Privacy Policy

Sugi Bee Garden (HK) Co., Limited. (“Company”) shall handle personal data collected through its service in accordance with the terms and conditions stipulated in this document (“Privacy Policy”). Furthermore, all of the terms and conditions stipulated in this Privacy Policy shall be in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") of the laws of the Hong Kong Special Administrative Region (“Hong Kong”), and other personal data privacy protection-related laws and regulations. This Privacy Policy is incorporated into and forms part of the Terms of Service.

Unless this Agreement otherwise defines or redefines, expressions used herein shall have the same meanings as defined in the Terms of Service.

In this Privacy Policy, the term “Personal Data” means any data relating directly or indirectly to the customer of the Company (“Customer”), from which it is practicable for the identity of the Customer to be directly or indirectly ascertained.

By visiting any websites owned and/or operated by the Company and/or its Group Company or providing the Company with the Personal Data via other means (including via telephone enquiries, or via the application for or use of the Company’s membership services), the Customers confirm and agree that the Company will collect, use, store and disclose the Personal Data of the Customers in accordance with this Privacy Policy, as amended from time to time under Article 9 herein.

Article 1. Compliance with Applicable Laws and Regulations, and Guidelines

The Company shall collect, use, store and disclose Personal Data legitimately and appropriately, in compliance with the PDPO, other personal data privacy protection-related laws and regulations, guidelines established by any authority such as the Office of the Privacy Commissioner for Personal Data, and this Privacy Policy.

Article 2. Collection of Personal data

The Company shall collect personal data in a lawful and fair way for the purpose directly related to the function or activity of the Company. The Customer consents to provide its Personal Date to the Company in order to receive various features and services that the Company offers to the Customer.

Article 3. Purpose of Collection and Use

  1. The Company may use Personal Data collected from the Customer within the scope of any of the following purposes;
    • (1) for shipment of products and other relevant matters,
    • (2) for after service and support,
    • (3) for notifications for matters such as new products, services, exhibitions,
    • (4) for receiving inquiries from Customers and customer support,
    • (5) for invoices, refunds, payment, and other relevant matters concerning business affairs, or
    • (6) for improvement of customer support via telephone and prevention of problematic situations.
  2. The Company may not use the Personal Data collected for any other purposes than those listed in the preceding subsection, unless the Company is authorized or allowed by the respective owner of the Personal Data to do so, or unless there is any situation such a usage is regarded to be lawful.

Article 4. Entrustment of Personal Data

  1. As the Company shall conduct business smoothly in order to provide the Customer with quality service, the Company may, in certain situations, entrust Personal Data of the Customer to its Group Companies or any data processors appointed by them (“Entrusted Party(ies)”). However, the amount of Personal Data disclosed shall be limited to the minimum amount required so that the Entrusted Parties are able to conduct the necessary operations.
  2. The Personal Data of Customer will be stored and processed in Hong Kong and/or any other areas outside Hong Kong. Personal Data collected by the Company shall be stored in the Company’s web server, any web server in Japan or elsewhere borrowed from the Entrusted Parties.

Article 5. Personal Data Provided to Third Parties

Except as otherwise explained in advance, unless with permission under the laws or with the prior consent of the Customer, the Company shall not disclose the Personal Data of a Customer to any third party (exclusive of to Entrusted Parties as defined in Article 4 above).
When any of the following is applicable, the Customer consents to the Company to provide a third party with the Personal Data of the Customer;

  • (1) when it is required to disclose in accordance with the requests under any applicable law or order by the court or other governmental authorities;
  • (2) when using in accordance with terms stipulated in this Privacy Policy; or
  • (3) when using in other circumstances as permitted by laws.

Article 6. Management of Personal data

  1. Maintenance of Data Accuracy
  2. The Company shall maintain and update the Personal Data of the Customer to the extent that it is necessary for achieving the purposes of its use, and if all or any part of the Personal Data will become not necessary any more, the Company shall make appropriate measures to delete or remove the abovementioned Personal Data.

  3. Measures to Secure Management
  4. The Company shall adopt necessary and appropriate measures for the prevention of disclosure, loss, damage, leakage or any other security management issues of the Personal Data of the Customer.

  5. Supervision of Employees
  6. The Company shall inform its employees with respect to appropriate handling of Personal Data through providing appropriate training, and conduct the necessary and appropriate supervision over its employees.

  7. Supervision of Entrusted Parties
  8. The Company shall, in the event of sharing Personal Data of the Customer, select appropriate company within the Group Company which adopts appropriate measures for Personal Data security. The Company shall conduct the necessary and appropriate supervision over such companies.

Article 7. Requests Regarding Stored Personal Data

  1. In the event of a Customer or its legal representative requesting the information regarding the purpose of use of the Personal Data stored by the Company or any of the Group Companies (“Stored Personal Data”), the Company shall inform the Customer or its legal representative , without delay, of it, except for in any of the following situations;
    • (1) when the purpose of use of the Stored Personal Data requested by the Customer is explicit,
    • (2) when there is a risk of harm to the life, physical condition, property, and any other rights and interests of any of the Customers or any third party,
    • (3) when there is a risk of harm to the rights and legitimate interests of the Company, or
    • (4) when the Company is legally required to cooperate with a governmental organization or a local authority, and there is a risk of interference with the cooperation with the above-mentioned governmental organization or a local authority.
  2. In the event of a Customer or its legal representative requesting disclosure of the Stored Personal Data, the Company shall inform the Customer or its legal representative, without delay, of it, except for in any of the following situations;
    • (1) when there is a risk of harm to the life, physical condition, property, and any other rights and interests of any of the Customers or any third party,
    • (2) when there is a risk of considerable interference being caused to the business operations of the Company, or
    • (3) when there is a infringement of any intellectual property or any other proprietary rights of any party.
  3. In the event of a Customer or its legal representative requesting corrections, additions, or removal of the Stored Personal Data, the Company shall conduct the corrections, additions, or removal in accordance with such requests appropriately and without delay.
  4. In the event of a Customer or its legal representative requesting the suspension of use or removal of the Stored Personal Data, the Company shall conduct the suspension of use or removal in accordance with such requests appropriately provided that such requests are deemed to have a valid justification.
  5. In the event when a Customer makes a request under the Article 7.1, 7.2, 7.3, and 7.4 above, the Customer shall personally contact to the Personal Data Privacy Officer of the Company at the address, e-mail address, and phone number set out in Article 8 below.

Article 8. Inquiries Address and Customer Support Address

According to PDPO, the Company is required to respond to the request from Customer within 40 days, though the Company may charge the Customer a reasonable fee for doing so. The Company set the Personal Data Privacy Officer who shall receive the contact from the Customer for any request under this Privacy Policy.

Contact Information of Personal Data Privacy Officer:
Name: Chan Wai Huen
Address: Flat 06, 12/f, Workview Commercial Building, No. 21 Yiu Wa Street, Causeway Bay, Hong Kong
Phone number: 2778-9838
Email: sugibeegarden-hk@0038.co.jp

Article 9. Privacy Policy Revision

The Company will review this Privacy Policy regularly and reserves the right to modify this Privacy Policy at its sole discretion from time to time. In the event of such modification, the modified Privacy Policy shall come into effect at respective date of publication, and the Customers are agreeing to this Privacy Policy as revised, by continuing to use the services of the Company after any amendment to this Privacy Policy.

Revised on 1 November, 2017