Effective on July 17th, 2018
This policy sets out how Silverlit Toys Manufactory Limited (“Silverlit”, “we”, “our” or “us”) collects, uses, handles and stores personal data. Silverlit appreciates your interest in our products and your visit to our website. Silverlit respects the privacy rights of users to our websites and treats all the data held with the utmost care and security. To us it is important that you feel comfortable in visiting our websites, therefore any personal data you give us will remain completely confidential.
Please read this policy carefully before using our websites or our Apps list on Apple App Store® and Google Play™ Store. By accessing our websites or our Apps and any of its pages, you irrevocably and unconditionally accept and agree to the terms set out hereunder. By continuing to use our websites or our Apps following the posting of any changes to these terms will signify your consent to the changes made.
Purpose Of Collection Of Personal Data
You can use our websites or our Apps without having to provide any personal data. We only collect and use data that your Internet browser automatically transmits to us or through Google Analytics, such as:-
your location (country, city)
date and time of access
time and frequency of visits
your browser type
your service provider
your browser settings
your screen resolution
your operating system used including brands of mobile devices
no. of pageviews, unique page views and the last page you visited
your transferred data volume and the access status (file transferred or not found, etc.)
your IP address
We need this data in order to enable trouble free use of the sites and to ensure that the site is optimally displayed in your browser. We use the IP address only for the duration of your visit. The data is then stored in anonymous form for logging purposes.
The following personal data will be collected from you only if you request email updates of Silverlit promotions and new products, Silverlit promotional brochures or materials, when you desires to be registered as member of our websites, or when you would like to contact Silverlit.
Shipping Address (Optional unless a purchase order has been placed)
Billing Address (Optional unless a purchase order has been placed)
Number of Children (Optional)
If you give us personal data in order to receive information in return from us, for instance catalogues or general information regarding Silverlit products, we will collect and store that information in a database for marketing purposes with your prior consent. This information enables us to fulfill your information request. If you review or download information from our websites, we track the visit. That information is helpful, amongst other things, to provide you with tailored information and to give us information about which part of our websites is frequented. The stored information will be used to improve the utility of our websites and to differentiate between users and their individual personal data. The purposes for which your personal data are collected and used may also include (without limitation) one or more of the following purposes:
• for purposes relating to its daily operation of your membership account, administration of your membership accounts and records.
• for the supply and purchase of any services which Silverlit may offer to you, or you may require from us, from time to time;
• for use of the online services available at any of the websites of Silverlit and/or through other social media platforms; • for conducting research to improve your satisfaction of needs to our websites; • for designing unique services and products and customize pages of our websites for you; • for notifying you of all up-to-date news to our websites, for instance, promotions, special offers or new products; • for performing statistical analysis of your behavior and characteristics in order to measure interest in and use of the various areas of our websites and usage pattern of our websites;
• for preparing aggregate information on the number of visitors to our websites;
• for communicating with you by the available means regarding your enquiries;
for complying with any statutory or regulatory requirements; and
• for any other incidental or associated purposes relating to the above, or any other purposes as specified in a personal information collection statement when your personal data is being collected, or any other purposes which you may from time to time agree.
Please rest assured that we do not sell or provide the personal information collected from you, to any third parties, except those expressly stated in this policy.
With Whom Does Silverlit Share Your Personal Data? Silverlit may share your personal data within Silverlit and its affiliated companies, and third party agent and service providers which use such data to provide technical or customer support. The agents and providers have been carefully chosen and commissioned in writing. The agents and providers are bound by our instructions and are regularly monitored by us. We undertake that these entities will not use your personal data for any other purpose and have agreed to maintain the confidentiality, security and integrity of the personal data they have obtained from Silverlit. Silverlit will not disclose your personal data to any governmental agencies and regulatory authorities, except at such time that Silverlit, in its good faith belief, feel that Silverlit are required to disclose such data by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose you or Silverlit to legal liability.
Personal data collected by Silverlit may be shared with its affiliates and subsidiaries and may be stored and processed in the U.S., Hong Kong or any other country in which Silverlit or its affiliates or subsidiaries or agents maintain facilities, and by providing us with your personal data and using our websites or services, you consent to any such transfer of information outside of your country. Your personal data may be transferred outside of your local jurisdiction for the above reasons. Subject to applicable privacy law, we will take steps to ensure that the standard of protection accorded to your personal data transferred is comparable to the protection under the applicable privacy law in your local jurisdiction.
