Updated on Jan 23, 2017

Personal Data (Privacy) Policy Statement (“Privacy Policy”)

LUBUDS® GROUP LIMITED and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”; if the context requires or permits, “Company” may refer to any one of LUBUDS HK Ltd and/or its subsidiary(ies) and/or affiliate(s)) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via members@lubuds.com, its sub-domains, any other websites, media platforms or applications including mobile applications operated/developed by the Company (hereinafter collectively referred to as the "Channels" ) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (“User(s)”) except to the authorized persons listed under paragraph 3 below.

Users are strongly recommended to read this Privacy Policy carefully to have an understanding of the Company’s policy and practices with regard to the treatment of personal information and data provided by the Users on the Channels. This Privacy Policy is applicable to both registered and non-registered Users, and the provisions herein may be updated, revised, varied and/or amended from time to time as the Company deems necessary.

If Users have questions or concerns regarding this Privacy Policy, they should first contact the Customer Service Representative of the Company's Customer Service Department by email to members@lubuds.com

• Purpose of Collection of Personal Data
  • In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so. The Company’s purposes for collection of information and data on the Channels include but not limited to the following:
    1. for the daily operation of the services provided to Users;
    2. to identify Users who accumulate points as part of our membership program;
    3. to identify Users who have posted advertisements, materials, messages, photos, views or comments or such other information (collectively “Information”) on the Channels;
    4. to provide Users with marketing and promotional materials for their enjoyment of benefits as members of the Channels;
    5. to notify members the update or/and amended information about the membership program or our product/service.
    6. to identify Users who have enjoyed their benefits as members of the Channels by receiving and using marketing and promotional materials;
    7. to allow updates or amendment of member's data;
    8. to design and provide products and services advice to Users in relation to the above purposes;
    9. to compile and analyze aggregate statistics about the Users’ use of the Channels and service usage by the Users for the Company’s internal use and marketing purposes, and to facilitate the Company to use the Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events and/or promotions of the Company and/or its clients.; 
    10. to allow us to follow up the satisfaction of the service;
    11. to deliver survey on service and products;
    12. to deliver information of VIP events and news;
    13. to directly market our products, include:
        1. to notify members of new products, service, and promotions of restaurants;
        2. to notify members of products, service, and promotions of business other than restaurants;
        3. to notify members of promotional events, birthday special, free trials of product, road shows and shop promotions;
        4. to notify members of promotional events of shopping malls, credit cards, banks, celebrities, media, charity and non-profit organization. 
  • The Company strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove. 
    
    If the Company requires the use of Users’ personal data for a purpose other than those set out hereinabove, the Company may request the Users’ prescribed consent to the same. If User is a minor, the prescribed consent should be given by his/her parent or guardian.
• Collection of Personal Data
  • The Company may collect personal information and/or data about a User such as his/her name, log-in ID and password, address, email address, phone number, age, sex, date of birth, country of residence, nationality, education level and work experience that is/are not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from a User in connection with contests, surveys, or special offers. Only duly authorized the staff of the Company will be permitted to access the Users’ personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Paragraph 3. entitled “Disclosure or Transfer of Data”.

1. Disclosure or Transfer of Data
   • The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following. 
     
     Generally speaking, the Company will only disclose and/or transfer Users’ personal information and/or data to the Company’s personnel and staff for the purpose of providing services to Users. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances:
     • where the information and/or data is disclosed and/or transferred to any third-party suppliers or external service providers who have been duly authorized by the Company to use such information and/or data and who will facilitate the services on the Channels, under a duty of confidentiality;
     • where the information and/or data is disclosed and/or transferred to any agents, affiliates or associates of the Company who have been duly authorized by the Company to use such information and/or data;
     • where the Company needs to protect and defend its rights and property;
     • where the Company considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Channels; and
     • where the Company deems necessary in order to maintain and improve the services on the Channels.
   • Personal data collected via the Channels may be transferred, stored and processed in any country in which the Company operates. By using the Channels, Users are deemed to have agreed to, consented to and authorized the Company to disclose and/or transfer their personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the Users’ country.
2. Subscription of Newsletter/Promotional Materials/Marketing Materials
   • The Company may from time to time send to members and Users of the Channels newsletters, promotional materials and marketing materials based on the personal information and data that they have provided to the Company. The Company may use Users’ data in direct marketing and the Company requires the Users’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
     • the name, log-in ID and password, contact details, age, sex, date of birth, country of residence, nationality, education level and work experience of Users held by the Company from time to time may be used by the Company and/or its authorized personnel or staff in direct marketing;
     • the following classes of services, products, and subjects may be marketed:
       1. food and beverage related products and services;
       2. traveling related products and services;
       3. special events hosted by the Company and its affiliates for members and Users, including but not limited to courses, workshops, and competitions;
       4. reward, loyalty or privileges programs and related products and services;
       5. special offers including coupons, discounts, group purchase offers and promotional campaigns;
       6. products and services offered by the Company and its advertisers (the names of such entities can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be);
       7. donations and contributions for charitable and/or non-profit making purposes;
     • The above products, services, and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or:
       • third party service providers providing the products, services, and subjects listed in paragraph (b) above; and
       • charitable or non-profit organizations;
     • in addition to marketing the above services, products and subject itself, the Company also intends to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products, and subjects, and the Company requires the Users’ written consent (which includes an indication of no objection) for that purpose;
     • the Company may receive money or other property in return for providing the data to the other persons in paragraph (d) above and, when requesting the Users’ written consent as described in paragraph (d) above, the Company will inform the Users if the Company receives any money or other property in return for providing the data to the other persons.
   • Suitable measures are implemented to make available to such members the options to “opt-out” of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the registration or user account in this application, or clicking on the automatic link appearing in each newsletter/message, or contact the Customer Service Representative of the Company by email to members@lubuds.com
3. Access
   • Any User is entitled to request access to or make amendments to his/her own personal information and data kept with the Company by contacting the Customer Service Representative of the Company by email to members@lubuds.com
     
