Essence Commerce (“the Site”) is committed to protecting and respecting your privacy.

This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. Collection of Data

We collect data from you in several different ways on the Site, including personal data and data about your use of the Site which does not identify you personally. Personal data means information, or combination of information, that can reasonably be used to identify you personally (such as your name, phone number, address, and email address).

We collect personal data that you voluntarily provide to us.

We collect personal data that you voluntarily provide to us (such as when you submit an inquiry), including name, email address, and any other data you choose to provide.

We automatically collect data about your use of the Site.

When you access and use the Site, our technology and tools may automatically collect and record certain data about your use of and interaction with the Site that does not identify you personally (such as your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring webpage, pages visited, and search terms).

We also use various tracking technologies (such as cookies and pixel tags) to collect data about your use of and access to the Site. Cookies are small data files stored on your hard drive or in device memory by websites you visit, applications you use, or advertisements you view and help us improve the Site and your experience on the Site. Pixel tags are electronic images that generate a generic notice of a visit to the Site and are used in conjunction with cookies to anonymously track activity on the Site by a particular browser.

Third parties may also automatically collect data about you.

Some content on the Site may be served by third-party content providers and may also use cookies, pixels tags, or other similar tracking technologies to automatically collect data about you, both on the Site and throughout the Internet. We do not control the technologies of those third parties. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.

2. Use of Collected Data

We use the data we collect to assist in the administration and operation of the Site and to provide you an efficient, meaningful, and customized experience.

We may use data to:

• Fulfill our obligations with respect to the reason you voluntarily provided the data (such as responding to an inquiry);
• Allow you to participate in certain features of the Site;
• Improve the Site or our products, events, and services and for other business or commercial purposes;
• Optimize your experience on the Site (such as troubleshooting technical programs or storing your preferences);
• Notify you about changes to the Site (including this Privacy Policy);
• Carry out any other purpose described to you at the time the data was collected; and
• Carry out any other purpose with your consent or as permitted by law.

Additionally, we may use data for marketing purposes to:

• Provide you with additional information regarding products, events, and services from Essence Commerce via email or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and
• Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).

3. Third-Party Websites

Through your use of the Site, you may access, directly or indirectly, other websites or services, including from our service providers, business partners, and other third parties, in each case, that are not owned or controlled by us. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.

Please note that when you apply for a job with us through our job application portal, the privacy policy of our job applicant processing partner may also apply to the submission of your application information.

4. Sharing of Collected Data

We may share the data we collect as follows:

• With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
• With our service providers that perform services for us (such as e-mail and mobile marketing, analytics, and web hosting);
• With our sponsors or event partners in connection with certain ticketed events;
• To comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property, or safety of our users and other third parties;
• With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop illegal, unethical, or actionable activity;
• In connection with, or during negotiations of, any merger, acquisition by another company, or sale of all or substantially all of our business or assets; and
• With your consent or at your direction.

5. Transfer of Collected Data

We may hold your data on servers in Hong Kong, and any other territories as we see fit from time to time. We may also transfer your data to overseas servers. By using the Site and/or providing us with any data, you consent to this transfer, processing, and storage of your data in Hong Kong, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen such as the European Union.

6. Data Security

We use commercially reasonable technical and organizational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.

7. Data Retention

We retain data only as long as necessary in light of the purpose(s) for which it was originally collected. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

8. Your Data Preferences

Cookies, Pixel Tags, and Other Similar Tracking Technologies - you may remove or reject cookies by adjusting settings on your browser, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data. These tracking technology opt-out tools are device and browser specific so you must repeat the opt-out from each of your devices and browsers. Please note that removing or rejecting cookies could affect the functionality of the Site.

9. Your Consent and Rights

By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.

Under the Hong Kong Personal Data (Privacy) Ordinance (the "Ordinance"), individuals have the right:

• to check whether we hold personal data about you and to access such data;
• to require us to correct as soon as reasonably practicable any data relating to you that is inaccurate;
• to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and
• to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.

You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to:

Clarityz Limited

3/F, The Hive Poho

5-13 New Street, Sai Ying Pun

Hong Kong

hello@essencecommerce.com

In accordance with the terms of the Ordinance, we have the right to and may charge a reasonable fee for processing any data access request.

In the event that a User wishes to access or amend his or her personal information and data, the Company may request him or her to provide personal details in order to verify and confirm his or her identity. An HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to a User’s request within thirty (30) days of his or her request and will endeavor to do so wherever possible.

10. Governing law and jurisdiction

Nothing in this Privacy Policy shall limit the rights of the data subject under the Ordinance. This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region. You agree to submit to the exclusive jurisdiction of the Hong Kong courts.

Last updated: 5 Nov 2024