ASA Innovation & Technology Limited and/or its affiliates (collectively “ASA”) at http://airluna.com (“Website”) is deemed as the data user collecting, controlling, holding, disclosing and using your personal data and therefore pledge to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, ASA will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by its customer(s) and prospect(s) (collectively “You”) to ASA and ASA will not release such information to anyone without your prior consent except to the authorized persons listed under section 3 “Disclosure or Transfer of Data”. References in this privacy statement (“Privacy Statement”) to “we” or “us” shall be deemed to be references to ASA.

You are strongly recommended to read this Privacy Statement carefully to have an understanding of our policy and practices with regard to the treatment of Personal Data (as defined under section 2 “Collection of Personal Data” clause 2.1) provided by you.

If you have questions or concerns regarding this Privacy Statement, you should first contact our customer service representative at (852) 3689 5185 or email official@airluna.com.

1.Provision of Services

1.1We provide the following types of products and services at the Website to you:

  • (a)sale and delivery of Airluna branded products in consumer electronics, home appliances and related industry;
  • (b)provision of warranty, repair and maintenance services related to the above products;
  • (c)provision of services related to the above and such other consumer and related products which may be accessed via the Website and its sub-domains only for Airluna branded products(collectively “Websites”) and/or rendered by such other appropriate means of ASA.
  • (collectively, “Services”).

1.2.We may engage our affiliates and third party service providers in providing Services to you from time to time.

2.Collection of Personal Data

2.1.Means of Collection of Personal Data
We may collect your Personal Data by various means including but not limited to the following:

  • via the Websites;
  • member, warranty registration forms (whether completed via the Websites);
  • activities enrolment forms (whether completed via the Websites);
  • order forms (whether completed via the Websites);
  • enquiry forms (whether completed via the Websites);
  • forms for repair and maintenance services, contests, surveys, or special offers (whether completed via the Websites);

We may collect your personal information and/or data such as your name, address, email address, phone number, age, sex, date of birth, country of residence, nationality, education level, work experience, marital status, number of children and log-in ID and password for getting access to the Websites (if applicable) that is/are not otherwise publicly available (collectively “Personal Data”). We may also automatically collect information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files, and link such information and data automatically collected to the Personal Data which have been provided to us by you (for details of collection of such information please refer to section 6 “Use of Websites of ASA” clause 6.1 “Cookies and Log Files”).

Only duly authorized staff of ASA will be permitted to access your Personal Data, and we will not release such Personal Data to any third parties save and except for the circumstances listed out under section 3 “Disclosure or Transfer of Data”.

2.2.Purpose of Collection of Personal Data
In the course of using the Services, you may disclose or be asked to provide Personal Data. In order to have the benefit of and enjoy various Services offered by ASA, it may be necessary for you to provide us with your Personal Data. Notwithstanding anything to the contrary, we guarantee the purpose of such collection through the Websites is limited to the Services in relation to any current and future products branded with Airluna and such Service is in no event to be combined with non-Airluna branded products. Although you are not obliged to provide the Personal Data as requested, we may not be able to render certain Services to you in the event that you fail to do so.

Our purposes for collection of information and data include but not limited to the following:

  • for the daily operation of the Services provided to you;
  • to identify you who have enjoyed and used the Services provided;
  • to provide you with our marketing and promotional materials of Airluna branded products for your enjoyment of benefits (for further details, please refer to section 4 “Subscription of Newsletter/Promotional Materials/Marketing Materials” below);
  • to identify you who have enjoyed our benefits as customers by receiving and using marketing and promotional materials of Airluna branded products;
  • to allow you to enjoy your benefits by enrolling for special events hosted by ASA for Airluna branded products;
  • to design and provide Airluna branded products and Services to you in relation to the above purposes; and
  • to facilitate us to use your Personal Data for purposes relating to our services, special events and/or promotions and/or our clients for Airluna branded products and the Services.

If you are under the age of 13, we would strongly recommend you to seek prior consent from a person with parental responsibility for you, e.g. parent or guardian, who may contact our responsible personnel at official@airluna.com, for providing relevant and appropriate Personal Data to us.

