Privacy Policy
This Privacy Policy explains what personal information we hold about you, how we collect it, and how we use and may share information about you. It relates to any personal information we receive from via:
our Website: lybymangiare.com that links to this Privacy Policy
our Social Pages: social media pages and accounts for “Ulivo”
our Services: our subscription services and any other Ulivo services that link to this Privacy Policy.
our Contact channels: where you provide or submit your personal information to us by email, phone, SMS, on social media (for example in response to a competition or promotion), in letters and in person.
our relationships with business partners, licensees and suppliers (where you are their staff member, officer or agent).
It also relates to any personal information you provide or submit to us by email, phone, SMS, on social media (for example in response to a competition or promotion), in Messenger and other chat bots, in letters and in person.
WHO WE ARE
When you visit our Websites, use our Services, interact with us (including via our Social Pages) or your personal information is otherwise submitted to us, Ulivo (‘us’ and ‘we’) is a ‘data controller’ and gathers and uses certain information about you. When we do so we are regulated under the Personal Data (Privacy) Ordinance which applies in Hong Kong.
HOW WE COLLECT INFORMATION FROM YOU
The types of information we collect about you depends on how you interact with us. There are three ways in which we may collect your personal information:
directly from you;
from other sources; and
automatically.
For more details about the types of information we receive from these and other sources, including where it is held and where it came from, see the table under the section ‘More about the information we collect and hold’ at the bottom of this policy.
INFORMATION WE RECEIVE DIRECTLY FROM YOU
Whenever you interact with us directly, we receive information from you, for example when you:
correspond with us, for example by using the contact forms on our Websites, by using Facebook Messenger, or by emailing us
sign-up for an account with ulivohk.com
sign up to receive any of our marketing or newsletters
enter any competitions or prize draws we run
comment on content on the Website
submit content to us, for example if you post a selfie and use one of our hashtags on your public social media account in response to one of our competitions or tag us in a tweet or other social media posts
INFORMATION RECEIVED FROM OTHER SOURCES
Sometimes we also obtain information about you from other sources, for example when you:
use any of our Services or Website Functions which enable you to sign-in via a third party service, for example if you log-in to your ulivohk,com account with Facebook – we receive some of your account information
complete one of our surveys – we receive your answers and any personal information you provide within your answers from Survey Monkey
are a staff member, officer or agent of a company that is our potential, current or recent business partner, licensee or supplier
have personal information about you which is publicly accessible such as on Companies Registry or another government website.
INFORMATION WE COLLECT AUTOMATICALLY
When you access and browse any of our Websites or use our Services, we collect information about your usage and activity on our Websites or Services using certain technologies, such as cookies and web beacons.
Depending on the cookie settings in your browser and the cookie preferences you set when you first access our Websites or Services, our third-party service providers, advertisers, and/or partners may also place, view, edit, or set their own cookies. If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.
HOW WE USE YOUR PERSONAL INFORMATION
We explain the ways in which we plan to use your personal information and the legal basis on which we rely for each use in the table below and in our Cookie Policy.
Generally, the reasons we use your personal information can be categorised as follows:
to personalise our Services to you
to enable you to partake in our prize draws or competitions
to maintain and improve our Services and our Websites’ infrastructure
to sell advertising space on the Websites – this allows us to provide certain sections of our Websites (and our delicious recipes!) to you for free
if you have opted-in to this, or where otherwise allowed by law, to market our products and services to you
to manage relationships and contracts with our potential, current or recent business partners, licensees and suppliers, where you are their staff member, officer or agent.
Where we propose to use your personal information for any other uses we will ensure that we notify you first (and if required, obtain your consent).
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
With Third-Party Partners
We work with third parties who may need to have access to your personal information to provide us with services or to help us to provide and improve our Services and Websites. In the table under the section ‘More about the information we collect and hold’ at the bottom of this policy and the paragraphs below we name (or where this is not possible, names the categories) third parties with whom the information we collect and hold about you may be shared.
