### 1. What Our Privacy Policy Covers
This Privacy Policy covers the Personal Data that Skin Stadium obtains about you in various contexts, both online and in-store, including when you visit, access and/or use our websites in both their web and mobile versions (such as “www.skinstadium.hk”), our “Skin Stadium” mobile application(s) (both iOS and Android versions), as well as any other web or mobile platforms owned, operated, or managed by Skin Stadium (such mobile application(s) may be collectively or individually referred to as the “App”, and such App together with the websites may be collectively or individually referred to as the “Site”). This applies when you visit us in our stores, use any of our services in our stores, communicate or interact with us, or participate in any of our promotions, programs, or events.
When we use the term “Personal Data,” we are referring to all data, whether true or not, about an individual who can be identified from that data or from that data and other information that an organization has or is likely to have access to, as well as any information for which the collection, disclosure, use, or processing is subject to data protection laws or regulations in any jurisdiction in which our stores and/or Sites are made available by us. Our Sites may include links to third-party websites and/or applications. Please note that we have no control over the processing of Personal Data by websites or applications not owned by Skin Stadium.
This Privacy Policy shall be governed in accordance with the laws of Hong Kong SAR.
This Privacy Policy complements and should be read together with the General Terms and Conditions of Sale and the Website Terms, as well as any documents or information notices referring to this Privacy Policy.
### 2. What We Collect
You have no obligation to provide any of the Personal Data requested by us. However, depending on circumstances, it may be the case that if you do not provide the requested Personal Data, we may not be able to transact with you or otherwise provide you with certain products and services.
The following are examples of the various ways in which we may interact with you, and some of the types of Personal Data that we will/may collect, use, disclose, and/or process in connection with that interaction. The column ‘Examples of Some of the Personal Data or Data Collected’ does not purport to exhaustively state the types of Personal Data that may be collected from you corresponding to the specified activity/interaction.
**Examples of Some of the Personal Data or Data Collected**
(a) **Account Registration**
When you create an account, we collect your name, phone number, email address, and date of birth. We may also collect your address if you choose to provide it.
You can choose to save certain information in your account to use for future purchases, such as your shipping addresses and payment information (“Card On File”). When you add a Card On File to your account, we collect your payment information details, billing address, phone number, and zip code.
(b) **Beauty Pass Programme**
When you join the Beauty Pass Programme, we collect your name, date of birth, phone number, email address, and mailing address. When you use your Beauty Pass Programme, we collect information about your purchase history.
(c) **Browsing Activity and Website Usage**
When you visit or use our Sites, we collect certain information about how you use and navigate our Sites, such as which links you click on, which pages or content you view, and other similar information or statistics. We also collect technical information about your device, operating systems, and web browser type.
(d) **Communications with Us**
When you communicate with us, including contacting us for support, providing feedback or comments, participating in a survey, or making a request or other inquiry, we collect your name and contact information (such as email address or phone number), as well as any other information that you choose to provide to us. In some cases, we record customer service calls for quality assurance.
(e) **Happening at Skin Stadium**
When you book a reservation for one of our services, classes, or when you RSVP for one of our events, we collect your name, contact number, email, and other information you provide in your booking or RSVP.
(f) **Use of Beauty Profile**
If you have created a Beauty Profile with us, we collect your name, skin type/concerns, eye color, hair color and type, and other information which you provide in order to build your Beauty Profile.
(g) **Posting in Public Forums and Spaces Within the Sites**
If you choose to submit or post information in a public space on our Sites or on our social media pages, such as creating a public profile, using our Ratings and Reviews feature to share product reviews, or leaving a testimonial about a Skin Stadium influencer, we collect the information you share.
(h) **Marketing Communications**
When you sign up to receive or otherwise consent to receiving marketing communications from us, such as email communications, mobile messages (including via text message and/or push notifications), and postal mailings, we collect your contact information. We may also collect certain information about how you interact with the marketing communications we send you.
(i) **Purchasing (Online and In Stores)**
When you place an order in our retail stores or by using the services offered on our Sites, we collect your name, shipping address, payment information, and billing address.
(j) **Sweepstakes, Contests, and Promotions**
When you participate in a sweepstake, contest, or other similar campaign or promotion, we may collect your name, contact information, and in some cases limited demographic information and content generated by participants. Some campaigns and promotions have a social networking component, and if you choose to submit additional information such as social media profiles and handles, photographs, and other content, we will collect such information as well.
In addition to the Personal Data we collect from you directly, we may also obtain information about you from other sources, including third-party business partners, our affiliates, or publicly available sources. For example, if you have given Skin Stadium permission to store your credit card information (e.g., by adding a Card On File) and your credit card issuer provides an account updater service, we may receive updated credit card information (including credit card number and expiration date) from the credit card issuer.
### 3. How We Collect, Use, Disclose Your Personal Data
We will/may collect, use, disclose, and/or process your Personal Data for one or more of the following purposes:
(a) Administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Sites. Without limiting the generality of the foregoing, if you:
(i) gain access to or sign in to the Sites using your login credentials of a Social Networking Site, or
(ii) use any features of a Social Networking Site such as its widgets, plug-ins, and browser push notifications made available to you on our Sites, it may result in information or your Personal Data being collected or shared between us and the third party operating the Social Networking Site. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook.
