Our Mission Statement
Pinkomate acknowledges the utmost significance of your Personal Information, especially considering the nature of our website and the products we offer. When you entrust us with it, we are obligated to safeguard it. Rest assured that our data handling policies and standards are in full compliance with the current data protection legislation.
Pinkomate adheres to all applicable data protection laws, including the General Data Protection Legislation (“GDPR”), the GDPR as incorporated into HK law via section 3 of the HK European Union (Withdrawal) Act 2018 and the HK Data Protection Act 2018 (collectively, “HK Data Protection Laws”), and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

I. Introduction
We have formulated this policy to ensure complete transparency regarding how we gather, utilize, and store your information. The privacy policy, subject to occasional amendments (“Policy”), details the types of personal information we may collect or that you may provide when using our Pinkomate.com website (“Website”), the products available thereon (“Products”), or in connection with our services (collectively, along with the Website and the Products, the “Services”), as well as our practices for collecting, using, protecting, and disclosing such personal information. When you access the Website, we may request information that can identify you personally, such as, but not limited to, name, postal address, email address, telephone number, mobile device identification number, or any other identifier for online or offline contact (“Personal Information”), or information related to you that does not individually identify you.

What We Do and Don't Do...
(a) We utilize your Personal Information to offer you excellent customer service, which involves customizing the information shared with you to ensure its relevance, usefulness, and timeliness.
(b) We respect your privacy and strive to meet strict regulatory requirements.
(c) We take extra measures to protect your Personal Information.
(d) We do not sell your Personal Information to third parties; however, certain third parties (such as online advertising services) may collect your Personal Information via automated technologies, and under some U.S. data protection laws, this may be regarded as a “sale” of personal data.

II. What This Policy Contains:
This Policy addresses the following crucial aspects related to your information (click on the links for more details):
III. Overview
IV. Policy
1. How we obtain your Personal Information;
2. Collection of your Personal Information and how we use it;
3. Legal basis for the use of your Personal Information
4. How and why we share your Personal Information with others;
5. How long we store your Personal Information;
6. Your rights;
7. State Privacy Rights
8. Chatbots
9. Session Replay
10. Children
11. Marketing;
12. Risks and how we keep your Personal Information secure;
13. Links to other websites;
14. Changes to this Policy; and
15. Further questions and how to make a complaint.

III. Overview
Who We Are: We are Pinkomate Group, and we serve as the data controller of your Personal Information. All references in this Policy to “Pinkomate”, “our”, “us” or “we” pertain to Pinkomate Limited and may include its subsidiaries and affiliates as context demands. All mentions of “our Website” refer to the website owned by Pinkomate Limited at www.Pinkomate.com.
Our Values and What This Policy Is For: We value your privacy and aim to be accountable, fair, and transparent in our collection and use of your Personal Information. We also want you to be aware of your rights concerning your information, which are detailed in this Policy. In line with these values, this Policy outlines what you can expect when we collect and use your Personal Information. To assist you in finding the most relevant information and understanding our relationship with you, we have designed our Policy for easy navigation. We are constantly seeking to enhance the information provided to our customers and Website users. If you have any feedback regarding this Policy, please inform us using the contact details in Section IV.15.
Who This Policy Applies To:
This policy applies to:
- Visitors to our Website;
- Persons participating in a Campaign (as defined below); and
- Customers who create an account with us.
Depending on your relationship with us, we may collect and use your information in diverse ways. Click on the links in Section II. to learn about the information we collect and how we use it.
Your Right to Object:
You possess various rights regarding our use of your Personal Information, as detailed in Section III. 6. Two fundamental rights to note are:
- You may request us to cease using your Personal Information for marketing purposes. Upon exercising this right, we will halt such use.
- You may ask us to consider any valid objections you have to our use of your Personal Information when we process it based on our or another person's legitimate interest.
What You Need to Do and Your Confirmation to Us:
Please read this Policy carefully to understand how we handle your Personal Information. By engaging with us in the manners described in this Policy, you confirm that you have read and understood the entire Policy as it pertains to you.

IV. Policy
1. How We Obtain Your Personal Information
1.1. Information That You Provide
You may furnish us with Personal Information about yourself by:
- Utilizing online forms on our Website;
- Establishing an account with us;
- Purchasing product(s) from our Website;
- Using the Pinkomate forum on our Website;
- Using the chatbot on our Website;
- Entering a competition, promotion, give-away, survey or other campaign on our Website or elsewhere (each a “Campaign”);
- Contacting us via phone, email, or other means.
This includes instances where you provide your Personal Information to receive products, deliveries, information, or services from us.
1.2. Information That We Collect Automatically
When you access our Website or use the Services, technology may be employed to automatically gather certain information, including, but not limited to:
Usage Details. When you access and use the Services, we may automatically record specific details of your access and usage of the Website, such as traffic data, location data, logs, other communication data, and the resources you access and use on or through the Website. This may encompass the full Uniform Resource Locators (URL) clickstream to, through, and from our Website (including date and time); products you viewed or searched for; page response times; download errors; length of visits to particular pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to navigate away from the page.
Device Information. We may collect data about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, time zone setting, browser type, browser plug-in types and versions. Web servers, which serve web pages, identify your computer by its IP address. As permitted by applicable law, we collect IP addresses for system administration, gathering and analyzing aggregated information, enhancing user experience, and auditing site usage.
Stored Information and Files. The Website may also access metadata, tags, and other information associated with files stored on your device, such as photographs.
1.3. Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
Cookies (or mobile cookies). Refer to Section IV. 2.2 of this Policy or our Cookie Policy for more details.
Web Beacons. Pages of the Website or our emails may contain small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs) that enable us, for example, to count users who have visited those pages or opened an email and gather other related statistics (such as recording the popularity of certain content and verifying system and server integrity).

