Privacy Policy

When you use TTI’s services, [1]you may provide us with your personal data. This TTI Group Privacy Policy (“Policy”) will help you understand how we collect, use and handle your personal data. It also describes your data protection rights, including your right to make data access and correction requests.

Please read this Policy carefully before furnishing us with any information about you or any other person.

Our Milwaukee Tool websites in various jurisdictions, which provide an online marketplace of tools and accessories, have their own privacy policies. If you provide any personal data on such websites, we recommend you take the time to read those policies as well.

This Policy is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.

If you are based in countries or regions outside Hong Kong during your interactions with us, please also refer to the applicable appendices.

This Policy was last updated on 10 May 2022.

 

[1] TTI” means Techtronic Industries Company Limited (Company Number: 151812) together with its related companies, including subsidiaries and affiliated companies.

Last updated: 10 May, 2022

At TTI, we are committed to protecting the privacy, confidentiality and security of your personal data. We pledge to comply with applicable data laws and regulations. In doing so, we are equally committed to ensuring that all our employees and agents uphold these requirements.

The laws of certain countries require us to provide you with additional information about our processing activities and we have included separate appendices to deal with these. In addition to this document, please refer to the appendices which apply to you.

We will notify you of any changes to this Policy, including by posting the updated version on our website. The changes will be effective from the date of posting.

Last updated: 10 May, 2022

We collect your personal data, that is, information (a) relating directly or indirectly to a living individual, (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained and (c) in a form in which access to or processing of the data is practicable; or such wider definition as provided in the applicable data laws and regulations.

In general, personal data we collect will include, without limitation, your name, email address, telephone number, media access control address, Internet Protocol (“IP”) address, credit cards, debit cards and other payment information, gender, date of birth, age, interests, geographical location, site usage (including browsing behaviour and activities), shopping and purchasing behaviour and other personal data you provide.

Last updated: 10 May, 2022

We set out in the following table the instances where we collect personal data directly from you, the types of personal data we collect and how we intend to use such data.

When we collect your personal data

Types of personal data

How we use your personal data

Visit and provide your personal data on the websites we own and operate (including https://www.ttigroup.com/)

When you visit our websites, we will record each of your visits and automatically collect the following information:

  • technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform; and
  • information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our websites (including date and time), products you viewed, searched for, filtered or purchased/redeemed, the hyperlinks you have clicked, the websites you visited before arriving at our websites, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the websites.

This information will be stored by us to administer our websites and for internal management, including troubleshooting, data analysis, testing, research, statistical and survey purposes and controlling illegal acts.

Purchase products at our store

When you make an order with us, through our physical stores, online stores or otherwise, we will collect personal data such as:

  • your personal details, including your name, company name, address, email address and phone number; and
  • your billing details, including your credit card information and billing address.

This information will be used by us to process your order, including arranging for product delivery, updating you on the delivery progress, verifying payment status and registering for product warranty.

Apply for a job with us and in the course of your employment

When you apply for a job with us (through email, by post or submit an application through our websites), you may be asked to provide personal data such as your name, telephone number, email address and correspondence address. We may also collect your resume, transcripts and reference letters, which may contain your personal data such as academic record, employment history and professional qualification. When you provide personal data of your referees to us, such as their names, company names, titles and contact details, you should have obtained their consent to act as your referees and provide such data to us.

Should you be offered a job with us, you may be asked to complete a form for employment which may require you to provide other personal data such as your Hong Kong identity card number / passport number and vaccination status. Further, in the course of your employment, should an update to your personal data in our record be required, we may collect additional personal data from you.

We collect your personal data to evaluate your job application, and should you be offered an employment with us, maintain our human resources record and attend to various human resources functions and activities.

Visit our premises

When you visit one of our premises, you may be asked to provide personal data such as your name, identity card number / passport number and health data such as vaccination proof.

We collect your personal data to maintain the security of our premises and ensure the health and safety of our staff members.

Subscribe for our newsletters and register for our events or campaigns

When you submit a form on our websites to subscribe for our newsletters or register for our events or campaigns, we may collect your personal data such as your name, telephone number, email address and correspondence address.

