1 Personal Data (Privacy) Ordinance

1.1 Advanced Sleep Innovations (Hong Kong) Company Limited ("EMMAS Mattress ", "we", or “our Company”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data. This Privacy Policy Statement (“PPS”) aims to set out our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region. In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality.

1.2 Please read the following carefully to understand our policy and practices regarding how your personal data will be handled. This PPS applies to all users of EMMAS Mattress’s website (the “Website”), and may from time to time be revised, or otherwise changed where we deem necessary without prior notice.

1.3 If there is any inconsistency between the English and Chinese versions of this PPS, the English version shall prevail.

1.4 For the purpose of this PPS, "Personal Data" means any identifiable personal information or data, from which it is practicable for the identity of the individual to be ascertained.

2 Collection of Personal Data and its purposes

2.1 We collect your Personal Data when you fill in the “e-newsletter subscription” form or “Contact Us” enquiry form (collectively the “Forms”) on the Website.

2.2 If you are under the age of 13, you must get consent of your parent or guardian before providing us any Personal Data.

2.3 EMMAS Mattress collects the following types of Personal Data:

a. Information you provided in the Forms
EMMAS Mattress collects Personal Data you provide to us in the Forms, which may include your name, address, email and phone number or other contact details.
b. Information automatically gathered from your device
When you visit the Website, our server software records the IP addresses (and domain names) of your computer, the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites and pages visited, including visit time and duration (webserver access log) in order to measure traffic, popularity of various parts of the Website, and understand the general information of visitors. However, we do not use, and have no intention to use, the data to personally identify anyone.
c. Cookies and similar technologies
"Cookies" are pieces of information that are sent from webserver to user’s computer hard drive for record-keeping purposes. Cookies allow the website to remember important information that will facilitate your use of the site in a more convenient way. Like most of the websites, EMMAS Mattress uses cookies for a variety of purposes in order to improve your online experience by, for example, tracking the total number of visitors to the Website on an anonymous aggregate basis and associating your personal information with a cookie file when you re-visit the Website.

You can use the options in your web browser if you do not wish to receive a cookie or if you wish to receive notification from browser upon receipt of a cookie. Click on the "Help" button of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of the Website.

2.4 Your Personal Data provided will be used by EMMAS Mattress for the purposes for which it is collected and for other directly related purposes, including but not limited to:

a. obtaining your feedback and handling your enquiry on the Website, products and services;
b. inviting your participation in any of our events (if any) from time to time;
c. verification of identity and updating our records;
d. conducting surveys on user traffic;
e. subject to clause 2.5 below, for direct marketing purposes by providing you with news update on our products, services and promotional events or other marketing materials or information such as discount coupons ("Direct Marketing"); and
f. making disclosure to third parties:

(i) when required by law, by court order, or in response to a search warrant or other legally valid inquiry;
(ii) to an investigative body;
(iii) to enforce our agreements with you;
(iv) with your express consent; or
(v) pursuant to our good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defenses, to obtain legal advice, to exercise and defend our legal rights, to protect our rights or property and those of our subsidiaries or associated companies, or to protect the life, body or property of an individual.

2.5 By submission of your Personal Data for the purposes for which it is collected, it indicates that you have read and understood PPS and that you consent to our collection and use of your Personal Data in association with all purposes described in this PPS. However, we may not use your Personal Data, including your name and contact details, in Direct Marketing unless we have received your express consent. If you would like to receive news updates on our products, services and promotional events or other marketing materials or information about us, please fill in “E-newsletter Subscription” form.

2.6 It is entirely voluntary for you to provide Personal Data which is not marked as "mandatory" in the Forms.

2.7 After you subscribed to EMMAS Mattress’s e-newsletter, we will use your Personal Data for Direct Marketing purposes. We shall use your last name, first name and email address for marketing of the following services and products:

a. products and services of EMMAS Mattress;
b. commercial merchandises of EMMAS Mattress; or
c. news, rewards, promotions and events related to or offered by EMMAS Mattress and its subsidiaries, associates and/or affiliates.

3 Handling of Sensitive Personal Data
If we have to collect your sensitive Personal Data (for example, financial information) in order to provide services or products to you, we shall follow the terms contained in the PPS.

4 Retention, Storage and Disclosure of Personal Data

4.1 In cases where we do collect Personal Data from you, we will:

a. informs you (by way of this PPS or by a separate notification) that we are collecting your Personal Data and the purposes of collection;
b. where relevant, give you the opportunity to object to a particular use of your Personal Data; and
c. Informs you how we will store and handle your Personal Data and how you can review, change and delete the Personal Data we have stored.

4.2 We will take all reasonable and practicable steps to keep your Personal Data confidential, but we may transfer/assign or disclose such data to the following parties:

a. if EMMAS Mattress decides to sell any relevant part of the business, to any actual or proposed assignee, transferee or successor of EMMAS Mattress;
b. any agent, contractor or third-party service provider who provides administrative, telecommunications, computer and other services to EMMAS Mattress; and
c. any person whom EMMAS Mattress is under an obligation to make disclosure under the requirement of any law binding on EMMAS Mattress or under any guidelines or codes of practice issued by regulatory or other authorities with which EMMAS Mattress is expected to comply.

5 Access and Correction of Personal Data
If you wish to access or correct your Personal Data, you may send an email with your name, contact number, email address to info@emmas.com.hk. Our company will respond to your request and update the Personal Data in our record within 7 working days from the date of receipt of your request.

6 Cease to use the Personal Data for Direct Marketing
If you want to stop receiving any promotional material from our Company, irrespective of whether you have given us a consent (either written or oral) before, you may at any time contact us by sending an email to info@emmas.com.hk, indicating your request to cease the use of your Personal Data. Upon receipt of your request, our company will erase your Personal Data from our list within 7 working days and cease using it for Direct Marketing purposes.

7 Retention of Data
Your Personal Data will be retained for a period necessary to attain the data collection purpose. Different retention periods apply to the various kinds of Personal Data collected, and it is subject to any legal, statutory, regulatory or accounting requirements. Personal Data which is no longer required will be destroyed.

8 Links to Other Websites
We may offer links to other websites that are not operated by EMMAS Mattress. If you visit one of the linked sites, you should review their privacy and other policies. We shall not be liable and responsible for the policies and practices of other companies and any information you submit to those companies is subject to their privacy policies.

9 Outsourcing Arrangements
The Website is developed and maintained by our staff and a third-party service provider, and we may engage the third-party service provider to perform maintenance service under the supervision of our staff. The third-party service provider engaged by us is bound by contractual duty to keep confidential any data it comes into contact with against unauthorized access, use and retention.

10 Security
Except as mentioned in clause 3 above, your Personal Data, no matter how it is stored, will be accessed only by our employees or contractors who are authorized to do so. Where Personal Data is stored electronically, it will be kept on a secured server and will be password-protected (or under some equivalent forms of protection) and accessible only by authorized personnel of EMMAS Mattress or its contractors. Designated employees and contractors will be instructed to handle the Personal Data in accordance with the PPS. However, we cannot guarantee the security of information provided over the Internet.

11 Change to the PPS
The PPS is subject to change or modification at any time and without prior notice. Any changes or modifications will be posted on this page and will apply only to the Personal Data we collect after the posting.

This PPS was last revised in November 2020.