Collection of Your Personal Information and How We Use It
Navigate to the relevant section(s) below based on our relationship with you to discover the Personal Information we collect and how we use it.
2.1 Visitors to Our Website
(a) What Personal Information We Collect About You
We may gather and use any of the following information about you:
(i) Your name;
(ii) Your email address;
(iii) Your telephone number;
(iv) Information provided when you communicate with us or use our Website tools;
(v) Usage details, device information, and other automatically collected information as described above (this Personal Information is generated and recorded automatically when you visit our Website).
(b) How We Use Your Personal Information
We collect, use, and store the above-listed Personal Information for the following purposes:
i) To enable you to access and use our Website (including protected areas);
(ii) For the improvement and maintenance of our Website and to provide technical support;
(iii) To ensure the security of our Website;
(iv) To recognize you upon your return to the Website, store information about your preferences, and customize the Website according to your individual interests;
(v) To evaluate your visit to the Website and prepare reports or compile statistics to understand the types of users, their usage patterns, and to make the Website more user-friendly. Such details will be anonymized to the extent possible, and you will not be identifiable from the collected information; and
(vi) To address any inquiries or issues you have regarding our Website, products, and services. If we do not have a contract with you, we may process your Personal Information for these purposes when it is in our legitimate interests for customer service.
See Sections 2.7 and 2.8 for more details on how we use your Personal Information.
2.2. A Word About Cookies
(a) Some pages on our Website use cookies, which are small text files, often encrypted for privacy, sent to your browser by the visited website. For example, the information includes the products you added to your basket and your preference for viewing products as 'what's new' or 'what's best-selling'.
(b) We use cookies to track your current shopping session, allowing you to retrieve your shopping basket at any time, personalize the Website's content, and ensure a consistent experience. We also use cookies to monitor how visitors interact with the Website to assess our performance.
(c) You can block cookies on our Website at any time. To do so, activate the browser setting that permits you to reject all or some cookies. However, if you block all cookies (including essential ones), you may not be able to access all or parts of the Website or use all its functions.
(d) For detailed information on the cookies we use and their purposes, refer to our Cookie Policy here.
2.3. Customers Who Create an Account with Us
(a) What Personal Information We May Collect About You
We may collect and use any of the following information:
(i) Your name;
(ii) Your postal address;
(iii) Your email address;
(iv) Your telephone number;
(v) Your IP address;
(vi) Your age;
(vii) Your gender;
(viii) Your day of birth;
(ix) Your anniversary;
(x) Your sexual preference;
(xi) Your relationship status;
(xii) Your credit/debit card details;
(xiii) Information provided when you communicate with us (such as reporting an order or account issue);
(xiv) Any updates to the provided information;
(xv) Information you post on the Pinkomate Forum;
(xvi) Information you provide when entering a competition, promotion, or survey;
(xvii) Information about your account and associated services we provide;
(xviii) Information required to offer our services (including account opening forms, order details, order history, and payment details);
(xix) Customer services information; and
(xx) Customer relationship management and marketing information.
(b) How We Use Your Personal Information
We collect, use, and store the above-listed Personal Information for the following reasons:
(i) To provide you with our services as an online retailer;
(ii) To facilitate product deliveries;
(iii) To handle any inquiries or issues regarding our Website, products, services, and your orders;
(iv) To verify your identity;
(v) To send you consented communications (via email, SMS, or telephone) about our products and services, such as administrative messages (e.g., changes to terms and conditions and this Policy); and
(vi) If you have consented, we may contact you via email with information about our products and services of potential interest.
See Sections 2.7 and 2.8 for more details on how we use your Personal Information.
2.4 People Who Participate in a Campaign
(a) What Personal Information We May Collect About You
We may collect and use any of the following information:
(i) Your name;
(ii) Your postal address;
(iii) Your email address;
(iv) Your telephone number;
(v) Your bank account;
(vi) Your age and/or date of birth;
(vii) Your profession;
(viii) Your opinion on our products or other topics;
(ix) Any other information specified in the Campaign rules, as applicable.
(b) How We Use Your Personal Information
The primary purpose of data processing is to verify your eligibility to participate in the Campaign and, if you win a prize or are entitled to a gift, to send or transfer it to you. The Rules may stipulate additional purposes.
We process your data for these purposes based on your meaningful and express consent. You can revoke your consent at any time, with future effect, using the provided contact information. Note that if you revoke consent during an ongoing Campaign, your application will no longer be considered, and you will lose the chance to win a prize.
Based on your consent, we will also use your data to send you information about products, services, events, and other relevant information about the sponsor(s) and/or Pinkomate. If you do not wish to receive further marketing promotions, you can revoke your consent at any time, with future effect, at GDPR@pinkomate.com.
2.5. Special Categories of Data.
Some of the Personal Information we collect or that you provide may fall into special categories, such as information about your sex life or sexual orientation. We handle such special categories of data with enhanced care.
2.6. Information We Need to Provide Services to You.
We require certain types of Personal Information to offer you services and fulfill our contractual and other legal obligations. If you do not provide or request deletion of such information, you may lose access to our services.
2.7 Regardless of Our Relationship with You, We May Also Collect, Use, and Store Your Personal Information for the Following Additional Reasons:
(a) To handle any inquiries or issues you have regarding our collection, storage, and use of your Personal Information, or any requests for a copy of the information we hold. If we do not have a contract with you, we may process your Personal Information for these purposes when it is in our legitimate interests for customer service;
(b) For internal corporate reporting, business administration, ensuring proper insurance coverage, safeguarding company facilities, research and development, and identifying and implementing business efficiencies. We may process your Personal Information for these purposes when it is in our legitimate interests;
(c) To comply with applicable procedures, laws, and regulations, which may include when we reasonably deem it in our or others' legitimate interests to comply, as well as when legally required; and
(d) To establish, exercise, or defend our legal rights, which may include when we reasonably consider it in our or others' legitimate interests, as well as when legally required.
2.8 Further Processing
We will not use your Personal Information in a manner inconsistent with the purposes outlined in this Section 2. Contact us using the details in Section 15 if you seek further information on the analysis we conduct to determine if a new use of your Personal Information is compatible with these purposes.