We collect your personal data to send you our newsletters and regular updates on our events and campaigns. This includes, without limitation, registering you for our investor-related events, activities and materials.

During marketing and other business events

We organise marketing, business development and other corporate events from time to time. During these events, we may collect your personal data such as your name, date of birth, telephone number, email address and correspondence address. In addition, we may, for the purpose of ensuring the health and safety of our participants, collect your health data such as vaccination proof.

We collect your personal data to record attendance, facilitate the event arrangement, send you event materials, contact you for feedback, deliver to you information about the Company, our products, services, events and campaigns, develop plans for future events and ensure the health and safety of our participants.

During your enquiry with our representative

When you make an enquiry with us, through telephone call, email, social media or otherwise, our representative may collect your personal data such as your name, date of birth, telephone number, email address, correspondence address and identity proof.

Please note for security reasons, our representative will not require you to provide your payment information (such as credit card details) and your full identity card number over telephone call, email or social media.

We collect your personal data to assist you with your questions, verify your identity and communicate with you if follow-up is required.

Complete our surveys and submit contact forms on our websites

When you complete our surveys, we may collect personal data such as your name, email address and correspondence address.

We collect your personal data to improve our products and services, contact you for further feedback, address your enquiries and handle any complaints you may have.

We occasionally collaborate with third-party service providers such as data analytics companies, advertising networks and cooperatives and your personal data provided to these third parties may be transferred to us. We endeavour to only collect personal data which is necessary and adequate but not excessive for the purpose of collection. It is generally voluntary for you to provide the personal data requested by us. However, failure to provide certain required personal data (usually marked with an asterisk (*) on the relevant forms) may result in us being unable to process your order or provide the service you request.Other than the specific uses of your personal data set out in the table above, personal data provided by you may also be used and retained by us (in electronic form and/or hard copy form or in any appropriate manner) for the following general purposes or other purposes as shall be agreed between you and us or as required by law from time to time:

  • to provide our services to you, including responding to any questions you may have and recommending our products or services;
  • to carry out our obligations arising from contracts entered between you and us;
  • to monitor the use of, and to improve and protect our websites, products, contents and services
  • to investigate complaints and suspicious transactions; to prevent and detect crimes;
  • to satisfy our legal obligations, including responding to requests by government or law enforcement authorities conducting an investigation;
  • to understand your preferences and behaviours in order to offer you a better user experience by the use of cookies and data sorting and analysis; and
  • to provide marketing materials to you (including regular communications from us with details of our products, services and relevant benefits and information), if you have given the necessary consent regarding direct marketing (please refer to the section “DIRECT MARKETING”).
Last updated: 10 May, 2022

We may from time to time use your personal data in order to send you marketing materials about, including without limitation, our products, services, offers, promotions, campaigns and events. Such direct marketing communications may be in various forms, including advertisements, special events notifications, newsletters or announcements, and delivered via various methods such as by email, SMS, WeChat/Whatsapp messages, notifications on your social media pages, in–app messaging and postal mail.

We may not use your personal data unless we have received your consent.

In addition, subject to your consent, we may transfer your personal data to our subsidiaries and affiliated companies such that they can share with you their marketing materials by electronic means (email, SMS and/or other media whether now known or available in the future) and/or by post. In any case, we will not share your personal data with third parties for gain.

You may opt out of receiving direct marketing communications at any time by post or email to our Data Privacy Officer (please refer to the contact details at the end of this Policy). Please state your full name and contact details. In the case of direct marketing emails, you may also opt out by clicking the unsubscribe link in such emails. We will then stop, and request our subsidiaries and affiliated companies to stop, sending any further marketing related emails to you. Please note that you may continue to receive direct marketing communications for a short period after changing your preferences while we and/or our subsidiaries and affiliated companies are updating our systems. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.

If we use your personal data in any direct marketing communications, you have the right to request that we provide you with the source of that personal data. There is no fee for requesting this information. We will provide you with the source of personal data unless it is impracticable or unreasonable to do so.

