We want you to be familiar with how we collect, use
and disclose Personal Information (as defined below). This Privacy Policy
describes our practices in connection with Personal Information that we collect
through websites operated by us or our affiliates from which you are accessing this
Privacy Policy (the “Websites”), through the
software applications made available by us for use on or through computers and
mobile devices (the “Apps”), through our
social media pages and apps, if any, through HTML-formatted email messages that we
send to you that link to this Privacy Policy, as well as through your offline
interactions with us where notice is legally required (collectively, including the
Websites, Apps, Social Media Pages and offline interactions, the
“Services”). By using the Services,
you agree to this Privacy Policy.
1.
Personal
Information
“Personal
Information” is information that identifies you as an individual
or relates to an identifiable individual, including:
-
Name
-
Postal address (including billing
and shipping addresses)
-
Telephone
number
-
Email address
-
Credit and debit card
number
-
Profile picture
-
Social media account
ID
-
Travel information, including
trip flight information
-
Date of birth
-
Gender
-
Air ticket number and Asia Miles
Membership Number (for Cathay Pacific customers only)
Collection of Personal Information
We and our service providers may collect Personal
Information in a variety of ways, including:
-
Through
the Services
: We may collect
Personal Information through the Services, e.g., when you sign up for a newsletter
or make a purchase.
-
Offline
: We may collect
Personal Information from you offline, such as when you visit our stores, attend one
of our trade shows, place an order over the phone or contact customer
service.
-
From
Other Sources
: We may receive your
Personal Information from other sources, such as our affiliates, public databases,
joint marketing partners, social media platforms (including from people with whom
you are friends or otherwise connected) and from other third parties. In
addition, if you elect to connect your social media account to your Website account,
certain Personal Information from your social media account will be shared with us,
which may include Personal Information that is part of your profile or your friends'
profiles.
We may use a third-party payment
service to process payments made through the Services. If you wish to make
a payment through the Services, your Personal Information may be collected by such
third party and not by us, and will be subject to the third party’s
privacy policy, rather than this Privacy Policy. We have no control over,
and are not responsible for, this third party’s collection, use and
disclosure of your Personal Information.
If you submit any Personal
Information relating to other people to us or to our service providers in connection
with the Services, you represent that you have the authority to do so and to permit
us to use the information in accordance with this Privacy
Policy.
How We
May Use Personal Information
We and our service providers may
use Personal Information:
-
To respond to your inquiries
and
fulfill your requests, such
as
to complete your transactions and provide you with related customer
service.
-
To send administrative
information to you, such as changes to our terms, conditions and policies, as well
as marketing communications that we believe may be of
interest.
-
To personalize your experience on
the Services by presenting products and offers tailored to you and to facilitate
social sharing functionality.
-
To allow you to participate in
sweepstakes, contests, loyalty programs and similar promotions and to administer
these activities. Some of these activities have additional rules
containing additional information about how we use and disclose your Personal
Information.
-
For our business purposes, such
as data analysis, audits, fraud monitoring and prevention, developing new products,
enhancing, improving or modifying our Services, identifying usage trends,
determining the effectiveness of our promotional campaigns and operating and
expanding our business activities.
Disclosure of Personal Information
Your Personal Information may be
disclosed:
-
To our affiliates for the
purposes described in this Privacy Policy.
-
To our third-party service
providers who provide services such as website hosting, data analysis, payment
processing, order fulfillment, information technology and related infrastructure
provision, customer service, email delivery, auditing and other
services.
-
To third parties, to permit them
to send you marketing communications, consistent with your choices if you have opted
into such sharing.
-
To third-party sponsors of
sweepstakes, contests, loyalty programs and similar promotions.
-
By you, on message boards, chat,
profile pages and blogs and other services to which you are able to post information
and content (including, without limitation, our Social Media Pages).
Please note that any information you post or disclose through these services will
become public and may be available to other users and the general
public.
-
To your friends associated with
your social media account, to other website users and to your social media account
provider, in connection with your social sharing activity. By connecting
your Services account and your social media account, you authorize us to share
information with your social media account provider, and you understand that the use
of the information we share will be governed by the social media provider's privacy
policy.
