CoCoMall Technology Limited Privacy Policy

CoCoMall Technology Limited Privacy Policy

1. Protection of Personal Data

The protection and respect of your personal data are of paramount importance. To facilitate an enhanced service and provide an optimal customer experience, the collection of certain personal data is required. This Privacy Policy outlines how personal data is collected and utilized, with whom it may be shared, and how its collection and use may be controlled.

Access or use of the Website (www.cocomalleshop.com), hereinafter referred to as the "Website," or the mobile application ("App"), or the registration for a CoCoMall membership that is accessible to the App and the Website ("Membership"), constitutes your agreement to and acceptance of this Privacy Policy. If this policy is not fully agreed upon by you, all use of the Website or App must cease, and a Membership should not be applied for. You hereby fully and irrevocably acknowledge and agree to use any products or services provided by the Service Provider. The Service Provider shall provide the Services (as hereinafter defined), which include the features and functions listed out on the App and the Website, and arrangements of online and offline trading events for you, in accordance with the terms and conditions outlined in this Privacy Policy. Personal data collected will be used in accordance with this Privacy Policy.

2. About the Company

CoCoMall Technology Limited, a company incorporated in Hong Kong having its registered office at 12/F, Eastern Central Plaza, 3 Yiu Hing Rd, Shau Kei Wan (the “Service Provider”) possesses a mobile application - CoCoMall (the ‘’App") and an online shopping website - {https://www.cocomall.hk} (the “Website”), which offer discounts, limited-time flash sales, and group-buying promotions in the form of Digital Coupons, as well as products from major retail channels and brands. 

3. DIRECT DIGITAL MARKETING PROMOTION CONSENT AND WAIVER

3.1. Data Collection and Partners. Your personal data is provided by you or is collected by the Service Provider, the CODECO Group, the third-party collaborators, or the third-party service provider of the Service Provider, which are collectively deemed as (the “Partners”) or captured automatically. For instance, personal data is collected upon completion of a Membership application, during any transactions with any products including Digital Coupons for sales that are via the Website and/or the App, upon redemption of any Digital Coupon, when any notices, updates, reports, reports acceptance confirmations are sent to the Service Provider or received by the Service Provider, or when the Website or App is browsed.

3.2. User Consent and Scope of Promotion. By accessing, utilizing, or otherwise interacting with the App, the Website, or any associated online or offline services or activities provided by the Service Provider (collectively, the "Services"), the User is deemed to have granted, and hereby grants, full, unambiguous, and explicit permission for Direct Digital Marketing Promotion.

3.3. Marketing Parties and Channels. This permission extends to the Service Provider and any and all entities within the CODECO Group (collectively, the "Marketing Entities"). Direct Digital Marketing Promotion includes, but is not limited to, the transmission of promotional, marketing, and sales event information through the following channels, utilizing the contact and personal data provided by the User:

App notification push messages.
Marketing or sales events displayed via the App or the Website.
WhatsApp messages.
SMS messages.

3.4. Condition of Service Use. The User acknowledges and agrees that the granting of this full permission for Direct Digital Marketing Promotion is a fundamental precondition for the use of the Services. If the User does not agree to the terms set forth in this Clause 3, they must not commence, continue, or maintain use of the App, the Website, or any related online or offline activities. Continued use constitutes express agreement.

3.5. Waiver of Claim. Unless the User provides a specific, written notice of decline of Direct Digital Marketing Promotion to the Service Provider's designated legal department via certified mail (the sole mechanism for opting out), the User is deemed to have given full and irrevocable permission. The User expressly waives any and all claims, demands, or causes of action against the Marketing Entities related to the receipt of these marketing communications, including claims of unsolicited contact, invasion of privacy, or digital trespass, and acknowledges that the Marketing Entities bear no responsibility for any resulting direct or indirect damage or inconvenience arising from the sending or receipt of such communications.

4. Age Restriction

The Website, App, and any attempts to use online and/or online services and/or trading events are intended for use only by individuals aged 18 or over. However, if an individual is under the age of 18, use of the Website or App or application for a Membership is permitted only with the prior authorization of a parent or legal guardian. The consent of the parent or legal guardian to use the Website or App or to become the App’s and/or the Website’s Member, on the basis of this Privacy Policy, must be obtained.

5. Information Collected

The provision of certain personal data may be required to receive the benefits of the App and/or the Website, the Website, or the App. You will be notified when such data is essential for Membership. All other personal data may be provided at your discretion. For the avoidance of doubt, personal data is defined as information capable of directly or indirectly identifying an individual. This information includes, but is not limited to, name, identity card number, address, telephone number, IP address, shopping habits, lifestyle, and health information.

