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Privacy Policy

Privacy Policy


At Spud The Bear, we protect your personal privacy and continuously work to ensure that your personal data is protected when using our services.

This privacy policy explains how we collect and use your personal data. It also describes your rights and how you can exercise them. It is important that you read and understand the privacy policy and feel confident in our processing of your personal data. You are always welcome to contact us with any questions (you will find contact information at the bottom of this document).

The table below will help you navigate to those sections of particular interest to you.

  1. What is personal data?
    2. What is personal data processing?
    3. When do we process your personal data and what type of personal data do we process?
    4. Why do we process data about you?
    5. Legal basis for processing personal data
    6. How long do we store your data?
    7. Sharing of personal data
    8. How do we protect your personal data?
    9. Your rights
    10. Cookies
    11. Contact information

1. What is personal data?

Personal data is all information that can be directly or indirectly attributed to a natural, now living person. For example, images and sound recordings that are processed in computers can be personal data even if no names are mentioned. Encrypted data and different types of electronic identities (such as IP numbers) are personal data, if they can be linked to natural persons.

2. What is personal data processing?

Processing of personal data is everything that happens to the personal data. Every action taken with personal data is processing, regardless of whether it is performed automatically or not. Examples of usual processing are collection, registration, structuring, organizing, storing, processing, transfer and erasure.

3. When do we process your personal data and what type of personal data do we process?

For Spud The Bear customers
Information collected in connection with a purchase is required in order for you, as a consumer, to enter into a contract with Spud The Bear and to enable us to fulfil our obligations relating to a purchase.
The data we process is:

  • Name
  • Gender
  • Address
  • Email address
  • Telephone number
  • Payment details
  • Customer number
  • IP address
  • Details of your purchases
  • Information on how you use the Spud The Bear website

4. Why do we process data about you?

The personal data we process at Spud The Bear for you as a customer of ours are processed primarily in order to:

  • Fulfil our obligations to you as a customer. For example, complete goods purchases, invoice and provide support.
  • Fulfil shipping and warranty obligations.
  • Offer general customer care and customer service (e.g. answer questions and correct incorrect data).
  • Manage the customer relationship and provide our services.
  • Improve and develop our services, products and functions.
  • Conduct market research with the possibility of influencing offers and services.
  • Prevent the abuse of, or inappropriate use of, our services.
  • Fulfil obligations regarding competitions.
  • Comply with applicable legislation.
  • Administer and manage your personal account with Spud The Bear.
  • Provide information and customized marketing on the website, by email or by text message.
  • Enable communication with you as Subscriber, via email or text message.

5. Legal basis for processing personal data

This section describes the legal grounds and considerations upon which Spud The Bear bases the processing of your personal data.

Your personal data is processed, among other things, in order to fulfil an agreement with you as a customer, for example, to carry out goods purchases. It may be that the processing of your personal data is supported by consent from you. Your consent must be voluntary, specific, informed and involve unambiguous consent in order for it to apply as a legal ground. We collect consent from you as a newsletter subscriber so that we can manage tasks and obtain information about your purchases. Further, your behavior is stored on our website, your interest in our offers and products, as well as your interaction with Spud The Bear. This is in order to fulfil our commitment to providing you with personal offers and the goal of providing you with an experience that is customized specifically for you.

Some of the processing of personal data that we perform is based on a so-called balance of interest. This applies, for example, to the processing we carry out so that we can send relevant offers to you. This may involve a limited segmentation of customers based, for example, on purchasing behavior.

Spud The Bear does not process sensitive personal data based on balance of interest.

In some cases, Spud The Bear may have a legal obligation to process your personal data. This applies, for example, to the processing of personal data that we carry out so that we can meet the requirements of the Accounting Act.

6. How long do we store your data?

Spud The Bear stores your personal data for as long as the need exists to be able to fulfil the tasks for which they were collected. In some cases we may store the data longer if necessary to comply with statutory requirements or to safeguard Spud The Bear’ legal interests.

For you as a customer
Spud The Bear stores your data for a maximum of 24 months (two years) after you as a customer last interacted with us (conducted a purchase or other contact with us).

For you as an account holder
We store your data for as long as you have an account with Spud The Bear.

