policy is prepared in English and Chinese. In case of any conflict or inconsistency of the two versions, the English version shall prevail.

Freudenberg Household Products Limited

Copyright 2020, All rights reserved

Version 1.0:  Dec, 2020

Effective Date: [2020]