3. Disclosure or Transfer of Data

3.1.We agree to take all practicable steps to keep all your Personal Data confidential and/or undisclosed, subject to the following.

Generally speaking, we will only disclose and/or transfer your Personal Data to our personnel and staff for the purpose of providing Services to you. However, we may disclose and/or transfer such Personal Data to third parties under the following circumstances:

  • where the Personal Data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorized by us to use such Personal Data and who will facilitate the Services provided by us, under a duty of confidentiality;
  • where the Personal Data is disclosed and/or transferred to any agents, affiliates or associates of ASA who have been duly authorized by us to use such Personal Data;
  • where we need to protect and defend its rights and property;
  • where we consider necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on ASA; and
  • where we deem necessary in order to maintain and improve the Services.

3.2.Personal data collected by us may be transferred, stored and processed in any country in which we operate. By using the Services, you are deemed to have agreed to, consented to and authorized us to disclose and/or transfer your Personal Data under the circumstances stated above, as well as to any transfer, disclosure and use of your Personal Data outside of your country. To the extent permitted by law, by using the Services, you are deemed to have agreed to, consented to and authorized us to disclose and/to transfer your Personal Data to the 3rd party – any members of Airluna Group through sending a separate prior notice to you.

4.Subscription of Newsletter/Promotional Materials/Marketing Materials

4.1.We may from time to time communicate to you with newsletters, promotional and marketing materials and information, either verbally or in writing, based on the Personal Data that you have provided to us. We may use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

  • your name, contact details, age, sex, date of birth, country of residence, nationality, education level, work experience, marital status, number of children and log-in ID and password for getting access to the Websites (if applicable) held by us from time to time may be used by ASA or its authorised personnel or staff in direct marketing;
  • the following classes of services, products and subjects may be marketed for Airluna branded products:
    • i.all products and services related to the Services provided by us;
    • ii.special events hosted by us for you, including but not limited to courses, workshops, road shows, member or club events, product launches, lucky draws and competitions;
    • iii.reward, loyalty, membership, club or privileges programmes and related products and services;
    • iv.special offers including coupons, discounts, group purchase offers and promotional campaigns;
    • v.products and services offered by our affiliates and corporate clients (the names of such affiliates and corporate clients can be found in the relevant advertisements and/or marketing or promotional materials for the relevant products and services, as the case may be);
    • vi.donations and contributions for charitable and/or non-profit making purposes.
  • the above products, services and subjects may be provided or (in the case of donations and contributions) solicited by us and/or:
    • i.our affiliates;
    • ii.third party service providers providing the products, services and subjects listed in paragraph (b) above; and
    • iii.charitable or non-profit marking organizations;
  • in addition to marketing the above services, products and subject itself, we also intend to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products and subjects, and we require your written consent (which includes an indication of no objection) for that purpose;
  • we may receive money or other property in return for providing the data to the other persons in paragraph (c) above and, when requesting your written consent as described in paragraph (d) above, we will inform you if we receive any money or other property in return for providing the data to the other persons.

4.2.Suitable measures are implemented to make available to you, the options to “opt out” of receiving such materials. In this regard, you may choose to unsubscribe for such materials by, as the case may be, clicking on the automatic link appearing in each e-newsletter/message and follow the instructions and procedures contained thereunder, filling out and returning the hard copy of the instruction for “opt-out” or contact our customer service representative at (852) 3689 5185 or email official@airluna.com.

5. Access

5.1.You are entitled to request access to or make amendments to your own Personal Data kept with us by contacting our customer service representative at (852) 3689 5185 or email official@airluna.com.

5.2.In the event that you wish to access or amend your Personal Data, we may request you to provide personal details in order to verify and confirm your identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. We are required to respond to your requests within 40 days of your request and will endeavor to do so wherever possible.