Communications With Our Websites Or Our Apps If you choose to provide Silverlit with your personal data, for instance, name, address and e-mail address through our websites or some of our Apps for the purpose of receiving information from Silverlit, please be advised that Silverlit will store the personal data in a database and may pass the personal data on to its affiliated companies. You are prohibited from posting or transmitting any commercial, unlawful, threatening, libelous, defamatory, obscene, inflammatory, pornographic, or profane material or any material that could constitute or encourage conduct that would be considered a criminal offense, or otherwise violate any law. Silverlit will fully cooperate with any law enforcement authorities or court order requesting or directing Silverlit to disclose the identity of or help identify or locate anyone posting any such information or materials.
Confidentiality Personal data held by Silverlit relating to users to our websites or our Apps will be kept confidential. Any questions, unsolicited comments, suggestions, ideas, submissions or information other than personal data sent or posted to our websites or our Apps, or any part of the website or the Apps by users will be considered voluntarily provided to Silverlit on a non-confidential and non-proprietary basis. Silverlit reserves the rights to use, reproduce, disclose, publish, and/or distribute such data freely and you also agree to that Silverlit is free to use such data that you send us for any purpose.
To ensure the proper use and to maintain the accuracy of the personal data collected from you, as well as preventing unauthorized or accidental access, processing, destruction, intentional manipulation or other use of the personal data, we have implemented different technical and organizational security measures and taken all practicable steps to safeguard and secure the personal data we collect. Our websites have firewalls in place, which should protect the personal data collected from you against accidental or unauthorized access. When using our website, your personal data is encrypted using SSL technology to prevent access by unauthorized third parties. Our security measures are being continuously improved in line with technological developments. Nevertheless, complete confidentiality and security is not yet possible over the internet, and privacy cannot be assured in your communications to us. You are recommended to prevent against unauthorized access to your password. Ensure you log out from your account when finished particularly when using a shared computer.
Retention Of Personal Data
Your personal data will not be retained longer than necessary for fulfilling any permissible legal, statutory and regulatory requirements. Your personal data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfill the purposes mentioned above after which it will be destroyed.
We use third party website analytic services, including Google Analytics, to gather information about how you and others use our websites, and to facilitate website users use of the website. For example, we will know how many users access a specific page and which links they clicked on. We may use this aggregated information to understand and optimize how our websites are used and the information regarding your activity on the website to assess your content and other needs so that we may offer content and/or services to meet such needs. To find out more about Google Analytics please visit: support.google.com/analytics/answer/6004245. You can prevent the collection of data generated by cookies by downloading and installing the browser plug-in that is available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
If you interact with us on social media platforms, for instance if you post on our timeline or “Like’ our Facebook Page, we can exchange with you and send you messages via these platforms. We will exchange with you in accordance with the social media platform’s rules but we are not responsible for how the platform controllers collect and handle your personal data. We are not responsible for what third parties post on our social media accounts. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation
Collection And Use Of Children’s Personal Information Children under the age of 13 should never provide personal data on the Internet without first discussing our websites or our Apps with their parents. Silverlit realizes that some young children may not able to understand some of the information contained in our websites or our Apps. Parents of children under the age of 13 are advised to discuss this policy with your children so that they can have better understanding about the use of our websites or any Apps we listed on Apple App Store® or Google Play™ Store and information they may be asked to provide. Silverlit asks all members who wish to provide data to Silverlit for their birthdates. If a member indicates that they are less than 13 years of age, parental consent is needed before they can provide Silverlit with personally identifiable information. Silverlit may collect and store personal data about children under 13 if it is submitted in connection with the parent’s verifiable consent. Silverlit will only collect such data if it is voluntarily submitted and to the extent that data is reasonably necessary to participate in our websites.
Changes This Policy may be amended from time to time. Silverlit reserves the right to delete, suspend or edit all information on our websites at any time without advance notice at its absolute discretion. You are advised to check our websites regularly for any revisions and/or amendments which may be made so that you are always informed of the way we collect and use personal data. Users are responsible for making their own assessments of all information contained in or in connection with our websites.
Applicable Law We are committed to safeguarding the privacy of individuals with respect to personal data . Silverlit shall at its best endeavors to maintain our policies and practices in relation to the collection, use, retention, transfer and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486) under the laws of the Hong Kong Special Administrative Region and all applicable laws of any other jurisdiction.
Withdrawal Of Consent And Data Access And/Or Correction Right
If you have provided Silverlit with your personal data by registering as member of any of our websites or by any other means and do not want Silverlit to retain this information anymore, you may at any time request for update, review, restrict, object, transfer and discontinue further collection and access to personal data by addressing your request to:
Silverlit Toys Manufactory Ltd. Room 1701-03, 17th Floor World Trade Centre 280 Gloucester Road Causeway Bay, Hong Kong Email : firstname.lastname@example.org Tel : (852) 2834 4168 Fax : (852) 2834 8797
This policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.