Welcome to vangormake.com (the “Website”), operated by HONG KONG ART VISUAL CULTURE COMMUNICATION LIMITED (“we”, “us”, or “our”), with a registered address at Room 1003, 10th Floor, Tower 1, Lippo Centre, 89 Queensway, Admiralty, Hong Kong. This Privacy Policy (“Policy”) explains how we collect, use, store, disclose, and protect your personal information when you access or use our Website, place an order, or interact with us in any other way. By using the Website or providing your personal information to us, you agree to the practices described in this Policy. This Policy is supplementary to our Terms & Conditions and Shipping and Returns Policy, and shall be read together with them.
We are committed to complying with applicable privacy laws and regulations, including the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), and relevant Hong Kong privacy regulations, as well as the latest compliance requirements for Hong Kong companies engaging in overseas business[1]. We will not collect or use your personal information in any way that violates these laws, and we will not use “one-time blanket authorization” or “default authorization” to force or implicitly force you to agree to the collection and use of personal information unrelated to our business activities.
1. Information We Collect
We only collect personal information that is necessary for our business operations, in line with the principle of data minimization required by GDPR[2]. The personal information we collect falls into the following categories, depending on your interactions with the Website:
1.1 Personal Information You Voluntarily Provide
When you create an account, place an order, or contact our customer service, you may voluntarily provide the following personal information:
Contact information: Name, email address, phone number, and shipping/billing address.
Account information: Username, password (encrypted), and account preferences.
Payment information: Credit card details, PayPal account information, or other payment method details (we do not store full payment card information; this is processed by our third-party payment service providers).
Order information: Product selections, order quantities, order history, and communication related to your orders.
Other information: Any other personal information you choose to provide when contacting us (e.g., feedback, complaints, or special requests).
1.2 Automatically Collected Information
When you access or use the Website, we may automatically collect certain non-identifiable and identifiable information through cookies, web beacons, and other tracking technologies, including:
Device information: IP address, device type, operating system, browser type, and device identifiers.
Browsing information: Pages visited on the Website, time spent on each page, search queries, click-through rates, and other browsing behavior.
Usage information: Date and time of your visit, frequency of visits, and interactions with the Website’s features (e.g., product searches, cart actions).
This information is collected to improve the Website’s functionality, personalize your experience, and analyze user behavior. You can manage or disable cookies through your browser settings, but this may affect some features of the Website.
1.3 Information from Third Parties
We may receive personal information about you from third-party service providers, including:
Payment service providers (e.g., PayPal, credit card processors) to process your payments and prevent fraud.
Shipping and logistics providers (e.g., DHL, FedEx) to deliver your orders and provide tracking information.
Analytics service providers to help us understand Website usage and user behavior.
We only collect information from third parties if you have authorized them to share your information with us, or if required by law.
2. How We Use Your Personal Information
We use your personal information only for the purposes stated in this Policy, in accordance with the principles of legality, fairness, and transparency[2]. The main purposes for using your personal information are:
To process and fulfill your orders: Including verifying your identity, processing payments, arranging shipping, and providing order updates.
To manage your user account: Including creating and maintaining your account, allowing you to access account features, and updating your account information.
To provide customer service: Responding to your inquiries, feedback, complaints, or special requests, and resolving any issues related to your orders or the Website.
To improve the Website and our services: Analyzing user behavior, identifying areas for improvement, and optimizing the Website’s functionality and user experience.
To personalize your experience: Showing you relevant products, promotions, and content based on your browsing and purchase history.
To ensure security and prevent fraud: Detecting and preventing fraudulent activities, protecting the Website and our users from security breaches, and complying with anti-money laundering requirements[1].
To comply with legal obligations: Including tax reporting, responding to legal requests (e.g., subpoenas), and complying with Hong Kong’s regulatory requirements such as the Significant Controller Register (SCR) and CRS reporting[1].
We will not use your personal information for any purpose not stated in this Policy without your prior consent.
3. How We Disclose Your Personal Information
We respect your privacy and will not sell, rent, or lease your personal information to any third party for marketing purposes, in compliance with CCPA’s “Do Not Sell My Personal Information” requirement[3]. We may disclose your personal information in the following limited circumstances:
3.1 Third-Party Service Providers
We may share your personal information with third-party service providers who assist us in operating our business, provided that these providers agree to protect your personal information and only use it to perform the services we request. These providers include:
Payment processors (to process payments securely).
Shipping and logistics providers (to deliver your orders and provide tracking).
Analytics and marketing service providers (to analyze Website usage and send relevant promotions with your consent).
IT service providers (to maintain the Website’s functionality and security).
3.2 Legal and Regulatory Requirements
We may disclose your personal information if required by law, regulation, or legal process (e.g., a subpoena, court order, or government request). We may also disclose your personal information to protect our rights, property, or safety, or the rights, property, or safety of our users or others.
3.3 Business Transfers
If we are involved in a merger, acquisition, sale of assets, or other business transfer, your personal information may be transferred to the new owner or operator of the business, provided that the new owner agrees to comply with this Policy.