Last updated: 10 May, 2022

Personal data you provide to us may be disclosed or transferred (whether in Hong Kong or overseas, including the Mainland China, Macao Special Administrative Region, Taiwan Region, Indonesia, Singapore, Malaysia, Philippines, Australia, New Zealand, United States, Japan, South Korea, Vietnam and Thailand) to:

Category

Transferee

Among TTI Group Entities

Your personal data may be transferred to relevant persons in another TTI Group Entity.

 

Persons/other offices within the Company

Your personal data may be transferred within the Company.

 

Product delivery

Your personal data may be transferred to delivery service providers for sending to you the goods you order.

Payment

Your personal data may be transferred to our banks, credit card issuers, payment gateways or payment service providers to verify your payment details and status.

Other professional service providers

Your personal data may be transferred to agents, contractors and other third-party service providers who provide telecommunications, collection, credit reference, security, financial or other professional services to us.

Advertising networks

Your personal data may be transferred to Google, Facebook, Rakuten Marketing and other advertising networks for matching of your personal data with their database in order to send you our direct marketing materials through your Google and/or Facebook account(s).

Data processor

Your personal data may be transferred to agents, contractors or other third-party service providers which provide data processing or data storage services to the Company. In that case, the Company will adopt contractual and/or other means to ensure the data processors will take all practicable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and (ii) ensure that personal data will not be kept longer than necessary.

Data analytics and hackathon service providers and agencies

Your personal data may be transferred to data analytics and hackathon service providers and agencies to assist us in analysing user behaviour and activities and facilitate our event management. In most cases, only anonymized data will be transferred to these service providers.

Marketing (including digital marketing) and website analytic agencies

Your personal data may be transferred to marketing and website analytic agencies for display of advertising materials on our websites and other websites that you may visit, and analysis of your online behaviour and usage of our websites.

Parties and their representatives in a transaction

In the event the Company and/or any of the TTI Group Entities is involved in a merger, acquisition or due diligence exercise, your personal data may be transferred to a relevant outside party to the extent such data is reasonably required to decide on matters relating to the acquisition or merger. Examples of relevant outside party include the counterparty, their financial advisors, bankers and lawyers. Your personal data may also be transferred to new owners of the business.

Government departments, regulatory bodies and courts

Your personal data may be transferred to government departments, law enforcement, regulatory bodies and courts, to the extent permitted or required by applicable laws, rules, regulations, codes of practice or guidelines or pursuant to a court order.

Last updated: 10 May, 2022

All personal data you provide to us will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorized access or disclosure, accidental loss, alteration or destruction.

In addition, we will adopt contractual or other means to prevent any personal data transferred to our data processors (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorised or accidental access, processing, erasure, loss or use, if we are to engage any data processor.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Last updated: 10 May, 2022

We aim to retain your personal data no longer than is necessary for the fulfillment of the purposes of collection unless a longer retention period is required or permitted by applicable data laws and regulations.

We will take reasonable steps to ensure the accuracy of your personal data held by us. If we note that the personal data is inaccurate, we will not use such data and will notify any third party to which your personal data has been transferred regarding the same.

Last updated: 10 May, 2022

As a data subject, you are entitled to assert the rights of a data subject at any time. In particular, you have the right to:

  1. obtain information about whether or not and if applicable to what extent we process personal data concerning you;
  2. access information, in particular, the following information: stored data concerning you, purpose(s) of the processing, categories of data, recipients to whom we disclose data or duration of storage in the case of processing of personal data concerning you;
  3. require us to correct any personal data without undue delay which is inaccurate or incomplete;
  4. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;
  5. require us to delete or cease the collection, processing or use of your personal data without undue delay;
  6. withdraw your consent given vis-à-vis us concerning the processing of your data at any time;
  7. require the processing of your personal data be restricted; and
  8. receive the personal data concerning you which you had provided to us in a structured, standard and machine-readable format, and to transmit these data to another controller.

We may charge a reasonable fee for personal data access request.

All requests for access to or correction of personal data should be in writing and addressed to our Data Privacy Officer (please refer to the contact details at the end of this Policy). Our processing of your request may be conditional upon your completion of a data access request form at our request, which requires you to provide information such as “type of data” and “period covered by data”.