7. Sharing of personal data

Spud The Bear may disclose personal data to third parties. Examples of occasions when data may be forwarded to third parties is to a shipper in connection with the delivery of goods or a media agency for distribution of marketing. Our partners are: Facebook, Instagram, Twitter, Webtoons, YouTube, Google and SF Express.

Read more at Google: “How Google uses information from sites or apps that use our services“.

Spud The Bear may disclose your personal data if it is necessary to comply with applicable laws or government requirements, to safeguard Spud The Bear’ legal interests or to detect, prevent or pay regard to fraud and other security or technical issues.

Spud The Bear aims to only store personal data within Hong Kong. However, if personal data were to be transferred to a country outside Hong Kong, Spud The Bear ensures that the personal data is still protected in accordance with the laws and regulations governing the transfer of personal data to countries outside of Hong Kong.

8. How do we protect your personal data?

At Spud The Bear, we have taken technical and organizational measures to protect your data from unauthorized access, manipulation and loss. We continually adapt our security measures in accordance with the progress and development that is taking place in this area.

Only those persons who actually need to process your personal data in order to fulfil our stated purposes have access to them.

In the event of any personal data incidents, Spud The Bear undertakes to report this to the responsible regulatory authority (Data Inspection Board) without undue delay and within 72 hours of becoming aware of the incident. If such notification cannot be made within 72 hours, Spud The Bear will state the reasons for the delay in the notification and information will be given in batches without further undue delay.

Spud The Bear undertakes to inform you as soon as possible if you have been affected by a personal data incident and take the necessary precautions.

9. Your rights

Spud The Bear is responsible for the processing of your personal data in accordance with applicable laws and, at your request or on our own initiative, we will correct, anonymize, erase or supplement data that is found to be incorrect, incomplete or misleading.

You have the right to request:

  1. Access to your personal data
    You are entitled to request a register extract of the personal data that is registered about you and the processing we perform regarding your personal data. In the register extract you also have the right to receive information on where the data has been obtained if the personal data was not collected from you, the existence of automated decision making (including profiling) and the predicted period for which the data will be stored, or the criteria used to determine this period.
  2. Correction of your personal data
    At your request we will correct any incorrect or incomplete information we process about you as quickly as possible.
  3. Erasure of your personal data
    You are entitled to request that your personal data is removed. A prerequisite for this, however, is that they are no longer necessary for the purpose for which they were collected. Legal requirements may also exist that we cannot immediately delete your personal data in, for example, accounting and tax legislation. We will then end the processing that is done for purposes other than complying with the legislation.
  4. Restriction to processing
    This means that your personal data is marked so that they can only be processed for certain limited purposes. For example, you may request a restriction when you believe your data is incorrect and you have requested a correction in accordance with the section “Correction of your personal data” While the accuracy of the data is investigated, processing will be restricted.

If Spud The Bear has disclosed your information to third parties, we will notify you of any corrections or erasure of data as well as restriction on data processing.

If your personal data is stored by Spud The Bear, you are entitled to data portability. This means that, under certain conditions, you may request to remove and transfer your personal data in a structured, widely used and machine-readable format to another data controller.

If Spud The Bear’ personal data processing is performed on the basis of a balance of interests, you are entitled to object to this. In the event of an objection, Spud The Bear will only continue processing if there are legitimate reasons for processing that outweigh your interests. Spud The Bear bears the burden of proof as to whether such reasons exist.

As a registered person, you are entitled to file any complaints regarding the processing of your personal data with the Data Inspection Board.

10. Cookies

The cookies we use at Spud The Bear are there to improve the services we offer. Some of our services need cookies to work properly, while others improve the services for you. We use cookies for general analytical information regarding your use of our services and to save functional settings such as languages and other data. We also use cookies to direct relevant marketing to you.

If you want, your browser or device will allow you to change the settings for the usage and scope of cookies. Go to settings in your browser or device to learn more about adjusting the settings for cookies. Examples of what you can adjust include blocking all cookies, only accepting first-party cookies, or deleting cookies when you close your browser. Bear in mind that some of our services might not work if you block or delete cookies.

11. Contact information

If you have any questions about our Privacy policy, the processing of your personal data, or if you wish to request a register extract, please contact us.

Unit 115, 1/F,
Mirror Tower,
61 Mody Road
Tsimshatsui, Hong Kong

Telephone: +852 2754 1993


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