Other
Uses
and
Disclosures
We also may use and disclose your
Personal Information as we believe to be necessary or appropriate: (a) to comply
with applicable law, which may include laws outside your country of residence, to
respond to requests from public and government authorities, which may include such
authorities outside your country of residence, to cooperate with law enforcement, or
for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect
our rights, privacy, safety or property, and/or that of our affiliates, you or
others.
We may furthermore use, disclose
or transfer your information to a third party in the event of any reorganization,
merger, sale, joint venture, assignment, transfer or other disposition of all or any
portion of our business, assets or stock (including in connection with any
bankruptcy or similar proceedings).
We may also use and disclose
Personal Information collected through the Services in other ways, with your
consent.
2.
OTHER
Information
“Other
Information” is any information that does not reveal your
specific identity or does not directly relate to an identifiable individual, such
as:
-
Browser and device
information
-
App usage data
-
Information collected through
cookies, pixel tags and other technologies
-
Demographic information and other
information provided by you that does not reveal your specific
identify.
-
Information that has been
aggregated in a manner that it no longer reveals your specific
identity.
If we are required to treat Other
Information as Personal Information under applicable law, then we may use and
disclose it for the purposes for which we use and disclose Personal Information, as
detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other
Information in a variety of ways, including:
-
Through
your browser or
device
: Certain information
is collected by most browsers or automatically through your device, such as your
Media Access Control (MAC) address, computer type (Windows or Macintosh), screen
resolution, operating system name and version, device manufacturer and model,
language, Internet browser type and version and the name and version of the Services
(such as the App) you are using. We use this information to ensure that
the Services function properly.
-
If
applicable, through your use of the
App
:
When you download and use the
App,
we and our service
providers
may track and collect App usage
data, such as the date and time the App on your device accesses our servers and what
information and files have been downloaded to the App based on your device
number.
If you do not want information
collected through the use of cookies, most browsers allow you to automatically
decline cookies or be given the choice of declining or accepting a particular cookie
(or cookies) from a particular website.
You may also wish to refer to
http://www.allaboutcookies.org/manage-cookies/index.html.
If, however, you do not accept cookies, you may experience some inconvenience in
your use of the Services. You also may not receive advertising or other
offers from us that are relevant to your interests and needs.
-
Using
pixel tags and
other
similar technologies: Pixel tags (also known as web beacons and
clear GIFs) may be used to, among other things, track the actions of users of the
Services (including email recipients), measure the success of our marketing
campaigns and compile statistics about usage of the Services and response
rates.
We use services of Google
Analytics, which uses cookies and similar technologies to collect and analyze
information about use of the Services and report on activities and trends.
This service may also collect information regarding the use of other websites, apps
and online resources. You can learn about Google’s practices by
going to
www.google.com/policies/privacy/partners/
,
and opt out of them by
downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout,
We also use the services of
Emarsys to track and gather certain information on this website that helps us to
better understand our visitors’ needs related to our website, our services
and/or our products. You can learn about Emarsys’s practices by
going to https://www.emarsys.com/en-hk/privacy-policy/, and opt out of them by using
the “unsubscribe” link at the bottom of any email that may send
you, or by emailing unsubscribe@emarsys.com.
-
IP
Address
: Your IP address is a
number that is automatically assigned to your computer by your Internet Service
Provider (ISP). An IP address may be identified and logged automatically
in our server log files whenever a user accesses the Services, along with the time
of the visit and the page(s) that were visited. Collecting IP addresses is
standard practice and is done automatically by many websites, applications and other
services. We use IP addresses for purposes such as calculating usage
levels, diagnosing server problems and administering the Services. We may
also derive your approximate location from your IP address.
-
Physical/Site
Location:
We may collect the
physical location of your device by, for example, using satellite, cell phone tower
or WiFi signals. We may use your device’s physical location to
provide you with personalized location-based services and content. We may
also share your device’s physical location, combined with information
about what advertisements you viewed and other information we collect, with our
marketing partners to enable them to provide you with more personalized content and
to study the effectiveness of advertising campaigns. In some instances,
you may be permitted to allow or deny such uses and/or sharing of your
device’s location, but if you do, we and/or our marketing partners may not
be able to provide you with the applicable personalized services and
content.