6.Use of Websites

6.1.Cookies and Log Files
Apart from circumstances where provision of Personal Data is expressly requested, when you access the Websites, we record your visits. The Websites’ server software will also record the domain name server address, track the pages you visit, store such information in “cookies” and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without you being aware that they are occurring. We may link such information and data automatically collected in the above manner to the Personal Data which have been provided to us by you. We generally use such automatically collected information and data to estimate the audience size of the Websites, gauge the popularity of various parts of the Websites, track your movements on the Websites and number of entries in our promotional activities and special events, measure traffic patterns of how you use the Websites and administer the Websites. Such information may also be used by us for the purpose of marketing our goods and services. Such automatically collected information and data will not be disclosed save and except in accordance with section 3 “Disclosure or Transfer of Data”.

6.2.Links to Other Sites

  • The Websites may provide links to other websites which are not owned or controlled by us. Your Personal Data may be collected on these other websites when you visit them and make use of their services. Where and when you decide to click on any advertisement or hyperlink on the Websites which grants you access to another website, the protection of your Personal Data which are deemed to be private and confidential may be exposed in these other websites.
  • Upon using the Websites, you are deemed to have consented to the terms of this Privacy Statement. If you have not registered to the Websites and gain access to the Websites, including via your accounts in online social networking tools (including but not limited to Facebook), you are deemed to have consented to the terms of this Privacy Statement, and your Personal Data which you have provided to those networking tools may be obtained by us and be used by us and our authorized persons in and outside of your country for the purpose of providing services and marketing materials to you. ASA and its authorized personnel may gain access to and use your Personal Data so obtained, subject to the other provisions of this Privacy Statement.
  • This Privacy Statement is only applicable to those who utilise our Services. You are reminded that this Privacy Statement grants no protection to your Personal Data that may be exposed on websites other than the Websites, and we are not responsible for the privacy practices of such other websites. You are strongly recommended to refer to the privacy policy of such other websites.

7.Security

7.1.The security of your Personal Data is important to ASA. We will always strive to ensure that your Personal Data will be protected against unauthorized access. We have implemented appropriate electronic and managerial measures in order to safeguard, protect and secure your Personal Data.

7.2.All Personal Data provided by you are only accessible by the authorized personnel of ASA or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Statement when accessing such Personal Data. You may rest be assured that your Personal Data will only be kept for as long as is necessary to fulfill the purpose for which it is collected. If you have registered to the Websites, you should safeguard your unique Username and Password by keeping it secret and confidential and never share these details with anyone (where applicable).

7.3.We use a third party payment gateway service provider to facilitate electronic transactions on the Websites. Regarding sensitive information provided by you, such as credit card number for completing any electronic transactions, the browser on the Websites and third party payment gateway communicate such information using secure socket layer technology (SSL).

7.4.We follow generally accepted industry standards to protect the Personal Data submitted by you, both during transmission and once we receive it. However, no method of transmission or storage of data, including without limitation transmission over the Internet and storage by electronic means, is 100% secure. Therefore, while we strive to protect your Personal Data against unauthorized access, we cannot guarantee its absolute security.

8.Retention of Personal Data

Once we have obtained your Personal Data, it will be maintained securely in designated premises and computer systems of ASA and/or its engaged service provider(s). Subject to legal requirements, your Personal Data will be retained by us after deactivation of the relevant service until you request us in writing to erase your own Personal Data from our database or to terminate your membership of the Websites (if applicable).

9.Changes in this Privacy Statement

9.1.We reserve the right to update, revise, modify or amend this Privacy Statement in the following manner at any time as we deem necessary and you are strongly recommended to review this Privacy Statement frequently. If we decide to update, revise, modify or amend this Privacy Statement, we will post those changes to this webpage and/or other places we deem appropriate so that you would be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

9.2.If we make material changes to this Privacy Statement, we will notify you by email or by means of a notice on our home page.

9.3.For any query, please contact our customer service representative at (852) 3689 5185 or email to official@airluna.com.

10.Language

This Privacy Statement is written in both English and Chinese, both of which are equally authentic. In the event of conflict between the two versions, the English version shall prevail.