Privacy Policy
Introduction
Purpose of this Privacy Policy
MyEcoCup (referred to in this Privacy Policy as “MyEcoCup”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you how we protect your personal data when you visit MyEcoCup.com (“Website”), regardless of where you visit from, and tell you about your privacy rights and how the law protects you.
This Privacy Policy is designed to provide you with information about 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 for our newsletter, purchase any products or services and/or enter a competition.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide when we collect or process your personal data so that you are fully aware of how and why we use your data. This Privacy Policy supplements other notices and privacy policies and is not intended to replace them.
Data Controller
MyEcoCup is the “Data Controller” of your personal data.
In short, this means that we (i) “control” your personal data, including keeping it secure; and (ii) make certain decisions about how your personal data is used and protected, but only to the extent we have informed you of the use or as otherwise permitted by law.
Contact Information and Complaints
If you have any questions about this Privacy Policy or any concerns about our use of your personal data, please contact our Data Privacy Manager via the Contact Us page.
If you currently reside in the European Economic Area, you have the right to complain to the data protection supervisory authority in your country at any time. For an up-to-date list of national data protection authorities, please visit the European Data Protection Board website at https://edpb.europa.eu/about-edpb/board/members_en.
However, before you contact the supervisory authority in your country, we would like the opportunity to address your concerns, so please contact us first.
Changes to this Privacy Policy and Personal Data
This Privacy Policy is reviewed regularly and was last updated on March 1, 2020. We may amend or update our Privacy Policy from time to time. To do so, we will provide you with notice of revisions to this Privacy Policy and update the “Last Updated” date above.
It is important that the personal information we hold about you is accurate and up to date. Please let us know if your personal information changes during your relationship with us.
Third Party Links
This website may contain 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 your data. 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.
Data We Collect About You
The types of personal information we collect, use and store about you depend on the services you request from us and/or the nature of your interaction with us. When you use our website, we collect and process the following types of personal information:-
Your first name, last name, username or similar identifier, date of birth and gender (“Identity Data”);
Your billing address, delivery address, email address and telephone number (“Contact Information”);
Your bank account and payment card details (“Financial Data”);
Details about payments you make to and from us and other details about products and services you purchase 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 this website (“Technical Data”);
Your username and password, purchases or orders you make, your interests, preferences, feedback and survey responses (“Personal Data”);
Information about how you use our website and services (“Usage Data”); and
Your preferences in receiving marketing from us and third parties and your communication preferences (“Marketing and Communications Data”).
We do not collect any Special Categories of Personal Data about you (this includes information 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). We also do not collect any information about criminal convictions and offences.
How we collect your data
Direct interactions
We collect Identity Data, Contact Data and Financial Data that you provide when you fill in forms or when you correspond with us by post, phone, email or otherwise. This includes personal data you provide when you:
Apply for our products or services;
Register on our website;
Subscribe to our newsletter;
Request to send you other marketing materials;
Enter a competition, promotion or survey; or
Provide us with feedback or contact us in any manner or form.
Automated technologies and interactions
When you interact with our website, we 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 that is sent to your computer when you visit a website and then stored by your computer. Whenever you visit the same website again, the information stored in the cookie can be retrieved to inform the website of your previous activity. We use cookies to facilitate website navigation, maintain the quality of our online services, provide additional security, allow you to customize your visit to the website and remember you when you return to the website.
Cookies do not give us access to your computer or information you have not given us, and we do not store personally identifiable information such as your name or address in the cookies we create, but we do use the encrypted information we collect from them to help improve your experience on our website. If you do not want to enable cookies, you can still browse the website and use it for research purposes.
You can set your browser to refuse all or some browser cookies, or to alert you when a website sets or accesses a cookie. If you disable or refuse cookies, please note that some parts of this website may be inaccessible or not function properly.
When you visit our website, you may notice some cookies that are not related to Francfranc. If you visit other websites that have embedded content, you may receive cookies from those websites. We do not control the setting of these cookies, so we recommend that 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.
Third Parties
We also work closely with third parties, such as analytics providers.