Uses
and Disclosures of Other Information
We may use and disclose Other Information for any
purpose, except where we are required to do otherwise under applicable
law. In some instances, we may combine Other Information with Personal
Information. If we do, we will treat the combined information as Personal
Information as long as it is combined.
3.
THIRD
PARTY
SERVICES
This Privacy Policy does not address, and we are not
responsible for, the privacy, information or other practices of any third parties,
including any third party operating any website or service to which the Services
link. The inclusion of a link on the Services does not imply endorsement
of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the
information collection, use, disclosure or security policies or practices of other
organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app
developer, app provider, social media platform provider, operating system provider,
wireless service provider or device manufacturer, including with respect to any
Personal Information you disclose to other organizations through or in connection
with the Apps or our Social Media Pages.
4. THIRD-PARTY
ADVERTISING
We may use third-party advertising companies to
serve advertisements regarding goods and services that may be of interest to you
when you access and use the Services and other websites or online services, based on
information relating to your access to and use of the Services and other websites or
online services on any of your devices, as well as on information received from
third parties. To do so, these companies may place or recognize a unique
cookie on your browser (including through the use of pixel tags). They may
also use these technologies, along with information they collect about your online
use, to recognize you across the devices you use, such as a mobile phone and a
laptop. If you would like more information about this practice, and to
learn how to opt out of it in desktop and mobile browsers on the particular device
on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/managing/opt_out.asp
and http://www.aboutads.info/.
You may download the AppChoices app at www.aboutads.info/appchoices to opt out in
mobile apps.
5.
security
We seek to use reasonable organizational, technical
and administrative measures to protect Personal Information within our
organization. Unfortunately, no data transmission or storage system can be
guaranteed to be 100% secure. If you have reason to believe that your
interaction with us is no longer secure, please immediately notify us in accordance
with the “Contacting Us”
section below.
6.
CHOICES AND
ACCESS
Your choices regarding our use
and disclosure
of your Personal
Information
We give you choices regarding our use and disclosure
of your Personal Information for marketing purposes. You may opt-out
from:
-
Receiving
electronic communications from
us
: If you no longer want
to receive marketing-related emails from us on a going-forward basis, you may
opt-out by: following the unsubscribe link in any
marketing
communication and by contacting us at
contact.hk@americantourister.com.
Similarly, to stop
receiving
SMS text messages, you will have to send an email to
contact.hk@americantourister.com to unsubscribe the SMS contact.
-
Our
sharing
of
your Personal Information with affiliates for their direct marketing
purposes
: If you would prefer
that we not share your Personal Information on a going-forward basis with our
affiliates for their direct marketing purposes, you may opt-out of this sharing by:
contacting us at
contact.hk@americantourister.com.
-
Our
sharing
of
your Personal Information with unaffiliated third parties for their
direct
marketing purposes
: If you would prefer
that we not share your Personal Information on a going-forward basis with
unaffiliated third parties for their direct marketing purposes, you may opt-out of
this sharing by: contacting us at
contact.hk@americantourister.com.
We will try to comply with your request(s) as soon
as reasonably practicable. Please note that if you opt-out of receiving
marketing-related emails from us, we may still send you important administrative
messages, from which you cannot opt-out.
How you
can access, change or suppress your
Personal Information
If you would like to review, correct, update,
suppress/restrict or delete Personal Information that you have previously provided
to us, or if you would like to transfer your Personal Information to another company
(to the extent this right to data portability is provided to you by applicable law),
you may contact us by writing to contact.hk@americantourister.com or call us
on (852) 2422-2611.
In your request, please make
clear what Personal Information you would like to have changed, whether you would
like to have your Personal Information suppressed from our database or otherwise let
us know what limitations you would like to put on our use of your Personal
Information. For your protection, we may only implement requests with
respect to the Personal Information associated with the particular email address
that you use to send us your request, and we may need to verify your identity before
implementing your request. We will try to comply with your request as soon
as reasonably practicable.
