Privacy Policy

Madison (Hong Kong) Limited (collectively, the "Company", "we", "us") are committed to protecting the privacy of its online guests at https://subzero.com.hk (the "Site"). In order to provide you with the best possible service and experience, we will collect, use, process and disclose personal data about you. This privacy policy ("Privacy Policy") is intended to provide you notice of our information management practices, including the types of information we collect and how it is used and safeguards we have in place.

By using, accessing or submitting personal data to us or to the Site, you agree to the collection, use, processing and disclosure of your personal data and (with your consent) to direct marketing as set out in this Privacy Policy. The Privacy Policy shall be read together with the Company's Terms of Use for this Site and Cookies Policy available on the Site.

If you provide us with personal data about third parties (such as your family members), you confirm that, before providing us with their information, you have shown them this Privacy Policy and have obtained their consent for us to process their personal data as outlined in this Privacy Policy.

Collection and Use of Your Data

We may collect information about you from:

  • where you submit a request for information, reach out to us for support, make a purchase, subscribed to our latest news & promotion, submit a request through our Contact Us page through our Site;
  • being our specialist circle member, submit a request through our Customer Service page, submit a warranty registration request, and/or submit an extended warranty request through our Site;
  • or request to download our content through our Site. and
  • through data gathered from your social media and online activities, and any preferences you have indicated to us through our Site.

We may collect the following types of data from you:

  • Basic information about you: name, physical address, e-mail address, phone numbers and the name of the company you work for, date of birth, financial or credit card information, membership data.
  • Information about the products you purchased: product serial numbers of the products you purchased with us.
  • Technical information: which will include the type of mobile device you use, unique mobile device identifiers (such as, IP address, IMEI number, the address of the device's wireless network interface, or mobile phone number used by the device), mobile network information (such as domain name, or the address of the website that linked you to our Site), your mobile operating system (including the type of browser), time-zone settings, your activities (such as pages viewed or search requests);
  • Location information: geo-location data to determine your current location;

Purposes for Processing Your Personal Data

We may process your personal data for the following purposes:

  • to provide you access to and use of the Site and our services;
  • to communicate with you or provide you with customer support in connection with your use of the Site or our products and services;
  • to respond to your comments, queries, feedback or requests (including sending you a requested product brochure or requested information);
  • to improve and enhance your experience with the Site and our products and services (including understanding how you access, use and interact with the Site, analysing your use of the Site for improving technical functionality of the Site, or collecting feedback for enhancing and developing the Site and our products and services);
  • to aggregate data for statistical purposes, helping us determine user interest in different areas of our Site, improve navigation and content;
  • to retain records as may be required for corporate compliance and financial matters, including for tax, legal, audit and financial purposes, whether internal or external;
  • to detect fraud, illegal activities, or security breaches and carry out security and fraud prevention activities;
  • to respond to and comply with the requests from regulatory bodies or other authorities within or outside Hong Kong when legally required (including those concerning our tax, health and safety, employment, or anti-discrimination obligations);
  • to monitor and ensure compliance with company policies and corporate rules and procedures (including those related to whistleblowing and internal investigations, confidentiality obligations, anti-bribery and anti-corruption, conflict of interest and anti-discrimination);
  • to handle claims that we may face before any judicial and/or administrative authority, arbitration commission and/ or mediation panel; and
  • to manage our business, customer relationships, and corporate structuring and/ or M&A activity.

We will indicate whether it is mandatory for you to provide certain types of personal data at the time of collection. If you do not provide us with personal data which is marked as mandatory, we may be unable to administer and manage our relationship with you (including providing you with access our services) or comply with our legal obligations.

