updated by 2021-10-25
Celestion Music is committed to compliance with the applicable regulatory and legal requirements in which we operate, and when we collect, use, hold and process Personal Data. This Policy sets out the general terms of Personal Data handling.
1. YOUR RIGHT AS A DATA SUBJECT
You may exercise your right to know whether we hold your Personal Data, what type of Personal Data is held and request access to, correction of, or deletion of your Personal Data held by us. We will provide you with a response in accordance with applicable data protection law. Celestion Music may refuse to provide such information in limited circumstances under applicable local law. You may send such requests or inquiries to email@example.com if you wish to:
- have access to your Personal Data for complying with your request;
- correct any Personal Data relating to you which is inaccurate;
- remove any Personal Data relating to you;
- withdraw your consent to the use of your Personal Data by us (however, withdrawing consent may affect your access and use of our App and/or Website); or
- restrict or object to processing of your Personal Data by us,
You also have the right to lodge a complaint before your local data privacy authority should we violate applicable data privacy laws(s) in our processing of your personal information.
2. PERSONAL DATA PROCESSING AND COLLECTION
“Personal Data” is any information that can identify a person individually and includes, without limitation, name, e-mail and/or postal address, telephone number, username, password, date of birth, gender, credit card number, billing and/or other contact information. Celestion Music will only process, collect and store your Personal Data under any of the following reasonable justifications:
- Consent: You have given explicit consent for Celestion Music to process, collect and store your Personal Data for the specified purpose.
- Performance of a Contract: Celestion Music process, collect and store your Personal Data for the purpose of entering or performing a contract with you given that you have accepted the contract and willingly provided these Personal Data to us.
- Legitimate Interest: It is necessary for Celestion Music to process, collect and store your Personal Data to reasonably maintain the interest of Celestion Music and any associated third party, under the circumstances that it does not override your fundamental rights and freedoms.
- Compliance with Legal Obligation: It is necessary for Celestion Music to process, collect and store your Personal Data to fulfil legal/regulatory obligations of countries that Celestion Music operates.
3. WHAT AND HOW PERSONAL DATA IS COLLECTED FROM YOU
The following are the most common situations when we may collect and store your Personal Data, and by using the Website and/or App, you agree to us collecting your Personal Data through the following means, although these means are not exhaustive:
- registration to use the App and/or Website;
- browsing, using, purchasing products, signing-up for Celestion Music’s newsletters through the App and/or Website and/or otherwise using Celestion Music’s services through the App and/or Website
- visiting Celestion Music’s booth for marketing campaigns;
- visiting Celestion Music’s social media platforms, including but not limited to Celestion Music’s Website, WeChat, Facebook or Instagram pages;
- visiting Celestion Music’s social media platforms to communicate with us on any enquiries;
- submission of surveys and/or event questionnaires (e.g. via webforms on the Website) and entry into sales promotions;
- registration for product warranties and maintenance services;
- requests for customer service or other assistance on the App, Website and/or mobile communication applications (such as WhatsApp, WeChat and/or Line);
- contacting us by email, post, fax and mobile communication applications or any other means of communication.
To fulfill the purpose of personal information processing including processing your purchase orders and delivery, addressing your support enquiry and communication, APP and/or Website account management and product registration, only necessary information of the below information would be collected to carryout such tasks at both Celestion Music and your interest:
- Name, email, contact numbers
- Shipping address
- Billing information for product/service purchasing*, including payment transaction details and billing address
*Billing information is classified as sensitive information according to the Personal Information Protection Law of China.
4. NON-PERSONAL DATA PROCESSING AND COLLECTION
“Non-Personal Data” includes aggregated and/or automatic information collected about use of Celestion Music’s resources or about a group or category of users, which individual identities with its identifiable information have been stored separately. These non-Personal Data include the performance data of Celestion Music’s product (e.g. activity logs and diagnostic data) and anonymized user behavior where usually would be stored within the product or the any devices with the connection to our products. Whereas any circumstance that is required to transfer such non-Personal Data from customer-end to Celestion Music, this would be conducted anonymously and we would not be able to identify any of the individual with the purpose of such processing considered as mandatory for us to collect some of the non-Personal Data to ensure the proper functioning of these resources and products. Celestion Music commits with the best effort to avoid identifying any individual from the collected non-personal unless at Celestion Music’s legitimate interest or data subject’s benefit to do so. Reasonable efforts have been committed by Celestion Music to govern the usage, such as access control, encryption and contractual agreements.
As these are considered as non-Personal Data, to the extent that the laws of certain jurisdictions allow, this Policy should not restrict or limit our collection, use and provision of non-Personal Data.
5. USE OF PERSONAL DATA IN DIRECT MARKETING
When you first register for an account on the Website and/or the App or when you first provide your personal information to us at Celestion Music Physical Locations or through other means of communication such as email, if you do not want your Personal Data to be used for direct marketing purposes, please do not tick the checkbox which allows you to opt into our newsletters and/or direct marketing activities.
You may also change your mind and request that we stop sending you direct marking materials/communications or to cease using or providing your Personal Data for any direct marketing purposes at any time by following the opt-out / unsubscribe facility provided in our marketing materials or by emailing us at firstname.lastname@example.org. We will ensure that you are not included in future direct marketing promotions.