Please note that we may need to
retain certain information for recordkeeping purposes and/or to complete any
transactions that you began prior to requesting a change or deletion (e.g., when you
make a purchase or enter a promotion, you may not be able to change or delete the
Personal Information provided until after the completion of such purchase or
promotion). There may also be residual information that will remain within
our databases and other records, which will not be removed.
7.
RETENTION PERIOD
We will retain your Personal Information for the
period necessary to fulfill the purposes outlined in this Privacy Policy unless a
longer retention period is required or permitted by law.
8.
use of
Services by
MINORS
The Services are not directed to individuals under
the age of eighteen (18), and we do not knowingly collect Personal Information from
individuals under 18.
9.
Jurisdiction and CROSS-BORDER
TRANSFER
The Services are controlled and operated by us from
the United States and are not intended to subject us to the laws or jurisdiction of
any state, country or territory other than that of the United States. Your
Personal Information may be stored and processed in any country where we have
facilities or in which we engage service providers, and by using the Services you
consent to the transfer of information to countries outside of your country of
residence, including the United States, which may have data protection rules that
are different from those of your country. In certain circumstances,
courts, law enforcement agencies, regulatory agencies or security authorities in
those other countries may be entitled to access your personal
information,
If you are located in the EEA:
Some of the non-EEA countries are recognized by the European Commission as providing
an adequate level of protection according to EEA standards (the full list of these
countries is available here a hyperlink to EU Commission’s adequacy list
online:
https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
With regard to transfers to other countries, we have put in place
measures, such as [standard contractual clauses adopted by the European Commission
and binding corporate rules to protect your Personal Information. You may obtain a
copy of these measures by contacting European Commission
https://ec.europa.eu/info/about-european-commission/contact_en
or by following this link:
https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
10.
SENSITIVE
INFORMATION
we ask that you not send
us, and you not disclose, any sensitive Personal Information
(e.g., social security numbers, information related to racial or
ethnic origin, political opinions, religion or other beliefs, health, biometrics or
genetic characteristics, criminal background or trade union membership) on or
through the Services or otherwise to us.
11.
RATINGS AND
REVIEWS
The Services include the “Ratings and Reviews” feature on our Websites,
which you may choose to use for the purpose of leaving a rating for product and
sharing product reviews. Therefore, we may collect your Personal Information, and we
will collect Other Information, through your use of such “Ratings and Reviews”
feature, should you choose to use it. For your Personal Information, if collected by
us through the “Ratings and Reviews” feature, the above sections of this Privacy
Policy on Personal Information shall apply accordingly. For Other Information
collected by us through the “Ratings and Reviews” feature, in addition to the above
sections of this Privacy Policy on Other Information being applied accordingly, we
may also use and disclose such Other Information for reviews-specific purposes
including but not limited to administering ratings and reviews directly by us or
with the use of third party service providers, syndicating ratings and reviews
across Websites operated by us, our affiliates and our authorised distributors or
business partners, in other countries. You can request that we remove content or
information that you have posted through the “Ratings & Reviews” feature. To do
so, please submit a written request as per instructions within this Privacy Policy.
Please note that we may request for further information from you in order to
ascertain your identity and the nature of your request, as well as to process,
fulfil or otherwise deal with your request. Please note that while we will endeavour
to honour your request, our removal of your content or information does not ensure
complete or comprehensive removal of that information from Websites operated by us,
our affiliates and our authorised distributors or business partners, or the
internet. For example, historical copies, or “caches” may remain.
12. UPDATES TO THIS PRIVACY
POLICY
We may change this Privacy Policy. The
“Last
Updated” legend at the top of this Privacy Policy
indicates when this Privacy Policy was last revised. Any changes will
become effective when we post the revised Privacy Policy on the Services.
Your use of the Services following these changes means that you accept the revised
Privacy Policy.
13.
CONTACTING
US
If you have any questions about this Privacy Policy,
please contact us at privacy.asia@samsonite.com.
Because email communications are not always secure,
please do not include credit card or other sensitive information in your emails to
us.