Where required to do so in accordance with applicable law, we will obtain your consent to process your personal data. for purposes other than those stated in this Privacy Policy

Sharing of Your Data

We may disclose your personal data to:

  • the Company's subsidiaries and/ or affiliates.
  • third parties who provide services to us or who otherwise process your personal data on behalf of us following our instructions, including when we are required to complete a customer-requested transaction, shipping or delivery of orders, or to provide in-warranty or out-of-warranty service.
  • to a subsequent owner or operator of our Site if we assign our rights and obligations regarding any of your data at the time of a merger, acquisition, or sale of all or substantially all of our assets or the Site's assets and/or services to a subsequent owner or operator.
  • our advisors and regulators, which includes our accountants, auditors, lawyers, other professional advisors and business contacts: for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations.

The Company may also disclose your personal data to third parties in the following instances: 1) we have been given your consent to disclose; 2) we have previously informed you of the disclosure, including by means of our Privacy Policy; 3) we are required by law or court order to disclose, or we believe in good faith that the law requires it; 4) disclosure is necessary to identify, contact, or bring legal action against, someone who may cause or be causing harm to, or interference with, our rights or property, other Site users, or anyone else; or 5) to respond to an inquiry, request or complaint that you have made.

We may also use IP addresses in cooperation with internet service providers to identify users if we deem it necessary to comply with laws, to enforce compliance with this Privacy Policy or our Terms of Use, or to protect our Site, customers, or others.

We may also use your personal data to send you marketing information about our services, news, offers, promotions and events which we think may be of interest to you via email or other electronic means. In each case, where required by applicable laws, we will only do so where we have your consent to receiving such marketing information from us.

From time to time your personal data may be transferred overseas for the purposes described in this privacy policy. Any transfers of personal data overseas are made pursuant to legally acceptable mechanisms that are aimed at ensuring an adequate level of protection as regards your personal data.

Our Site may contain links to and from the websites of our partners. If you access other sites using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these websites. Please check these policies before you submit any personal data to these websites.

Data Retention

We will retain your personal information for as long as required to achieve the purposes for which the personal data was collected unless a longer retention period is required or permitted by applicable laws.

Your Rights

You have the following rights in respect of your personal data:

  • to request access to personal data held about you;
  • to ask for the personal data we hold about you to be rectified if it is inaccurate or incomplete;
  • to lodge a complaint with the supervisory authority; and
  • (where applicable) to withdraw your consent at any time to direct marketing communications.

Please note that the exercise of such rights may be subject to certain legal conditions. If you would like to exercise any of these rights, please contact us using our Contact Us page on the Site. Where permitted to do so under applicable law, we may charge you a reasonable fee to process your request.

Protection of Children's Personal Data

We do not publish content that is targeted to children. We do not intend to collect personal data from anyone under 18 and will not knowingly collect, maintain, or disclose such data. If you are under 18, you should not enter any personal data about yourself on our Site. If you are a parent or guardian who has discovered that your child under the age of 18 has submitted his or her personal data without your permission or consent, we will make reasonable efforts to remove the data from our database, at your written request. To request the removal of your child's information, please send us an e-mail and be sure to include in your message the same information, including e-mail address that your child submitted.

Use of Cookies

Non-personal information may also be collected with the use of cookies. "Cookies" are small text files a website can use to recognize repeat users. When someone visits the Site, a cookie is placed on the customer's machine (only if the visitor's web browser has been set to accept cookies) or is read if the visitor has visited the Site previously. subzero.com.hk may collect aggregated Site-visitation statistics using cookies.

Security

We implement reasonable technical, physical, technical and organizational measures to protect your personal data from unauthorised or accidental access, loss, misuse, alteration, destruction or damage as well as to keep your personal data confidential.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us or from our Site, and you provide such information at your own risk.

Changes to Policy

We may make changes or updates to this privacy policy from time to time. Please check back frequently to see any such updates or changes. We may notify you in the event of any material changes and will, where required by applicable laws, obtain your consent to the same.

Further Questions

If you have any questions or comments about the Privacy Policy, please contact us via the Contact Us page or company addressed at 22nd Floor, Jonsim Place, 228 Queen’s Road East, Wan Chai, Hong Kong

Attention:

Data Privacy Manager

(Marked Confidential, and with the name of Madison (Hong Kong) Limited or by email at [email protected]

The effective date of this Privacy Policy is January 24, 2025.