Introduction

Kimberly-Clark (Hong Kong) Limited ("KCHK") respects and is committed to upholding your rights to privacy protection under the CAP 486 Personal Data (Privacy) Ordinance (“the Personal Data (Privacy) Ordinance”). KCHK will comply with the Personal Data (Privacy) Ordinance which regulate the collection, use, disclosure and handling of personal information.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable directly or indirectly.

This privacy policy (the “Policy”) details the practices that we have adopted to protect your privacy, so that you can feel confident about how we manage the personal information you entrust to us.

By using our websites and other online applications or platforms, or otherwise providing us with personal information (including sensitive information), you consent to us collecting, using, disclosing and/or transferring (including cross-border transfer) that information in accordance with this Policy. Any failure to disclose your personal information to us will affect your benefits to the extent that the purposes specified in this Policy may not be achieved.

Please ensure that you read this Policy before submitting your information to us. Before providing personal information to us relating to other persons, you must obtain their consent and notify them of the location of this Policy.

Children's privacy is of primary concern to us. We do not knowingly collect personal information from children under 18 years of age or retain any communication we receive that is identified as being from a child under the age of 18, unless we have the prior consent of the child’s parent or legal guardian. If you are under the age of 18, you must let your parent or guardian know about this Policy before using our websites and other online applications or platforms.

If there is any inconsistency between the English and Chinese version of this Policy, the English version shall prevail.

What kinds of personal information will we collect, and why do we collect it?

KCHK will collect and hold personal information that is required for our business functions and activities, or to comply with our legal obligations. Personal information may include your name, e-mail address, phone number, date of birth, postal address or social media account ID.

Because of the nature of our products, we may also collect sensitive information about you, including information concerning your health or medical condition.

How do we collect your personal information?

We collect personal information in a number of ways, including information that you provide to us:

• through your use of our websites and other online applications or platforms;
• when you speak to our staff;
• when you request a sample, make an enquiry, or provide feedback about a KCHK product;
• when you make a payment to us or our carefully selected partners;
• when you submit a rating or user review about a KCHK product;
• when you participate in KCHK promotions, events or market research; and
• when you apply for employment with KCHK.

In addition, there will be circumstances where we obtain your personal information from other sources, such as joint marketing partners, social media platforms or persons with whom you are connected on social media platforms.

Cookies and passive information collection

Like many companies, we sometimes use "cookie" technology or other automated means to collect certain information about you, your computer or other device through which you access our websites. We use cookies to help us to identify, customise and deliver content such as advertisements, promotions or offerings of greatest interest to you, gather statistical information and better understand individual use. In certain cases, we share this information with third parties to assist us in this process. If you choose, you may set your browser to reject cookies or you can manually delete individual or all of the cookies on your device by following your browser’s help file directions (though please note that you may lose functionality by doing so).

A web beacon is an electronic file on a Web page that allows us to count and recognize users who have visited that page. Among other things, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness – for instance, if you get an email from us and click on a link in that email to go to our website. You can generally avoid web beacons in email by turning off HTML display and displaying only the text portion of your email.

Pixel tags, web beacons, clear GIFs and similar technologies may also be used by us or our third party service providers to measure the success of marketing campaigns and compile statistics about communications and site usage.

Furthermore, and as is common practice, we may identify and compile information concerning your IP address (a number automatically assigned to your device by your internet service provider) which helps us to calculate site usage levels, diagnose technical problems and administer our websites and other applications.

What will we do with your personal information?

Your personal information will be collected, held, used and disclosed by us in accordance with this Policy and applicable privacy laws. We may disclose or use your personal information for the purpose for which we collected it, as well as for related purposes where you would reasonably expect us to do so. This may include (but is not limited to) the following:

• to respond to your inquiries or feedback and to fulfil your requests;
• to process rewards, donations, prizes, or sample requests;
• to provide you with updates, announcements and details of promotional activities concerning any KCHK brands, as well as non-KCHK brands which we believe may be of interest to you and for the purpose of direct marketing (as described below in “Use of your personal information in direct marketing”);
• to enable you to participate in social sharing, including live social media feeds and blogs;
• for our business purposes, including quality assurance, market research developing and improving our products, enhancing our sites or apps, identifying usage trends and measuring customer satisfaction;
• in dealing with our third party service providers that provide services such as advertising, web hosting and moderating, e-mail and direct mail delivery, IT services and fulfilment houses;
• where the law requires or permits us to do so, including sharing your information with government entities or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against legal claims that might be brought against us; and
• for other purposes disclosed to you when we collect your information.

