Privacy notice

Privacy Collection Statement

Fackel Ecommerce Limited and its group companies in Hong Kong and Macau (hereinafter referred to as "Fackel", "we", or "us") respect your privacy. We are committed to ensuring that your personal data is collected, transmitted, stored, and used in accordance with the provisions of the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (Cap. 486) (the "Ordinance") and the Personal Data Protection Law of the Macau Special Administrative Region, as applicable.

This Privacy Policy (hereinafter referred to as the "Policy") outlines our privacy practices and forms an integral part of Fackel's Membership Terms and Conditions and Fackel's Shopping Terms and Conditions (including terms and conditions related to delivery services and shopping guarantees).

1. Collection of Personal Data

1.1 We may collect your personal data when you submit a membership application form, request services (e.g., delivery), or contact us.

1.2 If you are under the age of 18, you must obtain consent from a parent or guardian before providing any personal data.

1.3 If you are submitting personal data on behalf of another individual, you declare and warrant that you have obtained the individual’s consent for such submission.

1.4 The personal data you provide will be used by Fackel for the purposes outlined below, as well as any directly related purposes. These purposes are categorized into purposes for which data must be provided and purposes for which data may be voluntarily provided. If personal data is required for a specific purpose, it will be marked as "mandatory" in the membership application form. In other cases (e.g., responding to inquiries or requests), we will inform you whether providing such data is mandatory. If personal data is requested for voluntary purposes, you may choose whether to provide the data.

1.5 The purposes for which you are required to provide personal data include:

• (a) Processing your membership application;
• (b) Enabling and maintaining your membership benefits;
• (c) Continuing or terminating your membership;
• (d) Managing your membership and personal data;
• (e) Providing our products and services and fulfilling transactions requested by you;
• (f) Handling and following up on inquiries and complaints;
• (g) Verifying your identity;
• (h) Informing you of any updates to the membership program; and
• (i) Disclosing data to government, regulatory, or enforcement authorities in Hong Kong and overseas, as required by laws and regulations governing us.

1.6 The purposes for which you may voluntarily provide personal data include:

• (a) Allowing us to provide products and services tailored to your needs;
• (b) Monitoring and analyzing trends related to our products and services;
• (c) Helping us better understand our customer demographics;
• (d) Conducting research related to our products and services;
• (e) Performing statistical analysis on your behavior and interests regarding our products and services;
• (f) Conducting customer data analysis;
• (g) Recommending products and services that may interest you and other customers; and
• (h) Any other purposes you agree to from time to time.

1.7 With your consent (including implied consent), we may use your name, email address, phone number, residence area, gender, age group, and/or shopping history for the promotion of our products and services, the products and services of Fackel's group companies, and news, rewards, promotions, and other activities organized by Fackel. If you no longer wish for us to use your personal data for direct marketing purposes, you may notify us by sending an email to cs@fackelecommerce.com. We will update our systems within fourteen (14) days of receiving your request.

2. Disclosure of Personal Data

We will take practical and reasonable steps to protect your personal data from unauthorized access, disclosure, misuse, handling, alteration, destruction, or loss. However, we may transfer or disclose your personal data to the following parties:

• (a) Any actual or potential buyer, assignee, or successor in the event of a sale of any part of our business;
• (b) Agents, suppliers, contractors, professional advisors, insurers, network operators, or third-party service providers providing administrative, IT, or other services to us and/or related to our products or services;
• (c) Government, regulatory, or enforcement bodies where disclosure is required by law or regulation; and/or
• (d) Government authorities or third parties assisting us in investigating, preventing, or responding to fraud, security, or technical issues.

3. Cookies

Cookies are small text files automatically stored on your device when you visit certain sections of our website. We may use cookies to provide certain services and enhance your experience. Cookies can identify devices but are not used to collect personal data of individual users of our website. Most browsers automatically accept cookies, but you can modify your browser settings to decline them. However, declining cookies may prevent you from using some features of our website. By browsing these sections of our website, you consent to our use of cookies.

4. Security of Personal Data

4.1 Aside from the situations outlined in Section 2(a) to (d), only authorized employees or contractors may process your personal data. Authorized personnel are assigned to handle your personal data in compliance with this Policy.

4.2 While we have implemented reasonable security measures to prevent unauthorized access, disclosure, use, or alteration of your personal data, we cannot guarantee absolute security of data processing.

5. Retention of Personal Data

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. Thereafter, we will destroy such data unless retention is required by law, regulation, or for accounting purposes, or for protecting our rights under applicable laws or regulations.

6. Your Rights

6.1 You have the following rights:

• (a) To know whether we hold your personal data and to access or obtain copies of the data;
• (b) To request correction or supplementation of any inaccurate or incomplete information related to you;
• (c) To inquire about our privacy policies and practices and request details on the types of personal data we hold about you;
• (d) To object to our use of your personal data for direct marketing purposes; and
• (e) To withdraw your consent to the collection and processing of your personal data (note that this does not affect the legality of any processing carried out before your withdrawal. If you withdraw consent, we may be unable to provide certain products or services to you).

6.2 We will make reasonable efforts to comply with your requests, but there may be circumstances where we cannot fulfill certain requests due to legal reasons (if applicable, we will notify you). All requests will be reviewed within forty (40) days of receipt. If your request is complex or you submit multiple requests, we may need more time to respond. In such cases, we will inform you of the need for additional time.

6.3 To exercise any of the above rights, please email cs@fackelecommerce.com with the subject "Confidential" and include relevant details (e.g., name and membership number) to facilitate the processing of your request. We may ask for additional data to verify your identity. A reasonable fee may be charged for processing your request.

7. General

7.1 If any part of this Policy is deemed unlawful or unenforceable for any reason, that part will be considered severable, and the validity and enforceability of the remaining provisions will not be affected.

7.2 In the event of any discrepancies between the English and Chinese versions of this Policy, the Chinese version shall prevail.