     In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. 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 requests within 40 days of his/her request and will endeavor to do so wherever possible.
4. Cookies and Log Files
   • The Company does not collect any personally identifiable information from any Users whilst they visit and browse the Channels, save and except where such information of the Users is expressly requested. When Users access the Channels, the Company records their visits only and do not collect their personal information or data. The Channels’ server software will also record the domain name server address and track the pages the Users visit and store such information in “cookies”, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring. 
     
     The Company and third-party vendors engaged by the Company use the Company’s cookies and third-party cookies, such as the Google Analytics cookies, together to inform, optimize, and serve marketing materials based on the Users’ past visits to the Channels. Please visit http://networkadvertising.org/managing/opt_out.asp for details. 
     
     The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track Users’ movements and the number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns and administer the Channels. Such automatically collected information and data will not be disclosed save and except in accordance with the Paragraph 3 entitled “Disclosure or Transfer of Data”.
5. Google Analytics
   • Google Analytics Advertising Features (“Features”) are implemented on the Channels. The Features which the Company has implemented are based on Google Analytics Demographics and Interest Reporting. 
     
     Google Analytics is a web analysis service provided by Google which utilizes the data collected to track and examine the use of the Channels, to prepare reports on the Users’ activities and share them with other Google services. Google may use the data collected to contextualize and personalize the marketing materials of its own advertising network.
6. Links to Other Websites / Media Platforms / Applications

   The Channels may provide links to other websites / media platforms / applications which are not owned or controlled by the Company. Personal information and data from Users may be collected on these other websites / media platforms / applications when Users visit such websites / media platforms / applications and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Channels which grants Users access to another website / media platforms / applications, the protection of Users’ personal information and data which are deemed to be private and confidential may be exposed in these other websites / media platforms / applications.

    

   Non-registered Users who gain access to the Channels via their accounts in online social networking tools (including but not limited to Facebook or Apple) are deemed to have consented to the terms of this Privacy Policy, and such Users’ personal data which they have provided to those networking tools may be obtained by the Company and be used by the Company and its authorized persons in and outside of the User’s country for the purpose of providing services and marketing materials to the Users.

    

   If a User logins to any Channels with his/her Facebook account, the Company will collect and store the User’s personal profile and information, such as User’s name, profile picture, gender, friend list, which the User has chosen to make available to the Channels. If a User logins to any Channels with his/her Apple account, the Company will collect such User’s email address associated with his/her Apple account and store such email address in the system of the Company as an unique identifier which will be combined with other personal data of such User collected by the Company when he/she uses services provided by the Company. These Users are deemed to have consented to the Company and its authorized personnel’s access and use of their personal data so obtained for the purposes as stipulated under Clause 1 above and/or share their personal data pursuant to Clause 3 above, subject to the other provisions of the Privacy Policy.

    

   This Privacy Policy is only applicable to the Channels. Users are reminded that this Privacy Policy grants no protection to Users’ personal information and data that may be exposed on websites / media platforms / applications other than the Channels, and the Company is not responsible for the privacy practices of such other websites / media platforms / applications. Users are strongly recommended to refer to the privacy policy of such other websites / media platforms / applications. For the avoidance of doubt, the Company assumes no responsibility or liability for Users’ use of such other websites / media platforms / applications.

    

   If you want to do the account deletion of your personal data from our website and application, please contact us via email member@lubuds.com:

   [Your Name]

   [Address]

   [Email Address]

   [Phone Number]

   •  
7. Security
   • The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data will be protected against unauthorized access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data. 
     
     All personal information and data provided by Users are only accessible by the authorized personnel of the Company or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected. Registered Users should safeguard his/her unique Username and Password by keeping it secret and confidential and never share these details with anyone. 
     
     The Company uses third party payment gateway service providers to facilitate electronic transactions on the Channels. Regarding sensitive information provided by Users, such as credit card number for completing any electronic transactions, the web browser and third party payment gateway communicate such information using secure socket layer technology (SSL). 
     
     The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to protect Users’ personal information and data against unauthorized access, the Company cannot guarantee its absolute security.
8. Retention of Personal Data
   • Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company after deactivation of the relevant service until the User requests the Company in writing to erase his/her own personal information and/or data from the Company's database or to terminate his/her membership of the Channels.
9. Changes in this Privacy Policy
   • The Company reserves the right to update, revise, modify or amend this Privacy Policy in the following manner at any time as the Company deems necessary and Users are strongly recommended to review this Privacy Policy frequently. If the Company decides to update, revise, modify or amend this Privacy Policy, the Company will post those changes to this application and/or other places the Company deems appropriate so that Users would be aware of what information the Company collects, how the Company uses it, and under what circumstances, if any, the Company discloses it. 
     
     If the Company makes material changes to this Privacy Policy, the Company will notify Users on this application, by email, or by means of a notice on the home page of the Company.

For any query, please contact our Customer Service Representative:

LUBUDS® GROUP LIMITED
Email address： members@lubuds.com