(a) Membership Data

If you are a registered member of the App and/or  the Website("Member"), personal data that may be collected includes:

Your full name, month and year of birth, email address, telephone number, postal address, username, and password;
Any activities, details, and status displayed on the Website and the App;
Your transaction history or payment details upon making a purchase from the Service Provider or a Partner and utilizing your Membership to accumulate Points (including the product or service purchased, the date of purchase, the location of the purchase, the cardholder's name, credit card number, expiry date, and billing information);
Information regarding the Digital Coupons that are redeemed; and
Your shopping habits/preferences, including brand preferences and the types of products and services of potential interest to you.

(b) Data Collected During Website or App Visits

Online tracking technologies, including but not limited to cookies, pixel tags, web beacons, and other similar technologies, may be employed to automatically collect information about:

Your visits to the Website or App, such as your browsing history, visit duration, and frequency;
Your live and/or frequently stayed location(s) information as provided by your mobile or other device when interacting with the Website or App, including your IP address and general geographic location; and the device used to browse the Website or App (e.g., your device ID, operating system, device type, browser type and version, mobile application crashes and other system activity, and third-party Websites accessed prior to interacting with the services).

The right to disable any of these online tracking technologies is available. To learn more about how the above data is used, please refer to the section below on Clause 14 Online Tracking Technology.

(c) Other Information

Your personal data is also collected whenever communication is initiated by you (e.g., email content, contact information, etc.) or when any voluntary surveys and questionnaires that may be sent from time to time are completed (e.g., your demographic information and feedback). This data is utilized to better understand you, improve the services, and/or enhance the membership program.

6. Use of Information

Your personal data will only be used for the purposes outlined below.

(a) Account Administration

Your account administration and maintenance are facilitated through:

The creation and updating of your Account;
Identity verification;
The creation of a single profile about you, which includes combining your information with any other personal data already held by the Service Provider, its Partners, or any members of  the CODECO Group;
The processing of any offers issuance and redemptions of Digital Coupons and any offers issued by the Service Provider, its Partners, and the CODECO group members;
The completion of transactions, including the processing or facilitation of payments;
The sending of updates about new features and benefits relating to the App and/or the Website;
The solicitation of your views and feedback via voluntary surveys and questionnaires for a better understanding of your needs, and for the improvement of services and/or the membership programme; and
The enabling of features that allow for the personalisation of your Account on the Website or App, such as bookmarking your frequently viewed and/or purchased items.

(b) Customer Support

Assistance is provided when your inquiries are sent to the Service Provider indicated channel aiming to provide Customer Services is/are granted with confirmation of acceptance of such enquire(s), which includes responding to and investigating any of your questions or concerns, and the monitoring and improvement of customer support services.

(c) Marketing

Your preferences and market trends are analyzed to generate insights. These insights may be used to tailor the advertisements and offers presented to you on the Website, App, and third-party social media platforms. Additionally, the information collected about you may be combined with data from other customers to enhance these insights and identify market trends. These insights, which are anonymised personal data, may be shared with suppliers for product promotion purposes.

While the App or Website is used, or other third-party platforms are browsed, marketing, offers, and promotional materials ("Marketing Materials") may be displayed within the App, Website, and other third-party platforms.

For information about Direct Marketing, please see the section on Direct Marketing below.

(d) Personalisation

Personalized Marketing Materials are created and tailored to your interests and preferences, and/or to provide you with the best possible personalized customer experience in relation to the Website, App, and your Membership. Data analytics tools may also be used to determine whether offers, advertisements, and promotions from the Service Provider or any CODECO Group members are effective, as well as to determine whether you may be interested in new products or services, and/or to customize the content and types of offers, products, and services presented to you. For the purpose of personalizing your experience, advertising service providers (such as social media platforms) may also be utilized for marketing and promotional purposes, which may involve the sharing of your anonymised personal data with them.

(e) Optimisation and Improvements

Your personal data may be used to understand and improve the Website, App, or the Service Provider’s operations, or the operations of Partners or the CODECO Group members, through various means, such as the use of analytics tools, research, surveys, pushed notifications through the App, online and offline customized and universal advertisements and promotions, and feedback forms. This will enable the Service Provider, its Partners, and its CODECO Group members to enhance services or products, develop new features and benefits, and amend business, marketing, and strategic operations and plans.

(f) Legal and Administration Purposes

Your personal data may be used to investigate or handle any incidents, claims, or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts, or other governmental agencies. Your personal data may also be used in relation to any legal proceedings concerning you.

7. Disclosure of Information to Third Parties

For the protection of your privacy, an endeavour will be made to share only aggregated and anonymised data, or data that otherwise does not contain your name or contact details, with third parties. However, in limited circumstances, data (which may include your personal data) may be shared with third parties who may or may not be located overseas, as detailed in this section. By using the Website or App, or applying for a Membership, your agreement is granted for the sharing of your personal data with third parties and for the cross-border transfer of your personal data in accordance with this section. Regardless of where your personal data is stored or processed, a commitment is made to protect it and to take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.

