PRIVACY POLICY

INTRODUCTION

  1. Purpose of this Privacy Policy

Castaralo Limited, (doing business as “MONO SKINCARE” or the "Company") (referred to in this Privacy Policy as “MONO SKINCARE”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

Throughout this Privacy Policy, the term "personal data" means any data relating directly or indirectly to you, from which it is practicable for your identity to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable. This Privacy Policy will inform you as to how we look after your personal data when you visit us at www.monoskincare.com, (the “Website”), regardless of where you visit them from, and tell you about your privacy rights and how the law protects you. This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Website, including any data you may provide through the Website, when you sign up to our newsletter and / or purchase any products on our Website.

By visiting our Website or providing us with your personal data via other means, you agree that we will collect, use and store your personal data in accordance with this Privacy Policy, as amended from time to time. This Privacy Policy is incorporated into and forms part of our Terms and Conditions.

We regularly review this Privacy Policy and may from time to time revise it by updating this page. By continuing to use our services after any amendments to this Privacy Policy, you are agreeing to this Privacy Policy as revised, so please do visit this page periodically for updates.

  1. Contact Information and Complaints

If you have any questions about this Privacy Policy or any questions regarding our use of your personal data, please contact our data privacy manager at hello@monoskincare.com, attention to Data Privacy Manager or by mail using the details provided below:

MONO Skincare, H10 Whitesands, South Lantau, New Territories Hong Kong SAR.

  1. Changes to this Privacy Policy and Personal Data

This Privacy Policy is regularly reviewed and was last updated on September 16th 2021. We may amend or update our Privacy Policy from time to time. For this purpose, we will provide you notice of amendments to this Privacy Policy and update the “last updated” date above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. Third-Party Links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

The types of personal data we collect, use and store about you will depend on your use on our Website and/or the nature of your interaction with us. When using our Website, we may collect and process the following types of personal data:-

  • your first name, last name (“Identity Data”);
  • your billing address, delivery address and email address (“Contact Data”);
  • your bank account and payment card details (“Financial Data”);
  • details about payments to and from you and other details of products and services you have purchased from us (“Transaction Data”);
  • your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Websites or the App (“Technical Data”);
  • your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (“Profile Data”);
  • information about how you use our Website (“Usage Data”); and
  • your preferences in receiving marketing from us and our third parties and your communication preferences (“Marketing and Communications Data”).

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW WE COLLECT YOUR DATA

  1. Direct Interactions

We collect Identity Data, Contact Data and Financial Data about you that you provide to us by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:-

  • purchase our products;
  • register on our Website;
  • subscribe to our newsletter;
  • request other marketing material to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us in any way or form.
  1. Automated Technologies and Interactions

As you interact with our Website we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

A cookie is a small file of letters and numbers stored by computer after being sent to your computer when you visit a website. Whenever you visit the same website again, the information stored in the cookie can be retrieved to notify the website of your previous activity. We use cookies to facilitate website navigation, maintain quality of online service, provide additional security, allow the customization of your access to the Website and remember you when you return to the Website.

A cookie cannot give us access to your computer or to information beyond what you provide us and we don't store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience on our Website. If you do not wish to enable cookies, you'll still be able to browse the Website and use them for research purposes.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

When you visit our Website, you may notice some cookies that are not related to MONO SKINCARE. If you go on to another website that contains embedded content, you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

  1. Third Parties

We are also working closely with third parties (including, for example, analytics providers and other third party providers of services).

We will receive personal data about you from such third parties as set out below:-

  • Technical Data and Usage Data from analytics providers such as Google, based inside and outside the EEA;
  • Contact Data, Financial Data and Transaction Data from our provider of payment services
  • Contact Data from delivery services

HOW WE USE YOUR PERSONAL DATA

  1. Data Usage

We are committed to only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you (“Performance of Contract”).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
  • Where we need to comply with a legal obligation (“Legal Obligations”).

We will use your personal data for the following purposes, and pursuant to the corresponding legal bases:

  • Registration as a new customer
  • Processing and delivery of your order
  • Management of our relationship with you (i.e. notifications about changes to Privacy Policy and asking you to leave a review or take a survey)
  • Enabling you to take part in a give away, competition or complete a survey
  • Administration and protection of our Website (including troubleshooting, data analysis, testing, system maintenance, support reporting and hosting of data)
  • Delivery of relevant website content and advertisements to you and understanding the effectiveness of the advertising we serve to you
  • Using data analytics to improve our Website, our products, marketing, customer relationships and experiences
  • Suggestions and recommendations about goods that may be of interest to you
  1. Marketing and Promotional Offers

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products may be relevant for you.

You will receive marketing emails and newsletters from us if you have requested information from us or purchased products from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have expressly consented to receiving such marketing emails and newsletters.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  1. Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by:-

  • by contacting us anytime at hello@monoskincare.com; and
  • by following the opt-out links on any newsletter or marketing message sent to you.

Where you opt-out of receiving these marketing messages or newsletters, this will not apply to personal data provided to us as a result of a product purchase which we will continue to process in order to perform a contract with you or as a result of our regulatory or legal obligations.

DISCLOSURES OF YOUR PERSONAL DATA

Your personal data held by us will be kept confidential, except we may disclose your personal data to the following parties (who may be located, and use your personal data, outside of Hong Kong):

  • Any: (a) person or company (including third party agent or sub-contractor) who is acting for, on behalf of or jointly with us; (b) any service provider of features on our Website; in all cases to fulfil any of the purposes, provided that such parties are subject to confidentiality and privacy obligations that are materially equivalent to those set out in this Privacy Policy ; (c) in case we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction, but we will notify you and/or your organization (for example, via email and/or a prominent notice on our Website) of any change in control or use of your personal data or Files, or if either become subject to a different Privacy Policy
  • Any financial institutions, charge or credit card issuing companies, credit information or reference bureaus, or collection agencies where necessary to establish and support the payment of any products and services being requested by you; and

We do not provide your personal data to any other third parties unless your prior express consent is obtained. We may transfer anonymous and aggregated data to third parties from time to time, which may include your personal data in an anonymous format and which does not allow the third parties to identify you in any way other than on our own Site.

This Privacy Policy applies to us and our Website, but not to any other third parties (including any websites maintained by third parties). Please check and read such third party’s privacy policy before submitting any of your personal data to such third parties (whether via our Site or not). We do not accept any responsibility or liability for any use or breach of your personal data by such third parties.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

1.     GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us at hello@monoskincare.com.

  1. CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us at hello@monoskincare.com. If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

PRIVACY OF MINORS

We do not collect or consciously request information from users under the age of 18, nor do we consciously allow such users to register with our services, except with parental consent. Our services and their contents are not intended for children under the age of 18.

If we learn that we have collected personal information from a child under the age of 18 without parental consent, we will delete this information as soon as possible.

If you believe we have any information about a child under the age of 18, please contact us at hello@monoskincare.com.