Last updated: 10 May, 2022

The websites of our TTI Group Entities use cookies which, among other things, help us to improve your experience of our websites and to ensure that they perform as you expect them to. For detailed information on how we use cookies and the purposes for which we use then, please refer to our Cookies Policy.

Last updated: 10 May, 2022

Our websites may contain links to other sites that are operated by third-party companies with different privacy practices. You should remain alert when you leave our site and read the privacy statements of other websites. We have no control over personal data that you submit to or receive from these third parties.

Last updated: 10 May, 2022

If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with our Data Privacy Officer by post or email:

Address: 29/F, Tower 2, Kowloon Commerce Centre, 51 Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong
Attention: Data Privacy Officer

Email: privacy@tti.com.hk

Last updated: 10 May, 2022

United States

This applies solely to all visitors who reside in the State of California and is presented in compliance with the California Consumer Privacy Act of 2018 (“CCPA”).

INFORMATION WE COLLECT

We are required to disclose to you the categories and sources of personal data we collect within the last 12 months. Please refer to the sections What information do we Collect? and How do we use this information, and what is the legal basis for this use? for details on the personal data we collect.

SHARING PERSONAL DATA/DO NOT SELL MY PERSONAL DATA

We may disclose your personal data to third parties for a variety of business purposes. Please refer to the Who will we share this data with, where and when? section for details.

We do not sell your personal data to third parties for their own marketing and advertising or other business purposes.

YOUR OTHER CALIFORNIA PRIVACY RIGHTS

Right to Know

You have the right to request us to disclose to you certain information about our collection of your personal data over the past 12 months. Upon receipt and confirmation of your verifiable customer request, we will disclose to you:

  • The categories of Personal Information we collected about you
  • he categories of sources from which we collected Personal Information about you
  • Our business or commercial purpose for collecting or selling such Personal Information
  • The categories of third parties with whom we share such Personal Information
  • The specific pieces of Personal Information we collected about you

Right to Request Deletion

You have the right to request us to delete Personal Information we collected from you. Upon receipt and confirmation of your verifiable customer request, we will delete such Personal Information from our records, unless it is necessary for us or our service providers to:

  • Complete the transaction for which such Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Use such Personal Data, internally, in a lawful manner that is compatible with the context in which you provided such Personal Information.

Right to access Personal Data

You may submit requests to exercise your rights in relation to your personal data to the email address set out in the How do I get in touch with you? section. We will seek to disclose and deliver to you the required information in accordance with the CCPA.

Right not to be discriminated against

We will not discriminate against you because you exercise your California privacy rights, and will not deny you goods or services, charge you a different price or rates for goods or services, or provide a lower quality of goods or services to you due to the exercise of such rights.

Last updated: 10 May, 2022

This Appendix applies if you are based in the European Economic Area (the EEA) during your interactions with us (other than where you are in the EEA solely for travel purposes).

WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING

In the case of customers or investors from the EEA, we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) contacting our Data Privacy Officer at privacy@tti.com.hk or sending your request by post to: Data Privacy Officer, Techtronic Industries Company Limited, 29/F, Kowloon Commerce Centre, 51 Kwai Cheong Road, Kwai Chung, Hong Kong SAR., or (b) in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.

WHO WILL WE SHARE THIS DATA WITH, WHERE AND WHEN?

If you are located in the EEA, where information is transferred outside the EEA, and where this is to a business partner or third party service provider in a country that is not subject to an adequacy decision by the EU Commission, data will be adequately protected by EU Commission approved standard contractual clauses, or third party or business partner’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to the contact mentioned in the section How do I get in touch with you below.

WHAT RIGHTS TO I HAVE?

If you are located in the EEA, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interest assessment, you can get in touch with us – or our Data Privacy Officer – using the details set out in How Do I Get In Touch With You. If you are located in EEA and have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

HOW LONG WILL MY DATA BE KEPT?

Where we process personal data for site security purposes, we retain it for 7 years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for 7 years from your last interaction with us.

Last updated: 10 May, 2022