Legal Basis for the Use of Your Personal Information
3.1 We Consider the Legal Basis for Using Your Personal Information as Outlined in This Policy to Be as Follows:
(a) Our use of your Personal Information is necessary to fulfill our obligations under any contract with you (e.g., to complete an order you placed); or
(b) Our use of your Personal Information is essential for complying with our legal obligations (e.g., if regulatory bodies or law enforcement agencies request information sharing); or
(c) When neither (a) nor (b) applies, using your Personal Information is necessary for our or others' legitimate interests (e.g., to ensure Website security). Our legitimate interests include:
(i) Operating our business;
(ii) Maintaining and securing our Website;
(iv) Serving our customers, receiving payment, and providing customer service; and
(v) For internal group administrative purposes.
If we rely on our (or another person's) legitimate interests for using your Personal Information, we will conduct a balancing test to ensure our (or the other person's) legitimate interests do not override your interests or fundamental rights and freedoms requiring protection of the Personal Information. You can request information on this balancing test using the contact details in Section IV.15.
3.2 We May Use Your Special Categories of Data (Such as Sex Life or Sexual Orientation) When You Have Provided Your Consent (Which You Can Withdraw at Any Time After Giving It, as Described Below).
3.3 We May Process Your Personal Information for Marketing Purposes in Some Cases Based on Your Consent (Which You Can Withdraw at Any Time After Giving It, as Described Below).
3.4 If We Rely on Your Consent for a Particular Use of Your Personal Information and You Later Change Your Mind, You Can Alter the Cookie Preferences Here or Withdraw Your Consent by Contacting Us at GDPR@pinkomate.com.

How Will We Share Your Data?
4.1 We May Share Your Personal Information with Our Group Companies When It Is in Our Legitimate Interests for Internal Administrative Purposes (Such as Corporate Strategy, Compliance, Auditing and Monitoring, Research and Development, and Quality Assurance).
4.2 We Will Share Your Personal Information with Our Affiliates, Subsidiaries, and Service Providers to Deliver the Services as Outlined Above, Which Include, but Are Not Limited to:
(a) Website services providers who assist in hosting and administering our Website;
(b) Email services providers;
(c) Delivery services providers (such as Royal Mail) for order delivery and sending tracking notifications, as well as returns services providers;
(d) Trustpilot, with whom we collaborate closely to maintain our independent reviews database;
(e) Our other service providers and subcontractors, including payment processors, technical and support services suppliers, insurers, logistic providers, and cloud service providers; and
(f) Analytics and search engineproviders that assist us in the improvement and optimisation of our Website.

4.3 Any third parties with whom we share your Personal Information are limited (by law and by contract) in their ability to use your Personal Information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your Personal Information are subject to privacy and security obligations consistent with this Policy, industry standards and applicable laws.

4.4 We will also disclose your Personal Information to third parties:

(a) where it is in our legitimate interests to do so to run our business:
(b) if we sell or buy any business or assets, we may disclose your Personal Information to the prospective seller or buyer of such busin