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Privacy Policy
1. What is the scope of this Privacy Policy?
In this policy, you will find all relevant information relating to our use of “customer/consumer” personal data. This Privacy Policy applies to Generwork customers, including current, former, and potential customers, as well as recipients of the products or services we offer, and visitors to our website generwork.com.
2. What is Personal Data?
Personal data is any information that can be directly or indirectly attributed to you. Examples of personal data include name, address, email address, phone number, payment information, and purchase orders. Usage history, IP address, member ID, and other types of information you provide when contacting our customer service or ordering products from our website generwork.com are also considered personal data.
3. Who is responsible for processing your personal data?
The data controller is:
Generwork (“we,” “Generwork,” or the “Controller”) is the data controller. This means that we are responsible for processing and protecting your personal data.
Email: mirai@generwork.com
4. When can we process your personal data?
We may not collect, process, use, or store personal data without valid legal grounds.
Legality can be based on the following:
4.1. Consent: With your consent, we will process your personal data for the specific purposes you consent to. For example, when you request us to send you newsletters containing offers and style updates, or when you purchase goods on our website, we will send you notifications about your order status.
4.2. Contracts: In providing you with products and services, we will process personal data necessary for contracts entered into with you (such as purchase agreements) and for fulfilling any obligations arising from those contracts.
4.3. Legal Interests: We may process your personal data as necessary to comply with our legal interests, and these interests shall not supersede your own. This includes processing for purposes such as customer service support, improving or developing our products and services; and processing for security purposes, including fraud prevention.
4.4. Legal Requirements: Whenever we need to process your personal data to fulfill our legal obligations in operating in Hong Kong, we will inform you of the applicable legal grounds for each specific purpose of processing your personal data.
5. How and why do we process your personal data?
5.1. Online Shopping
To be able to process your purchase orders and payment transactions
To be able to manage your deliveries, claims, warranty matters, returns, and refunds securely and efficiently, and to be able to notify you of the details and status of such matters.
To be able to provide and follow up on requested services (including discount codes) on the website or application, and to identify and contact you when necessary.
In these cases, we only process contact information (such as phone number, email address, shipping address), member ID (where applicable), and transaction data and payment method information.
Legal Basis: When providing you with products and services, we will process your personal data to fulfill the contracts we have entered into with you and to perform any obligations arising from those contracts, whether those contracts relate to purchase orders and payments or the use of other services provided by us or third parties. When you need to return goods or assert consumer rights, we will process your personal data to fulfill the obligations arising from contracts we have entered into with us, whether those contracts relate to purchase transactions or the use of other services provided by us or third parties. For any other purposes mentioned herein, our processing of your personal data is based on our legitimate interests as a business.
We will not retain and process your personal data for longer than necessary to fulfill our contractual and consumer obligations.
5.2. Security Safeguards
To protect our customers, users, visitors, assets, and business from violence, fraud, theft, abuse, and other malicious activities.
In these cases, we will only process your order history, payment data, and shopping activity.
Legal Basis: Unless there is a specific legal obligation, processing your personal data for security purposes is based on our legitimate interests.
We will not retain your personal data beyond what is necessary for each purpose.
5.3. Compliance with Law
To comply with certain legal obligations. We are obligated to process certain personal data in order to comply with local laws. These obligations may vary by country, for example, in relation to tax, accounting, bookkeeping, sanctions, and consumer regulations. The types of personal data we process are dictated by applicable law.
Legal Basis: Processing your personal data is necessary for Generwork to fulfill its legal obligations regarding its operations in Hong Kong.
Data retention periods will vary depending on the purpose, context, and specific local legal requirements.
5.4. Content You Share
We can provide you with customer engagement marketing services.
You can share your photos and/or videos on our official website, social media pages, and other promotional channels.
In these cases, we only process photos, videos, usernames, and credit/debit card information.
Legal Basis: The processing of your personal data is based on the service agreement you agree to.
6. Where and with whom do we share your personal data?
Your personal data is only available to those who need to achieve the intended processing purpose. We may share your personal data with Generwork internally, subcontractors, partners, and other third parties as necessary to achieve the intended processing purpose.
If we merge with or are acquired by a third party, undergo restructuring, or propose any other business transaction, we reserve the right to transfer any personal data we own about you.
7. How long will we retain your personal data?
The length of time we retain your data depends on the purpose for which we process the data, as described below:
7.1. Managing your platform user registration. We will process your data as long as you are a registered user (i.e., until you decide to delete your account).
7.2. Formulation, performance, and execution of purchase or service contracts. We will process your data for as long as necessary to administer the products or services you purchase, including potential returns, complaints, or claims related to the purchase of the relevant products or services. Sometimes, we will only process your data before you make a decision, such as when you request that we store payment data for future purchases (where this feature is available).
