It should be noted that confidentiality of data exchanges is not guaranteed over the Internet and that every internet user is required to take all appropriate measures to protect their own data and/or software from contamination of any possible viruses circulating on the Internet.
This policy sets out the basis on which Milki Train Limited of Unit C, 8/F, King Palace Plaza, No.55 King Yip Street, Kwun Tong, Kowloon, Hong Kong (Company Number 2870876) (called "Milki Train" or “we”) collects personal data from you and how we process such data.
By visiting our website www.milkitrain.com (our “Site”), you accept and consent to the practices set out below.
1. Collection of information
1.1 For the purposes outlined in Clause 2, we may collect and process the following information about you:
(a) Information you give us - information that you provide us (which may include personal data consisting of your name, postal address, email address, telephone number, IP address and any other identifying information that enables you to be contacted online or offline, or any other information that can be attributed to you either directly or indirectly) by filling in forms on our Site, or by corresponding with us (by phone, email or otherwise), for example:
(i) when you report any problem to us
(ii) when you use certain features on our Site;
(iii) when you request any support from us; or
(iv) when you complete any survey or questionnaire we send you.
(b) Information we collect about you - information automatically collected when you visit our Site, for example:
(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(ii) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number; and
(c) Information we receive from third parties - We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
1.2 We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.
2. Uses made of the information
2.1 We use information held about you for the following purposes:
(a) Managing orders, product sales, and the provision of services; managing claims/complaints, cancellations and product returns;
(b) Processing transactions, particularly payments;
(c) Creating and managing customer accounts;
(d) Operating, evaluating and improving the products/services and the user experience (especially for the purposes of developing new products and services, analysing the customer database and carrying out data analysis, accounting and auditing), profiling;
(e) Analysing visits to the website and their frequency; audience measurement, market research, statistics, surveys (cookies) and improving the website's user experience;
(f) Sending newsletters and exclusive offers, on condition that the user ticks the checkbox designed to enable them to indicate their agreement to this when subscribing to the services
(g) in any part of the world;
(h) responding or taking part in legal proceedings, including seeking professional advice;
(i) for direct marketing purposes (please see further details in Clause 2.2 below);
(j) Interactions with customer services; and
(k) purposes directly related or incidental to the above.
2.2 We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:
(a) the personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 1.1 above;
(b) the type of services or products that may be offered or advertised will be our products;
(c) the relevant information may be sent to you by email;
(d) you may opt out any time by emailing us at: firstname.lastname@example.org. We will cease to send you marketing information.
3. Disclosure of your information
We will keep your personal data we hold confidential but you agree we may provide information to:
(a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the Law of Hong Kong;
(b) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);
(c) our affiliates, business partners and counterparts (on a need-to-know basis only);
(d) persons under a duty of confidentiality to us;
(e) persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
(f) actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.
4.3. We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
4.4. We use the following cookies:
(a) Strictly necessary cookies – These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies – These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies – These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.
4.5. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.
4.6. We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.
5. Third-party sites
5.1. By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
5.2. Our Site or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.
6.1. All information you provide to us is stored on our secure servers.
6.2. Any payment transactions will be encrypted using TLS/SSL technology.
6.3. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6.4. We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
6.5. We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
6.6. Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
7. Data transfer
7.1. The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons referred to in Clause 3 above who operate outside Hong Kong.
8. Your rights
8.1. You have the right to:
(a) check whether we hold personal data about you;
(b) access any personal data we hold about you; and
(c) require us to correct any inaccuracy or error in any personal data we hold about you.
9. How to limit the use and communication of your data?
We do not have any control over the collection or use of your data for targeted advertising purposes by third parties. However, these third parties may allow you to prevent your data being collected or used for such purposes. You can indicate your objection to receiving targeted advertising from companies that are members of the NAI (Network Advertising Initiative) at www.networkadvertising.ord/choices/.
We may amend this policy from time to time by posting the updated policy on our Site. In cases where major changes are made to the way your personal data is processed, we inform you that the notice has been updated by email. By continuing to use our Site after the changes come into effect means that you agree to be bound by the revised policy.
11. Contact us
If you have any questions, comments or requests regarding personal data, please address them to: email@example.com
Last updated: 2 April 2020