(a) Partners

If you are a Member, your personal data may be shared with the Partners to facilitate the processing of Digital Coupons issuance, Digital Coupons redemption, and related transactions and any other types of offers, as well as for data analytics purposes to improve their operations, services, or products.

Please be aware that personal data may be collected directly by the Partners if it is provided to them when any goods or services are purchased from them, or if registration as a customer is made with them. The handling of data collected by the Partners will be governed by the relevant Partner's separate privacy policy (and not this Privacy Policy), and no involvement or responsibility is assumed for the collection and handling of such data.

(b) CODECO Group

Your personal data may be transferred to any CODECO Group member for any of the purposes set out above. Your personal data may be provided to any CODECO Group member for the purpose of sending marketing materials regarding their own products and services, unless immediate refusal regarding these advertisements is obtained.

(c) Service Providers

Your personal data may be shared with service providers (including agents and contractors) of the Service Provider or any CODECO Group members, who process personal data on behalf of the Service Provider to assist in the administration and operation of the Website, and the App, to conduct data analytics, to help aggregate and anonymise personal data, to send Direct Marketing Promotion Communications, or to carry out any of the purposes set out in this Privacy Policy. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, technological service providers, data management and analytics service providers, and customer contact services. Contact may be made on behalf of the Service Provider or on behalf of CODECO Group members by the service providers for any of the purposes set out above.

Only trustworthy service providers are utilized, who are under an obligation to protect and maintain the confidentiality of your personal data and to only use your personal data in accordance with the purposes outlined in this Privacy Policy.

(d) Professional Advisors and Assignees

When necessary, your personal data may be shared with professional advisors, including lawyers, accountants, financial advisors, and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing, or any other similar scenarios involving the transfer of some or all of the business assets.

(e) Government and Regulatory Authorities

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"). The handling of your personal data is striven to be in accordance with any data privacy laws that apply. Your personal data may be shared with regulatory authorities, courts, and other governmental agencies to comply with any legal or regulatory requirements, orders, or requests. Any dispute, controversy, difference or claim arising out of or relating to this Privacy Policy, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong Arbitration Society under the Hong Kong Arbitration Society Rules. The law of this arbitration clause shall be the laws of Hong Kong. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be in singular number(s). The arbitration shall be international and the subject-matter of the arbitration agreement relates to more than one country.

8. Aggregated and Anonymised Data

Aggregated or anonymised data that does not include any personally identifiable information may be utilized by the Service Provider, its Partners, its CODECO Group members, or other third parties for various purposes, including but not limited to enabling them to better understand customer needs or to improve and adapt their operations, products, and services, or for the purposes of industry benchmarking, machine learning, behaviour segmentation, targeted marketing, and research or analytics.

9. Direct Marketing

In the event that agreement has been given to receive offers and promotions from the Service Provider, Direct Marketing Communications (defined below) may be sent to you via email, app push notifications, SMS, post, telephone, and such other direct means of communications that may be provided ("Direct Marketing"), in connection with:

a) the latest news, events, updates, offers, Marketing Materials, and promotions in relation to the App and/or the Website; b) the latest news, events, updates, contests, promotions, offers, products, services, and Rewards offered by the Partners or CODECO Group members, which include but not limited to retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, electric vehicles charging services, built-in materials, any and all Digital Coupons, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications; and/or c) any seasonal events, lucky draws and contests, or other promotional activities. (collectively “Direct Marketing Communications”)

Before Direct Marketing Communications are sent to you for Direct Marketing purposes, your consent will be sought which based on your use of the App, the Website, or any other online and/or offline services provided by the Service Provider, its Partners, and/or members of the CODECO group. A choice can be made at any time not to receive any Direct Marketing by informing the Service Provider of this choice through explicit written notice or setting your communication preferences within the App, Website, and/or your mobile device. Please see section 13 (Your rights) below.

10. Partner and Affiliate Marketing

Marketing materials will not be sent to you by the Partners or CODECO Group members unless permission for this has been granted.

Should any Partner or CODECO Group member wish to directly send you any Direct Marketing Communications regarding their own products and services, then your separate consent must be obtained for this. No involvement is had in any direct marketing done directly by the Partners or CODECO Group members that is unrelated to the Service Provider. However, Direct Marketing Communications may be sent to you on behalf of the Partners or CODECO Group members, subject to your consent and in accordance with section 9 (Direct Marketing) above. If agreement is given to receive any direct marketing communications directly from the Partners or CODECO Group members, the respective Partners' or CODECO Group members’ own privacy policies should be carefully read.