6. SOURCE LOCATION DATA PROCESSING AND COLLECTION
When accessing Celestion Music’s resources, IP address location tracking or other means of technologies might be used to determine and collect information about the current location of your device, given that if the location tracking feature is enabled on the device. This geolocation data is collected anonymously in a form that does not personally identify you. The current location of your device will be stored locally on your device which will be used by the App and/or Website to serve you certain contents tied to the relevant location, and facilitate the initial setup of Celestion Music’s products. The basis of your location is being collected include certain regulatory requirement in specific jurisdiction or consider as mandatory to provide Celestion Music’s services for product usage.
If you elect to have your location-based searches saved to your history, we will store such information on our servers. In addition, only generic location such as country or region is being collected with the purpose as illustrated below:
- Customise and provide relevant information that relates to you.
- Enhance your browsing experience.
- Deliver advertisements according to your region.
- Address your enquiry and provide customer support through our regional representative.
A customer may always choose to restrict the sharing of location data by disabling the location tracking feature from the device and/or browser at any time. Disabling the location tracking feature will not affect your access or use of Celestion Music’s resources, but it may deliver information and contents that are less relevant to your location.
7. PERSONAL DATA TRANSFER FROM/ TO THIRD PARTY
Celestion Music is committed to take every measure to keep your Personal Data secure and confidential. Celestion Music does not exchange, nor transfer Personal Data with third parties for any purpose, including direct marketing. Share, sell, transfer, provide, rent or trade of Personal Data is not permitted unless we have obtained your consent or with legal basis in accordance with the requirements under the applicable law, except to carry out contractual obligations, fulfill purchase orders, by our legitimate interest, under the condition of Celestion Music that all or substantially all of our assets are sold/ transferred to another party, or requested by government agencies.
Considering Celestion Music operates and serves worldwide along with its subsidiaries and affiliated companies, the potential parties that may collect, use, hold, store and process of your Personal Data might also include the below which is committed to this Policy with appropriate contractual agreement in place:
- GP Acoustics International Limited
- GP Global Marketing Limited
- GP Acoustic (China) Limited
8. CHILDREN’S PRIVACY
We do not knowingly collect personal information from children aged under 14 or individuals under the age of majority in the country that they live. If you believe that we have inadvertently collected such information, please contact us at email@example.com so that we can promptly obtain parental consent or remove the information.
9. DATA SECURITY
We take reasonable administrative, physical and electronic measures designed to safeguard and protect your information from loss, destruction, misuse, unauthorised access, disclosure and alteration. Physical records of your Personal Data will be stored in locked cabinets in a secure location with restricted access. Electronic copies of your Personal Data will be stored on servers maintained by us and/or our third-party service providers, which are situated in secure locations and protected by adequate data security measures. Your Personal Data will be stored in an encrypted form behind a firewall designed to block access from outside our network.
While we try our best to safeguard your Personal Data once we receive it, no security or encryption method can be guaranteed to protect information from hackers or human error, and no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
Our Website and/or App may contain links to third party websites. These links are provided solely as a convenience. Celestion Music does not endorse any third-party websites. Access to any other website through any links provided on our Website and/or App is at your own risk. Celestion Music is not responsible for the content of any such websites or the accuracy or reliability of any information, data or other contents of those websites. We encourage you to consult the privacy policies of any third-party websites that you visit.
If you register an account on our Website and/or App, you are entirely responsible for ensuring and protecting the security and confidentiality of your password and account. You are also entirely responsible for any and all activities that occur under your account and we shall not be held liable for any claims, loss or damage resulting from a breach of the foregoing or any unauthorised use of your account.
10. DATA RETENTION
We will not keep your Personal Data for longer than necessary to fulfil the purposes and any directly-related purposes for which such Personal Data is collected. We will take into account any financial regulations and legal obligations that require us to retain the Personal Data for a certain period of time as well as the duration of your use of our Website and App. We will also keep your Personal Data as long as necessary for the following purpose at your own interest:
- Purpose of Celestion Music’s membership
- Provision of Celestion Music’s service and product
- Purpose of financial transaction
- Product delivery
- Provision of support request for Celestion Music’s service and product
If you wish to de-register from our Website and/or App, amend, update, remove your Personal Data, or request that we no longer use your Personal Data to provide you with the information or services you have requested, please contact us at firstname.lastname@example.org.
11. INTERNATIONAL TRANSFER AND LOCATION OF DATA PROCESSING
The location of the Personal Data sitting, usually in Hong Kong, where Celestion Music operates. In addition, one’s personal data may process through different information processing activities across the world, which it may take place in China or United States according to the location of customers. Processing location may also include the service providers and other third parties with whom Celestion Music may share information which might be out of the country of your location. If you are accessing the Celestion Music’s resources or by providing us with your Personal Data, you consent to the transfer of your Personal Data to our facilities outside of the country in which you have provided your Personal Data to us. The Personal Data protection laws of those countries where your Personal Data are stored might not be as stringent or comprehensive as those in your country, but we will take all reasonable steps to ensure the protection of your privacy and will only collect and use your Personal Data for the purposes which are set out in this Policy. In any case, Celestion Music will implement appropriate contractual measures, such as standard data protection clauses and data transfer agreement, to ensure that the relevant Celestion Music entities and third parties provide an adequate level of protection to your Personal Data as set out in this Policy and as required by applicable local law.
12. ENQUIRIES / CONTACT US
If you have any questions or complaints, or if you wish to access or correct your Personal Data or withdraw your consent to the use of your Personal Data held by us, or exercise any of your other rights, please contact us at email@example.com. We will, at no cost to you, act on your request within 30 working days in order to facilitate your data subject rights. You may also contact us by post via-
Celestion Music Asia Limited
9/F Building 12W, 12 Science Park West Avenue,
HK Science Park, Pak Shek Kok, New Territories