In addition:

• we may allow users of our websites, applications and social media pages to share comments, postings, testimonials (including ratings or reviews), or other information. If you choose to submit such information, the information that you submit may be available generally to the public through our websites, applications and social media pages or those of our partners, with whom we may share that information; and
• circumstances may also arise where KCHK decides to sell, buy, merge or otherwise reorganise its business. Such a transaction may involve the disclosure of personal information to prospective or actual buyers or sellers. It is our practice to seek appropriate protection for the disclosure of such information in these types of transactions.

You may restrict the use of your personal information at any time by using the opt-out mechanism that we include in our communications with you.

We will take all reasonable steps to maintain the security and integrity of your personal information including through the use of access passwords, firewalls and requiring that our partners protect your personal information. We will also take all practicable steps to erase your personal information where the information is no longer required for the purpose (including any directly related purpose) for which your personal information was used.

We may share your personal information with certain third parties (as described below).

How we share your personal information

We may share your personal information with companies or individuals that provide us with services. These services may include, among other things, helping us to provide services that you request, to create or maintain our databases, to research and analyse the people who request products, services, or information from us, to prepare and distribute communications, or to respond to inquiries. We may also give your information including your name, e-mail, telephone number or postal addresses to a fulfilment house, retailer or distributor of our products in order to carry out your requests.

KCHK will use the details you provide to us, including feedback given to our Consumer Engagement Team or Consumer Advisory Service (whether by e-mail, telephone, letter or otherwise) in order to investigate and provide you with the information, services and products necessary to satisfy your customer inquiry or complaint. We may also from time to time provide details of a serious complaint to the relevant supervisory government body (such as the Competition Commission of Hong Kong and the Pharmacy and Poisons Board of Hong Kong) in order to meet our legal obligations and in the interests of public safety. By submitting feedback, you consent to our use and disclosure of your personal and sensitive information in this way.

We may share non-personal information with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-personal information of numerous people together so that the data does not relate to any one person. De-identify means that we attempt to remove or change certain pieces of information that might be used to link data to a particular person.

We may share your personal information with certain third parties for direct marketing purpose (as described below).

Use of your personal information in direct marketing

If you provide us with your personal information, we may use it for direct marketing purpose. We may not use your personal data for such purpose unless we have received your consent. Therefore, by reading and acknowledging this Policy and submitting your personal information to us, you are taken to consent (which includes an indication of no objection) the use of your personal information for this purpose. As a result of your consent, the specific requirement regarding direct marketing in Part VIA of the Personal Data (Privacy) Ordinance is hereby fulfilled.

Pursuant to the Personal Data (Privacy) Ordinance, we may from time to time use the name, contact details, products and services portfolio information, financial background and demographic data in direct marketing. The direct marketing activities conducted by KCHK may include but not limited to the following:

• offering, or advertising of the availability, of goods, facilities or services; or
• sending information or goods, addressed to specific persons by name, by mail, fax, electronic mail or other means of communication; or
• making telephone calls to specific person

The following classes of service, products and subjects may be marketed:

• Wipers
• Toilet papers
• Facial Tissues
• Air fresheners
• Dispensers
• Personal Protect Equipment (PPE)
• Napkins
• Skincare and sanitizers
• Paper Towels
• Washroom Accessories

In addition to promoting our services and products, as permitted by, or to comply with, the Personal Data (Privacy) Ordinance and applicable privacy laws, we may also provide your personal information to third parties for direct marketing purpose. We may not use your personal data for such purpose unless we have received your consent. Therefore, by reading and acknowledging this Policy and submitting your personal information to us, you are taken to consent (which includes an indication of no objection) the use of your personal information for this purpose.

We may provide your personal information to a third party for gain. We may provide your personal information such as the name, contact details, products and services portfolio information, financial background and demographic data to third parties for direct marketing purpose.

We may provide your personal information to the following classes of people:

• Kimberly-Clark group companies;
• marketing agencies who assist us with our promotional, marketing and research activities; and
• our carefully selected partners when we believe their products or services may interest you.

The following classes of service, products and subjects may be marketed:

• Wipers
• Toilet papers
• Facial Tissues
• Air fresheners
• Dispensers
• Personal Protect Equipment (PPE)
• Napkins
• Skincare and sanitizers
• Paper Towels
• Washroom Accessories

We also participate in interest-based (on-line behaviour) advertising. This means that a third party may use technology, such as a cookie on your browser or a web beacon, to identify you on our website so that they can provide advertising about products and services tailored to your interest. You may see advertising on our website or apps tailored to how you browse or shop, or you may see advertising for our products on other websites or apps based on your browsing behaviour.

