Last updated: 18 October 2024 Personal Data (Privacy) Ordinance

Statement on the Personal Data (Privacy) Ordinance

1. Xiong Daxing Group Limited (hereinafter referred to as "Xiong Daxing") respects personal data and promises to fully implement and comply with the data protection principles and relevant provisions of the Ordinance. This Policy applies to VIBRAM VIP Membership Program (hereinafter referred to as “Members”), VIBRAM App, VIBRAM Hong Kong official website ( https://vibramhk.com/ ), and other persons whose personal data are collected, used and stored by Xiong Daxing in various ways. If you are unable or unwilling to provide complete and accurate personal information, Xiong Daxing may not be able to process your membership application or provide or continue to provide you with the products, benefits and services under this program. By using this mobile application, you understand and agree to the above privacy policy and accept the processing of your personal data by this application, including the use of cookies on your computer, mobile phone or any electronic device, or the use of such data in any way, including, but not limited to, the collection, storage, deletion, use, combination and disclosure of such data. If you reside outside Hong Kong, your data will be processed and stored in accordance with the Hong Kong Privacy Ordinance.

2. Xiong Da Xing will collect, use and save your name, birth month, email address, telephone number, membership purchase and points records. Xiong Daxing may automatically collect certain information, including but not limited to, Cookies on the applications or browsers of your computers, mobile phones or any electronic devices to understand your usage habits. You may provide personal information at your own will. If you are under 18, please consult your parent or guardian before providing personal information. The administrator of this website will link technical information to the use of the website in order to provide the various functions of this website. This technical information may be used by the administrator of this website to manage this website, for example by resolving technical problems or improving the convenience of certain parts of the website. This way we ensure that you can continue to find information on the website quickly and easily. Therefore, we use the above-mentioned cookies and also process various technical information such as your computer's IP address, the pages visited on the Website, the web browser you use, the last/next visited website and the duration of each visit. If we are unable to obtain the information marked "Required", we may not be able to provide you with the services, products, gifts, rewards, offers or information you requested. When you use and register as a VIBRAM member, this page will obtain the personal information you provide. You can choose to register or not. The personal data you provide and the data generated, collected or held by Xiong Daxing about you under the Membership Program ("Personal Data") may be used and stored by Xiong Daxing for the following purposes:

A. Process your membership application;
B. Processing payment and delivery of your order
C. Provide you with the products, benefits and services of the membership program;
D. To promote services and products provided by VIRBAM and persons or companies that cooperate with the Membership Program (“Participating Merchants”);
E. To provide you with rewards and offers selected for you by Xiong Daxing Group Limited and/or participating merchants. To this end, Xiong Daxing and participating merchants may need to process and analyze your personal data in order to better understand your lifestyle, purchasing behavior, characteristics and needs. The relevant analysis results may be shared and used by Xiong Daxing Group Co., Ltd. and participating merchants;
F. Where appropriate or necessary, we will conduct a matching procedure (as defined in the Ordinance) on your personal data and use the obtained or matched data to take legal proceedings against you;
G. Provide you with details and information about the membership program on a regular basis;
H. For the normal administration, operation and maintenance of the Membership Program;
I. Design new services or improve existing services and conduct related research for Xiong Da Hong and participating merchants;
J. Investigate complaints and suspected suspicious transactions;
K. Prevention and detection of crime;
L. Disclosure of information in accordance with the law; and
M. Purposes related to the above.

When you conduct transactions with the Company or use this website, the Company will keep all your records. The Company's general policy is to keep the relevant information for a reasonable period of time.

3. Performance and analytics cookies We use performance and analytics cookies, primarily Google Analytics cookies and Hotjar cookies, to understand how users use our website. We collect information such as the parts of web pages clicked, the number of pages viewed, the length of each visit, and error messages (if any) in order to improve our web pages and provide users with a better experience. For more information about Google Analytics, please click here. For more information about Hotjar, please click here. For detailed information about the privacy policy of the Google Analytics service, please click here. For Hotjar's privacy policy, please click here. We have configured the Google Analytics and Hotjar services to mask the IP address of anyone visiting our website, thereby preventing us from identifying you.

4. Xiong Daxing and VIBRAM will keep your personal data confidential. However, Xiong Daxing may disclose and transfer your personal data to Xiong Daxing’s members, participating merchants, agents, contractors, Xiong Daxing’s telecommunications or other service providers, any other person under a duty of confidentiality to Xiong Daxing, and any actual or proposed assignee of the Membership Program or Skechers (whether in Hong Kong or overseas).

5. Use of Personal Data for Direct Marketing
A. Xiong Da Hong and VIBRAM have the right to use your personal data for the following direct marketing purposes:
(i) use your name, contact details, service and product portfolio information, lifestyle and purchasing behaviour which you may have stored in VIBRAM from time to time for direct marketing purposes;
(ii) promote the following services and products offered from time to time by Skechers and/or participating merchants: (1) consumer goods; and (2) footwear, clothing, apparel and accessories;
(iii) provide your personal data described in paragraph (i) above to any member of Skechers and/or participating merchants for use in direct marketing of the services and products described in paragraph (ii) above.
B. If you do not want Hung Tat Hong and VIRBAM to use your personal data for direct marketing purposes, you may contact our Customer Service Officer at vibram@hungtathong.com and indicate your name and membership number to opt out of receiving such direct marketing materials.

6. To ensure the accuracy of the personal information of members including contact information held by Xiong Daxing and VIBRAM, you may receive confirmation or verification requests from us. At the same time, you also have the following rights:

a. Check whether XIONGDAHONG and VIBRAM hold any of your personal data;
b. Check your personal data held by Xiong Daxing and VIBRAM;
c. Request Xiong Daxing and VIBRAM to correct any inaccurate personal data;
d. determine the policies and practices adopted by Xiong Daxing and VIBRAM in relation to personal data; and
e. Request to stop receiving promotional materials.

7. Turn off specific information collection tools: If you turn off specific information collection tools, you may not be able to use some features that make your experience more efficient, or some of our services and features may not work properly. Please be aware that our website may not recognize or respond to Do Not Track Headers on internet browsers.

8. Third-Party Tracking: We also work with other companies that use tracking technologies to serve ads on our behalf across the internet. These companies may collect information about your interactions with us, including advertisements. These companies may not recognize or respond to Do Not Track Headers from internet browsers. Please note that if you choose to opt out of these third-party tracking technologies, you may still see our ads on other websites, but those ads will not be created using tracking technologies by third parties associated with this website.

9. The Privacy Policy may be amended from time to time. You can determine when this Privacy Policy was last revised by referring to the "Last Updated" graphic at the top of this page. If you do not agree to the revised Privacy Policy, you should stop using this website and stop using Xiong Daxing and VIBRAM membership services.

10. In the event of any inconsistency or ambiguity between the English version and the Chinese version, the Chinese version shall prevail.