(b) Monitoring, processing and/or tracking your use of the Sites to provide you with a seamless experience, facilitate or administer your use of the Sites, and/or assist us in improving your experience in using the Sites.
(c) Assessing and processing your request for the purchase of and/or subscription to our products and/or services.
(d) Registering you as a customer of Skin Stadium and/or to deal with, process and/or administer the account that you may open with us, including to facilitate your transactions or activities on the Sites or your transactions or activities with us.
(e) Administering, facilitating, processing and/or dealing with your relationship with us, any transactions or activities carried out by you on the Sites, App, or at our retail stores. This includes processing your application, orders, and payment transactions; implementing transactions and the supply of products and/or services to you that you have requested.
(f) Carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your customer service enquiries and complaints; or responding to or dealing with your interactions with us.
(g) Contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Sites, your Beauty Pass membership and/or account with us, your relationship with us, or any transactions made by you with us.
(h) Providing services to you as our account holder, as our customer, as a member of our loyalty program(s), or when requested by you; dealing with or administering your participation in contests, gamification, and social events organized by us.
(i) Sharing or disclosing (at our discretion) your suggestions, comments, feedback, or content (including audio, video, etc.) (collectively “Feedback”) that you provide through Social Networking Sites, to the Sites, or to us (including in person at the retail stores), with other users of the Sites or with the public, for publicity and/or promotion purposes.
(j) Where you have provided your consent to us, whether such consent was obtained through the Sites, the retail store(s), or otherwise, sharing your Beauty Profile Personal Data with or disclosing your Beauty Profile Personal Data to other users of the Site or with/to the public.
(k) Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations applicable to us or our affiliates/associated companies.
(l) To prevent or investigate any fraud, unlawful activity or omission, or misconduct, whether or not there is any suspicion of the aforementioned; dealing with and/or investigating complaints.
(m) Complying with or as required by any applicable law, court order, order of a regulatory body, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies.
(n) Complying with or as required by any request or direction of any governmental authority which we are expected to comply with; or responding to requests for information from public agencies or similar authorities.
(o) Conducting research (including customer research), surveys, market surveys, analysis and/or development activities to improve our services and facilities.
(p) Storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, anywhere in the world.
(q) Facilitating, dealing with, and/or administering external or internal audits of the business of Skin Stadium or that of its affiliates/related corporations.
(r) For marketing purposes where you have provided your consent to us for the same.
(s) Dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves Skin Stadium as a participant or involves only a related corporation or affiliated company of Skin Stadium.
(t) To implement and maintain our information technology systems, including to store and process Personal Data in computer databases and servers located anywhere in the world.
(u) Anonymization of your Personal Data.
(v) Record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements.
(w) Skin Stadium’s reporting purposes including but not limited to reporting on our business performance.
(The purposes set out above shall be collectively referred to as the “Purposes”.)
### 4. How We Share Your Personal Data
Skin Stadium may share and disclose your Personal Data to third parties anywhere in the world from time to time for one or more of the Purposes described in this Privacy Policy.
Without limiting the generality of the foregoing, Skin Stadium may share or disclose your Personal Data to the following third parties or in the following circumstances for one or more of the Purposes or other purposes stated herein:
(a) **Corporate Affiliates.** We may share your Personal Data with our corporate affiliates, including our parent company, sister companies, and subsidiaries anywhere in the world.
(b) **Service Providers.** We may share your Personal Data with third parties that perform services to support our core business functions and internal operations.
(c) **Third Party Partners.** We may share your Personal Data with third parties that we have partnered with to jointly create and offer a product, service, or joint promotion.
(d) **Social Media Platform and Networks.** Some of our Sites have features such as plugins, widgets, or other tools made available by third parties.
(e) **Public Forums.** Some of our Sites provide the opportunity to post content in a public forum.
(f) **Legal Process.** We may disclose Personal Data as required by any applicable rules, law, or regulation.
(g) **Business Transfers.** We may share Personal Data with another company that buys some, or all, of the assets or stock of Skin Stadium.
For the avoidance of doubt, you acknowledge and consent to Skin Stadium sharing anonymized information such as but not limited to in the following circumstances:
– **Aggregate Information.** We may share anonymized aggregate information about our customers with advertisers and marketing partners.
– **Behavioural-based Advertising.** A third party may use technology to collect anonymized information about your use of the Site.
### 5. Mobile Technology
In addition to the above, we may use the following technologies to automatically collect information about your activities on the Sites.
**How They Operate**
– **Cookies:** Skin Stadium may deposit “cookies” in your computer or mobile device in order to identify you. Cookies are small data text files.
– **Flash Cookies:** These are data files similar to cookies, used to remember settings and preferences.
– **Web Beacons:** Small graphic images used for tracking performance.
– **Analytics Tags:** Used to analyze user behavior and effectiveness of features and advertising.
– **Web Server Logs:** Records of activity created by the device or computer that delivers the webpages you request.
– **Geo-Location Technologies:** Technologies that permit us to determine your Country/Region.