You may restrict such use of your personal information in direct marketing at any time by using the opt-out mechanism that we include in our communications with you.

Overseas disclosure of your personal information

Your personal information may be disclosed to KCHK’s affiliate companies or third party service providers located outside of Hong Kong. It is likely that those overseas recipients will be located in the United States of America, Thailand, Vietnam, Singapore, the United Kingdom, Czech Republic, India, Korea or Malaysia, though this list will change from time to time. If you provide your personal information to us in accordance with this Policy, you acknowledge that some of these places might not have in force any law which is substantially similar to, or serves the same purposes as the Personal Data (Privacy) Ordinance, and you are taken to consent to the disclosure of your personal information to overseas recipients. As a result of your consent, Article 33, Section 2 of the Personal Data (Privacy) Ordinance (not yet in force) will not apply to the disclosure. Whilst we will make every reasonable effort to ensure that recipients of your information protect your personal information, we will not be obliged to ensure that overseas recipients comply with the Personal Data (Privacy) Ordinance including the Data Protection Principles (as relevant).

Information collected through employment applications

In processing applications for employment, KCHK collects resumes, references, certificates of graduation and qualification and other personal information about candidates. We may also provide your application to a recruitment agency or contractor that may assist in reviewing applications we receive.

Letters and resumes sent to KCHK as part of an application for an advertised position, or sent to ascertain whether any positions are available, will be used to match applicants with available opportunities. If we consider that your application may be suitable to our current requirements, we, or a party acting on our behalf, will notify you and may also contact persons nominated by you as referees and ask them questions in relation to you. If your application is not suitable for our current requirements, but we feel that there may be a position for you in the future, we may keep a record of your application and contact you again if a suitable position becomes available. Please advise us if you prefer that we do not retain your information for this purpose.

Content you submit on our websites

By submitting content to and through website(s) controlled by KCHK and/or its affiliates or service providers (“K-C Sites”), you are responsible for the following: (1) you are the owner of the content; (2) the content is truthful and accurate; (3) the content will not cause injury to any person or entity; (4) the content does not infringe someone else’s copyright, trademark, proprietary rights or rights of publicity and privacy; (5) the content does not violate a law, statute, ordinance or regulation; (6) the content would not reasonably be considered to be defamatory, libelous, hateful, racially or religiously biased or offensive or harassing to another party; (7) the content does not contain references to other websites, email addresses, contact information or phone numbers; (8) if the content contains the likeness or name of an identifiable person, you have that person’s permission to include their likeness/name in the content you are submitting; and (9) the content does not contain computer viruses, worms or other potentially damaging programs or files.

For any content that you submit, you grant KCHK a perpetual, irrevocable, royalty-free, sub-licensable, transferable right and license to use, copy, modify, delete in its entirety, adapt, publish, translate, create derivative works from and/or sell and/or distribute such content and/or incorporate such content into any form, medium or technology throughout the world without compensation to you. You also hereby grant each user of K-C Sites a non-exclusive license to access your content through these sites, and to use, reproduce, distribute, prepare derivative works of, display and perform such content as permitted through the functionality of these sites.

All content that you submit may be used at KCHK's sole discretion. KCHK and/or its affiliates reserve the right to change, condense or delete any content on K-C Sites that it deems, in its sole discretion, to violate the content guidelines or any other provisions herein. KCHK does not guarantee that you will have any recourse through us to edit or delete any content you have submitted. Product ratings and written comments are generally posted within 2 to 4 business days. However, KCHK reserves the right to remove or to refuse to post any submission for any reason.

Links and third parties

This Policy does not cover, and we are not responsible for the practices of third parties, including any third parties that operate a website or application accessed through a link that appears on a KCHK website or application. This includes any social media platforms to which you post content related to our products.

How to access and correct your personal information or make a request

If you would like to review, correct, update or delete the personal information that we hold concerning you, or if have any questions or requests concerning a possible breach of the Personal Data (Privacy) Ordinance, please contact us:

Mail: G.P.O. Box 8538 Hong Kong
Phone: (852) 2355-8640
E-mail: [email protected]

We will investigate and determine the steps we will take to resolve the requests. We aim to acknowledge receipt of your request within 5 working days, and to address the request within 15 working days and no less than 40 calendar days. We may also request information from you to help us with our investigation.

Updates to this Policy

We may change this Policy from time to time. The date on which the Policy was last updated is noted at the top of this page. Any changes to the Policy are effective from posting the revised Policy on this website.