4. Your Privacy Rights
Under applicable privacy laws (including GDPR and CCPA/CPRA), you have certain rights regarding your personal information. We will respond to your requests in a timely manner, in accordance with legal requirements[2][3].
4.1 Rights Under GDPR (For EU Residents)
Right to access: You have the right to request a copy of the personal information we hold about you.
Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal information about you.
Right to erasure (“right to be forgotten”): You have the right to request that we delete your personal information, subject to certain legal exceptions.
Right to restriction of processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.
Right to data portability: You have the right to request that we provide your personal information in a structured, machine-readable format, or transfer it to another data controller.
Right to object: You have the right to object to the processing of your personal information for marketing purposes or based on our legitimate interests.
Right to withdraw consent: If you have given us consent to process your personal information, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
4.2 Rights Under CCPA/CPRA (For California Residents)
Right to know: You have the right to request information about the personal information we collect, use, disclose, and sell (if applicable).
Right to delete: You have the right to request that we delete your personal information, subject to certain exceptions.
Right to opt-out of sale/sharing: You have the right to opt out of the sale or sharing of your personal information (we do not sell your personal information, but you may still exercise this right if applicable).
Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights (e.g., charging you higher prices or providing lower-quality services).
4.3 How to Exercise Your Rights
To exercise any of your privacy rights, please contact us at wayne@dramapapa.com, providing your full name, email address, and a clear description of your request. We may ask you to provide additional information to verify your identity, to ensure that your personal information is not disclosed to unauthorized individuals. We will respond to your request within the timeframes required by law (e.g., 30 days under CCPA, 1 month under GDPR, with possible extensions if necessary).
5. Data Storage and Security
5.1 Data Storage
We store your personal information on secure servers located in Hong Kong and other jurisdictions that comply with applicable privacy laws. We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law (e.g., retaining business records for at least 7 years in compliance with Hong Kong’s regulatory requirements[1]). After this period, we will securely delete or anonymize your personal information.
5.2 Data Security
We take reasonable technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, modification, or destruction. These measures include:
Encryption of sensitive personal information (e.g., payment details) in transit and at rest.
Secure access controls to limit access to personal information to authorized personnel only.
Regular security audits and updates to our systems and software.
Training for our employees on data protection and privacy best practices.
Compliance with Hong Kong’s banking and financial security requirements to protect financial data[1].
While we take all reasonable steps to protect your personal information, no method of transmission or storage is 100% secure. We cannot guarantee the absolute security of your personal information, but we will promptly notify you if a data breach occurs that may affect your personal information, in accordance with applicable law.
6. Cross-Border Data Transfer
As an international seller based in Hong Kong, we may transfer your personal information to third-party service providers or our affiliates located outside of your country or region (including but not limited to Hong Kong, the EU, and the US). We ensure that all cross-border data transfers comply with applicable privacy laws, including:
For EU residents: Transfers to countries outside the EU are made only to countries that have been deemed to provide an adequate level of data protection by the European Commission, or through the use of Standard Contractual Clauses (SCCs) approved by the European Commission[2].
For US residents: Transfers are made in compliance with CCPA/CPRA and other US state privacy laws, ensuring that your personal information is protected to the same standard as required by these laws.
For all users: We ensure that any third party receiving your personal information agrees to comply with this Policy and applicable privacy laws, and we maintain records of all cross-border data transfers in compliance with Hong Kong’s regulatory requirements[1].
7. Cookies and Tracking Technologies
We use cookies and other tracking technologies (e.g., web beacons, pixel tags) to improve your experience on the Website. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information about your visit.
Necessary cookies: These cookies are essential for the Website to function properly (e.g., to remember your cart items or login status). You cannot disable these cookies without affecting the Website’s functionality.
Analytics cookies: These cookies help us analyze how users interact with the Website, so we can improve its performance and functionality.
Marketing cookies: These cookies are used to show you relevant promotions and content based on your browsing and purchase history, with your consent.
You can manage your cookie preferences through your browser settings (e.g., Chrome, Firefox, Safari). Disabling certain cookies may affect your ability to use all features of the Website.
8. Children’s Privacy
Our Website is not intended for children under the age of 13 (or the legal age of consent in your jurisdiction). We do not knowingly collect personal information from children under this age. If we become aware that we have collected personal information from a child without parental consent, we will promptly delete that information.
9. Changes to This Policy
We reserve the right to update or modify this Policy at any time, to reflect changes in our practices, applicable laws, or regulatory requirements[1]. Any changes will be posted on the Website and will take effect immediately upon posting. We encourage you to review this Policy regularly to stay informed about how we protect your personal information. Your continued use of the Website after changes are posted constitutes your acceptance of the revised Policy.
10. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy, your personal information, or your privacy rights, please contact us at:
Email: wayne@dramapapa.com
Company: HONG KONG ART VISUAL CULTURE COMMUNICATION LIMITED
Address: Room 1003, 10th Floor, Tower 1, Lippo Centre, 89 Queensway, Admiralty, Hong Kong
We will respond to your inquiries within a reasonable timeframe and work with you to resolve any issues.