We will obtain personal information about you from the following third parties:-
Technical Data from analytics and search information providers (such as Google) based in and outside the EEA;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services (such as Visa, Mastercard, American Express, Alipay or WeChat Pay) based in and outside the EEA; and
Identity and Contact Data from publicly available sources, such as the Hong Kong Companies Registry based outside the EEA.
How we use your personal information
We are committed to only using your personal data where the law allows us to do so. 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 those interests are not overridden by your interests and fundamental rights (“Legitimate Interests”).
Where we need to comply with a legal obligation (“Legal Obligation”).
We intend to use your personal data for the following purposes and on the corresponding legal bases:
Purpose
Type of Data
Lawful Basis and Legitimate Interest Basis
Register as a new customer
Identity Data;
Contact Data.
Performance of a contract
Processing and delivering your order
Identity Data;
Contact Data;
Financial Data;
Transaction Data;
Marketing and Communications Data.
Performance of a contract;
Legitimate interest (to recover debts owed to us).
Manage our relationship with you
(i.e. notifications about changes to the Privacy Policy and asking you to leave a review or take part in a survey)
Identity Data;
Contact Data;
Personal Data;
Marketing and Communications Data.
Performance of a contract;
Legitimate interest (to keep your records updated and study how customers use our products/services).
Enable you to enter prize draws, competitions or complete surveys
Identity Data;
Contact Data;
Personal Data;
Usage Data;
Marketing and Communications Data.
Performance of a contract;
Legitimate interest (to study how customers use our products/services and to grow our business).
Administration and protection of our website
(including troubleshooting, data analysis, testing, system maintenance, support reporting and data hosting)
Identity Data;
Contact Data;
Technical Data;
Legitimate Interests (for operating our business, providing administration and IT services, network security, fraud prevention and in the context of a business reorganisation or group restructuring exercise);
Legal Obligations
To provide you with relevant website content and advertisements and to understand the effectiveness of the advertising we serve to you
Identity Data;
Contact Data;
Personal Data;
Usage Data;
Marketing and Communications Data;
Technical Data.
Legitimate Interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
Use data analytics to improve our website, products/services, marketing, customer relationships and experience
Usage Data;
Technical Data.
Legitimate Interests (to identify types of customers for our products and services, to keep our website updated and relevant, to grow our business and to inform our marketing strategy).
Suggestions and recommendations about goods or services that may be of interest to you
Identity Data;
Contact Data;
Personal Data;
Usage Data;
Marketing and Communications Data.
Legitimate Interest (to develop our products/services and grow our business).
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the processing for a new purpose is compatible with the original purpose, please feel free to contact us.
Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where this is required or permitted by law.
Marketing and Promotional Offers
We strive to provide you with choices about certain uses of your personal data, particularly in relation to marketing and advertising.
We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to understand what you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you.
If you request information from us or purchase products or services, or provide us with your details when entering a competition or registering for a promotion, you will receive marketing emails and newsletters from us and in each case you have expressly consented to receive such marketing emails and newsletters.
We will ask for your explicit consent before we share your personal data with any third party for marketing purposes.
Opt-out
You can ask us or third parties to stop sending you marketing messages at any time by:-
Adjusting your marketing preferences by logging into the website and ticking or unticking the relevant box;
By clicking on the unsubscribe link in any marketing message sent to you; or
Please contact us at any time via our Contact Us page.
If 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 purchase of a product or service, product or service experience, or other transaction (which we will continue to process to fulfill our contract with you or to meet our regulatory or legal obligations).
International transfers
We will share your personal data within our Hong Kong company, but we may transfer your data to other jurisdictions.
Please understand that we generally ensure a similar level of protection for your personal data as in the European Economic Area (EEA) by ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal data. For more information, see European Commission: Adequacy of the protection of personal data in non-EU countries.
We may use specific contracts or contractual clauses approved by the European Commission that provide the same protection to personal data as it has in Europe. For more information, see European Commission: Model contracts for the transfer of personal data to third countries.
When we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield. The Privacy Shield requires them to provide similar protection to personal data shared between the Europe and the United States. For more details, see European Commission: EU-US Privacy Shield.
If you would like more information on the specific mechanism we use when transferring your personal data, please feel free to contact us.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the satisfaction of any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for longer if there is a complaint or we have reason to believe there is a potential for litigation in relation 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, unauthorised use or disclosure of your personal data