respecting and protecting our customers' privacy and personal data is important. Paragon Design Limited and its related companies (including all holding, subsidiary adn affiliate companies) (collectively, we or us). This policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.
It also describes your data protection rights.
2. What information do we collect?
We collect and process personal data about you through Shopify when you:
2.1 Visit and / or register on any websites owned and operate by us on Shopify e commerce platform (including www.whosthatshop.com, www.paragondesign.com.hk) (collectively, our site):
2.2 Browse as a guest or as a registered user on our site at Shopify;
2.3 Third party service offered by service providers such as analytics companies, advertising networks and cooperatives, demographic companies, and any other third party service providers that we choose to collaborate or work with, and we obtain your personal data from those third parties.
2.4 Provide us with your personal data via: our physical stores, WI-FI, Mobile devices, social media Platforms /networks or telephone enquiries, your application for or use of our services or programs (such as VIP membership or private sales);
3. How do we use this information, and what is the legal basis for the use?
We process personal data for the following purpose:
3.1 To conduct our business and pursue legitimate interests, in particular;
3.1.1 To provide our services to you, including: responding to any questions you may have, providing you with recommendations on products in our stores or on our site; assessing your applications with us for any of our services or loyalty programs; fulfilling any orders you may make with us (including verification and security checks of your details, processing of your payments, shipping products that you have ordered to you, and processing returns or exchanges of products you have purchased).; personalizing our services to you and enhancing your experience in using our services; and
3.1.2 To analyse trends, usage, browsing and shopping behavior with us (whether on an individualized or anonymized and aggregated basis), which help us better understand how you and our collective customer base access and use our sites, stores and services, for the purposes of :
18.104.22.168 improving our services;
22.214.171.124 to respond to customer desires and preferences;
126.96.36.199 measuring the effectiveness of our marketing campaigns;
188.8.131.52 conducting marketing activities targeted at external, potential customers (on an aggregated and anonymized basis only); and
3.2 When you give us consent ( if required)
3.2.1 To provide you with direct marketing communications in relation to products, services, events, offers or promotions under the categories stated below, provided by
A/ us or our related companies (including our affiliate and subsidiary companies), B/ business partners, and C/ other third party providers, such marketing communications may be in various forms, including advertisements, special events notifications or newsletters, and delivered via various methods in accordance with the personal data that you provided to us, such as by emails, SMS, wechat messages, whatsapp messages, smartphone app push notifications, notifications on your social media pages, in-app messaging or postal mail. Such marketing communications may market or offer products or services (including special events and promotions) in the following categories: clothing and accessories, jewelry, luggage and bags, cosmetics, personal health and hygiene, home furnishings and housewares, and other products and services related to any of the foregoing, which we think may be relevant to you based on information you provide to us (for instance, via your participation in our surveys); and
3.2.2 To allow you to register for and participate inour events and promotions, including verifying your identity at those events and promotions.
3.3 For purposes which are required by law:
3.3.1 In response to requests by government or law enforcement authorities conducting an investigation.
4. Relying on our legitimate interests
We have carried out assessment on all the data processing activities described above in order to weigh up any privacy implications against our legitimate business interests. You can obtain information on any of our assessments by contacting us using the details set out later in this policy.
5. Withdrawing consent or otherwise objecting to direct marketing.
Wherever we require your consent under applicable law, you will always be able to withdraw any consent provided to us. We shall cease to use your personal data for the purpose in respect of which you have withdrawn your consent, but we may still use, process, store and transfer your data for other purposes, such as those set out above. Specifically, in the case of customers from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to op-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by contacting our privacy officer at email@example.com
6.Who will we share this data with, where and when?
We will share your personal data with the related companies of PARAGON DESIGN LIMITED for the purpose set out in clauses 3.1.and 3.2 above.
Personal data may be shared with government authorities and /or law enforcement officials if required for the purposes set out in clause 3.3 above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on our behalf for the purposes identified in clause 3 above. In particular, we use the following third party providers.
6.1 courier services
6.2 E-mail/ SMS/ MMS/ Wechat/ Whatsapp / IG / Facebook messenger service.
6.3 Telecom companies (for communication by mobile phone)
6.4 Data storage, and cloud service providers (for storage of your personal data, and hosting of applications that process your personal data for the purpose identified in this policy).
6.5 google, facebook, IG and other advertising networks ( for matching of your personal data with their database in order to send you our direct marketing material through your google, IG, Wechat and / or Facebook accounts.
6.6 Marketing (include digital marketing) and website analytic agencies ( for display of advertising materials on our site and other websites that you may visit, and analysis of your online behavior and usage of our site; and
6.7 Data analytics and hackathon service providers and agencies ( for the purpose stated in Clause 3.1.3 above, in which only anonymized data will be send to service providers for those purposes in sub clauses 184.108.40.206 and 220.127.116.11). you data, in an anonymous form such that your identity cannot be ascertained. In the even that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers ands any prospective purchaser's adviser and will be passed to the new owners of the business. If your information is transferred to a business partner or third party service provider in a country that is not subject to an adequacy decision y the EU commission, data will be adequately protected by EU commission approved standard contractual clauses, an appropriate privacy shield certification or third party or business partner's processor binding corporate rules.
7. What rights do i have ?
Where permitted by law, you have the right to ask us for a copy for your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share this data to another controller. In addition, you can object to the processing of your personal data in some circumstances ( in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given ( including direct marketing ) or other legal requirements).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights ) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
8. How do i get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org
9. Who is the data controller?
Who is the data controller? Shopify and Paragon Design Limited.