Privacy Policy / Personal Information Collection Statement
1. Introduction
This Privacy Policy / Personal Information Collection Statement applies to your registration and use of the Pocari Sweat Club mobile application, member account, SWEAT Points, receipt upload, gift redemption, activities and related services. Otsuka Pharmaceutical (H.K.) Limited (the Company) is committed to protecting your personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance and applicable laws.
2. Personal Data Collected
The Company may collect and process the following categories of personal data:
· Identity and membership information, including name, title, birthday month, gender, membership number, account login information and verification information.
· Contact information, including phone number, email address, delivery or gift collection address and other contact methods.
· Transaction and point information, including receipt images, merchant name, transaction date, receipt number, product information, spending amount, payment summary information, mission records, point records and redemption records.
· Activity and customer service information, including activity registration, attendance records, enquiries, complaints, feedback, customer service communications and verification documents reasonably requested by the Company.
· Device, location, Cookie and usage information, including device model, operating system, application version, language setting, push notification permission, login records, click and browsing records, error records, IP address, approximate location data, Cookie, similar technologies and preference settings.
· Other information that you voluntarily provide or that is generated through your use of the application, participation in activities, completion of missions, redemption of Rewards or contact with the Company.
If you are under 18 years old, you must obtain consent from your parent or legal guardian before submitting any personal data to the Company.
3. Purposes of Collection and Use
The Company may use your personal data for the following purposes:
· Processing membership registration, login, identity verification, account management and security monitoring.
· Reviewing receipts, verifying Eligible Products, calculating, issuing, adjusting, clawing back and managing SWEAT Points.
· Processing Rewards, e-vouchers, activity quotas, delivery, collection, exchange, reissue and related customer service arrangements.
· Operating, maintaining, improving and personalizing the application, membership program, missions, activities, offers and customer experience.
· Sending notifications relating to accounts, Points, receipt review, redemption, activities, services, systems, security and administrative arrangements.
· Where you have consented or where permitted by law, providing information about related products, activities, offers, member benefits and promotions.
· Preventing, detecting and investigating fraud, abuse, violations, technical issues, security incidents or any improper use of the Program.
· Conducting data analysis, internal audits, reporting, research, system testing, record keeping and fulfilling legal, regulatory or compliance requirements.
4. Data Disclosure and Transfer
The Company may disclose or transfer your personal data to the following persons or organizations where necessary and within a reasonable scope:
· The Company's affiliates, agents, contractors, technology service providers, cloud service providers, push notification, SMS, email, customer service, data analytics and system maintenance service providers.
· Rewards, activity, delivery, logistics, warehousing, payment, merchant, brand partner, advertising companies, production companies, public relations companies, and event management and production companies, as well as other third parties that need to process data for the provision of member services.
· Professional advisers, auditors, insurers, legal advisers, law enforcement agencies, courts, regulators or other persons to whom disclosure is required by law.
· Entities or advisers involved in business restructuring, merger, transfer, acquisition or related due diligence.
If relevant service providers are located outside Hong Kong, your personal data may be transferred outside Hong Kong for the above purposes. The Company will take reasonable steps to require the relevant recipients to protect personal data properly.
5. Direct Marketing
The Company intends to use your name, contact information, membership information, point and redemption records, activity records, preferences and usage information to provide information about related products, member activities, benefits, offers, missions, lucky draws, e-vouchers, partner promotions and related information. The Company will only use your personal data for direct marketing where it has obtained your consent or where permitted by law.
You may at any time request the Company to stop using your personal data for direct marketing through the application settings, the unsubscribe method in promotional messages, or by emailing support@psclub.otsuka.com.hk.
6. Data Retention
· The Company will retain personal data according to the purposes of collection and legal, accounting, audit, risk management, dispute handling and operational needs. The retention period will not exceed the time necessary to fulfil the relevant purposes.
· After account deletion, membership termination or service completion, the Company may retain necessary records for a reasonable period to handle enquiries, disputes, audits, fraud prevention, legal claims or compliance requirements.
· Anonymized or aggregated data that no longer identifies individuals may be used for statistics, analysis, service improvement and reporting.
7. Data Security
The Company will take reasonably practicable technical and organizational measures to protect personal data against unauthorized or accidental access, processing, deletion, loss or use. However, the internet, mobile networks, third-party platforms and electronic communications are not absolutely secure. You should also keep your login information, verification codes and mobile devices secure.
8. Cookie, Analytics and Location Data
· The Company may use Cookie, SDKs, analytics tools or similar technologies to maintain login status, record preferences, analyze application usage, improve services, detect errors and protect account security.
· If the application provides location-related functions, location data will only be used where you have authorized it or where device settings allow it. You may manage the relevant permissions through your device or application settings.
· Disabling certain Cookie, analytics or location permissions may affect the normal use of some application functions, offers, activities or personalized content.
9. Access and Correction of Personal Data
Under the Personal Data (Privacy) Ordinance, you have the right to request access to and correction of your personal data held by the Company. The Company may charge a reasonable fee for handling data access requests as permitted by law.
To request access, correction, deletion, withdrawal of direct marketing consent or to make a privacy-related enquiry, please email support@psclub.otsuka.com.hk and provide sufficient information for the Company to verify your identity and process the request.
10. Third-Party Websites and Services
The application may contain links to third-party websites, platforms, payment, maps, social media, activity registration or other services. The privacy policies and practices of those third parties are not governed by this statement. You should read their terms and privacy policies before using the relevant services.
11. Updates to This Statement
The Company may update this Personal Information Collection Statement from time to time. The updated version will take effect immediately after being published in the application or relevant channels. Your continued use of Pocari Sweat Club indicates acceptance of the updated statement.