Advertisers
We work with third-party advertising companies to serve ads while you are visiting our Websites. If you opt-in to our Advertising Cookies, we permit these companies to place and access their own cookies on your computer in the course of serving advertisements on our Websites. The information these companies may obtain through their cookies does not include your name, address, e-mail address or telephone number. Please refer to our Cookie Policy for further information about Advertising Cookies.
Vendors and service providers
We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, security, communication (e.g. email, file sharing), analysing how our Websites and services are used, providing customer service, facilitating payments, conducting surveys, or providing fraud detection service.
We may also need to share personal information with other parties, such as external contractors and our professional advisers and potential purchasers of some or all of our business or on a re-structuring. Usually, information will be anonymised but this may not always be possible. We may also be required to share some personal information as required to comply with the law.
Government and law enforcement bodies
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding suspected or confirmed illegal activities, violation of our intellectual property rights, violation of our Terms and Conditions or other agreements, or as required by law or by a government or law enforcement body.
HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will keep your personal information while we are providing any Services to you (including any marketing or newsletter services) or whilst we have a business relationship with our business partner, licensee or supplier of which you are a staff member, officer, or agent. Thereafter, we will keep your personal information for as long as is necessary:
to respond to any questions, complaints or claims made by you or on your behalf
to show that we treated you fairly
to keep records required by law
to establish, exercise or defend legal claims.
We will not retain your personal information for longer than necessary for the purposes set out in this policy and when it is no longer necessary to retain your personal information, we will delete or anonymise it. Different retention periods apply for different types of personal information. If you require further details, please see below ‘How to contact us’.
REASONS WE CAN USE YOUR PERSONAL INFORMATION
This section addresses the legal basis for processing your personal data. The legal bases on which we rely in each instance where we collect and use your personal data, generally, are:
as necessary to fulfil and enforce our Terms of Use and any other contract we have with you (such as if you supply goods or services to us)
consistent with your consent, which, for newsletters and marketing you may revoke at any time in the Subscription Centre, which can be accessed by clicking the ‘Unsubscribe’ option at the bottom of our emails or by clicking ‘Change contact preferences’ in your profile (if you have a ulivohk.com account) – if you’re having any issues unsubscribing please email info@ulivohk.com
as necessary for our (or others’) legitimate interests, including our interests in providing safe Website/Services, fraud detection, tailoring your experience on our Websites/Services, knowing how customers use our Website/Services and products, keeping our Websites/Services updated and relevant, developing our business and informing our marketing strategy, and managing our relationships and fulfilling contracts with business partners, licensees and suppliers, but only if these are not overridden by your interests, rights or freedoms.
YOUR RIGHTS
Under the Personal Data (Privacy) Ordinance you have a number of important rights. In summary, you have the right to access your personal data and require that we rectify any errors in the data that we hold, or request that we erase your personal data subject to certain limitations. In some circumstances, you can also require that we restrict the way we process your personal data, object to its processing or request a copy of your personal data (at your own expenses). Where we have requested and obtained your consent to process particular information, you may withdraw that consent at any time. However, if we do not hold all the data we need to administer contracts, orders, competitions or challenges you entered into, we may not be able to provide you with these benefits any longer.
If you would like to exercise any of those rights, please send your request to us via either of the methods described below under “How to Contact us” and:
let us have enough information to identify you (e.g. your full name and contact details – including your email address); and
let us know what right you want to exercise and the information to which your request relates (e.g. details of the specific information you require and any relevant dates).
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems to make sure the level of security matches any risk and we run regular security tests.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy was published on 4 September 2020 and last updated on 10 September 2020. We may change this Privacy Policy from time to time; when we do we will post the changes on the Website. Where the changes are significant, we will inform all our registered users by email. Where required by law, will we obtain your consent to make these changes.
HOW TO CONTACT US
Please contact us if you have any questions about this Privacy Policy or the information we hold about you.
If you wish to contact us please:
email us at info@ulivohk.com