7.3. Customer support. We will process your data for as long as necessary to fulfill your requests or applications.
7.4. Marketing. We will continue to process your data until you unsubscribe from or cancel your newsletter subscription. Similarly, we will show you personalized ads until you change your device, browser, and/or cookie settings, thereby revoking such permission. If you participate in a promotional campaign, we will retain your data for six (6) months after the campaign ends.
7.5. Availability and quality analysis. We will process your data periodically during specific quality actions or investigations, or until we anonymize your browsing data. While we will process your data within the strict timeframes required to achieve the intended purpose, we will subsequently store and protect this data properly in accordance with applicable laws from time to time to prevent liability arising during processing. Once the statute of limitations for each potential action has expired, we will delete the personal data.
8. What are your rights?
Data protection is a fundamental right, and you have several rights under applicable data protection regulations. These rights include:
8.1. Right of Access: You have the right to request access to your personal data information held by us at any time.
8.2. Right of Portability: When we process your personal data automatically based on your consent or contract, you have the right to request a copy of the data to yourself or other parties. This only includes personal data that you have submitted to us.
8.3. Right of Correction: If your personal information is incorrect, you have the right to request correction, including supplementation of incomplete personal information.
8.4. Right of Erasure: You have the right to erase any personal data we process at any time, except in the following circumstances:
• You have a dispute with customer service;
• You have an outstanding order;
• You have an outstanding balance with us;
• If you have made any purchases, we will retain personal data related to your transactions for accounting purposes.
8.5. Right of Restriction: You have the right to request that we restrict the processing of your personal data in the following circumstances:
• If you object to processing based on our legitimate interests, we will restrict all processing of such data until those interests are verified.
• If you claim your personal data is incorrect, we must restrict all processing of such data until its accuracy is verified.
• If processing is illegal, you can object to the deletion of your personal data and instead request restrictions on its use.
• If we no longer need your personal data, but you require it to protect your legitimate interests, you have the right to withdraw your consent; you have the right to withdraw your consent at any time for each purpose for which you have consented to processing.
• If you choose to do so, we will cease processing your personal data for that specific purpose. However, if you continue to receive marketing messages from us in your social media feeds or web browser, this is entirely a matter between you and your platform provider.
You can withdraw your consent or object to further marketing communications by:
• Following the instructions in each marketing post;
• By editing your account settings;
• Configuring privacy settings on your social media account or browser;
• Contacting customer support;
• Disabling your account on Generwork.
8.6. Right to Object to Processing Based on Our Legitimate Interests
You have the right to object to our processing of your personal data based on our legitimate interests. We will not continue processing your personal data unless we can demonstrate a legitimate reason superseding your interests and rights, or a legitimate claim.
9. How to Exercise Your Rights?
If you have an account on Generwork, or if you provided us with personal information when purchasing goods, you can exercise your rights to access, transfer, and correct your data on your account page. You can also delete your account on these pages or contact us to request the removal of your personal information from our global database. If you have any questions about our privacy policy or the processing of your data, please contact us at mirai@generwork.com.
10. Changes to the Privacy Policy
We may modify the information contained in this policy when we deem it appropriate. If we make changes, we will notify you through various means on the platform (e.g., via banners, pop-ups, or push notifications), or, when the changes relate to your privacy, we may even send a notification to your email address so that you can view, evaluate, and, if appropriate, object to or unsubscribe from any service or feature. Regardless, we encourage you to review this policy periodically for updates on minor changes or any interactive improvements we make, so you can always find it as a permanent information point on our website.
11. Information about Cookies
We use cookies and similar devices to facilitate your browsing on our platform, understand how you interact with us, and, in some cases, show you advertisements based on your browsing habits.
11.1 We use four types of cookies: Essential, Performance, Functional, and Marketing. Only the last three types of cookies require user consent. Essential cookies do not require user consent because they allow for the complete and persistent display of website content so you can access the website and receive an appropriate digital browsing and online experience.
11.2 If you do not wish to use cookies on your device, you can manage your cookie preferences by selecting the appropriate options in the Cookie Category list in "Cookie Settings." Please note that these changes/selections may affect the functionality of the website and may prevent you from receiving personalized offers or advertisements.
In addition to withdrawing your consent, you can easily prevent your browser from accepting cookies by configuring your browser's cookie settings. All commercial web browsers have cookie management capabilities. Please check your web browser to learn how to delete or disable cookies, etc.
11.3 If you select "Accept All Cookies," you agree to all cookie categories and consent to us sharing this information with third parties (such as our advertising partners). If you select "Required Cookies Only," no cookies other than those categorized as "Absolutely Essential" will be placed on your device. You can withdraw your consent at any time and disable cookies that are not absolutely essential for the website to function.
12. Contact Us
For more information about our privacy practices, if you have any questions, or if you wish to file a complaint, please contact us at mirai@generwork.com.
