The Garden Club mobile application (“this Application”), operated by The Garden Company Limited (“the Company” or “we”), values and is committed to protecting users’ personal privacy and data security. This Privacy Policy applies solely to users of this Application.

Article 1 Company Information

1. “We” refers to The Garden Company Limited, located in Hong Kong (1–11 Sham Tseng Tsuen Road, Sham Tseng). We are the operator of the Garden Club.

Article 2 Definitions and Applicability

2. Unless otherwise specified, terms used in this Privacy Policy follow the definitions stated in our Terms and Conditions.

“Your personal data” refers to any information relating to an identified or identifiable natural person, provided by you or on your behalf.

Article 3 Protection Commitment

3.1. We are committed to protecting the privacy, confidentiality, and security of your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong). Our staff are also required to comply with relevant obligations.

3.2. Consent and Scope of Application

By using this Application (including but not limited to its functions, membership reward programme, and redemption features), you agree that we may collect, use, and process your personal data in accordance with this Privacy Policy. If you do not agree, please do not use the Application.

3.3. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Hong Kong. The courts of Hong Kong have exclusive jurisdiction over any claims relating to this Policy or the handling of your personal data.

Article 4 Data We Collect

4.1. Data provided during account registration, profile updates, membership usage, or purchases: name, email, registered mobile number, location, purchase history, payment details, etc.

4.2. Technical data: IP address, browser/device data, application usage logs, cookies, QR code scanning records, etc.

4.3. Social media interaction data (if you choose to use such features).

Article 5 Purposes of Data Collection

5.1. Creating and managing your account;

5.2. Providing membership rewards, purchase history and transaction services;

5.3. Sending essential notifications (e.g., verification codes);

5.4. Sending promotional/marketing information with your consent;

5.5. Handling inquiries, complaints and customer service matters;

5.6. Analysing and improving our products and services;

5.7. Meeting legal or regulatory requirements.

Article 6 Consequences of Not Providing Data

6.1. If you refuse to provide required data, we may be unable to register your account, grant membership rewards, or provide certain features.

Article 7 Direct Marketing

7.1. We may use the contact information you provide to send promotional or marketing messages after obtaining your consent. You may opt out at any time via email or written request.

Article 8 Sharing with Third Parties

To fulfil the purposes listed in this Policy, we may disclose personal data to the following categories of third parties:

8.1. Affiliated companies and business partners;

8.2. Third-party payment and logistics providers;

8.3. Market research, IT, and cloud service providers;

8.4. Legal, audit, and consulting firms;

8.5. Regulators or courts where legally required.

All third parties are contractually required to maintain confidentiality and use the data only for service-related purposes.

Article 9 Data Security

9.1. We adopt reasonable technical and organizational measures to protect personal data from unauthorized access, disclosure, or destruction.

9.2. Your data is stored on designated servers. While we strive to protect your data, internet transmission is not 100% secure.

Article 10 Data Retention

10. We retain personal data only for a reasonable period necessary to fulfil the purposes outlined in this Policy. Thereafter, data will be securely deleted or anonymized. Data may be retained longer if required by law or to resolve disputes.

Article 11 Access, Correction, or Deletion of Personal Data

11. You have the right to access, correct, or request deletion of your personal data held by us. Identity verification may be required before processing.

Contact us:

Email: gardenclub@garden.com.hk

Phone: +852 2491 0401

Address: 1–11 Sham Tseng Tsuen Road, Hong Kong

Article 12 External Links

12. This Application may contain links to external websites. We are not responsible for their privacy practices. You are encouraged to review their privacy statements.

Article 13 Policy Updates

13. We may update this Privacy Policy from time to time and publish the latest version on this Application. Continued use of the Application signifies acceptance of the updated Policy.