DATA PRIVACY POLICY
Last Updated: 16 January 2025
This Data Privacy Policy (“Privacy Policy”) sets out how Bamboo Lifestyle & Dining Limited (“BLD”, “we” or “us”) collects, stores and handles “Personal Data” (i.e., any personal information that can be used to identify a living individual), which we may collect:
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through websites operated by us from which you are accessing this Privacy Policy, including www.primo-hk.com and other websites owned or controlled by BLD (“Websites”);
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through software applications (including automated tools and chat functionalities) made available by us for use on or through computers and mobile devices (“Apps”);
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through email messages that we send you that link to this Privacy Policy and through your communications with us online or in person;
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from third parties or other sources such as public databases, marketing partners, and other third parties; and
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when you visit as a guest at our restaurants or through other offline interactions (“Guest Interactions”).
Collectively, we refer to our Websites, the Apps, and Guest Interactions as our “Services”.
This Privacy Policy is intended to ensure you can make informed decisions about providing your Personal Data when purchasing our products, using our Services and communicating with us. For any comments or queries, please contact us in accordance with Section 5 (Contacting us) below.
Please note that our Services are not intended for Minors. By “Minors”, we mean: (i) users under the age of 18 years old; or (ii) in the case of a region where the minimum age for processing Personal Data differs, such different age. We do not knowingly solicit or collect Personal Data from Minors for any purpose unless such information are voluntarily provided or consented by a parent or a legal guardian. If you believe that we have Personal Data of a Minor without lawful consent, or if you are the parent or guardian of the user of a relevant Minor and wish to withdraw consent, please contact us in accordance with Section 5 (Contacting us) below.
By providing Personal Data to us, you agree to the processing and use set out in this Privacy Policy and have obtained corresponding authorisation (if required). If you do not agree to the processing of Personal Data in the way this Privacy Policy describes, please do not provide such data and stop using the Services.
We have organised and composed the Privacy Policy by major processes and scope of information processing so that you can easily browse the information of most interest to you.
1. How we collect and use Personal Data
3. How we transmit, protect, and store Personal Data
4. Your rights
6. Cookies
7. Changes to the Privacy Policy
8. Other sites
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1. How we collect and use Personal Data
1.1 This section provides more detail on the types of Personal Data we collect from you, and why.
​Personal information that you provide to us, or that we obtain from public channels, including your name, date of birth, gender, nationality, language preference, telephone number, email address and (residential and/or delivery) address and records of your trading history with us.
Social media account information: depending on your interactions with various social media platforms linked to us or with which we engage, we may process your social media profile names, account ID, photographs, posts, etc. that are publicly available.
We use this information to:
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administer, process and confirm your reservation requests (including correspondence relating to the same);
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provide you with and charge for Services and related information, including food and beverages;
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facilitate any special requests or assistance and to customise our Services (including products) to you;
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complete your orders; and/or
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to register and create your account for, or relating to, our Services in accordance with your request.
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We also use this information to handle any accidents (such as liaising with emergency services) and medical service requests, and to handle any claims made by customers.
We may use this information to:
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provide you with updates, offers, and subscriptions, special events, news and/or other marketing materials, in each case, relating to our Services or services or products of our shopping arcade partners; and/or
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tailor our marketing communication to you by determining what offers are most likely to be of interest to different categories of customers.
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Your payment information such as your credit card information (including credit card number, code and expiry date) and your bank account details.
We use this information to:
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administer, process and confirm your reservation requests (including correspondence relating to the same);
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provide you with and charge for Services and related information, including food and beverages;
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facilitate any special requests or assistance and to customise our Services (including products) to you; and/or
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to complete your orders.
If you contact us, via email, telephone or other means of communication, for any purpose (e.g., making enquiries in relation to a transaction with us), we may keep the correspondence on record.
We use this information to:
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administer, process and confirm your reservation requests (including correspondence relating to the same);
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provide you with and charge for Services and related information, including food and beverages;
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facilitate any special requests or assistance and to customise our Services (including products) to you.
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We also use this information to handle any accidents (such as liaising with emergency services) and medical service requests, and to handle any claims made by you or third parties.
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CCTV recordings: We may have close circuit television systems installed which will take visual and/or aural recordings where appropriate and relevant, and we may keep recordings as permitted by applicable laws.
We use this information to ensure the security of our properties, and, where applicable, to comply with our legal obligations.
We use this information to handle any accidents (such as liaising with emergency services) and medical service requests, and to handle any claims made by customers.
Survey Information: We may ask you to complete surveys that we use for research purposes. In such circumstances we will collect the information provided in the survey and use this to assist us in developing new services and products and to improve our existing services and products.
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Health-related information or preferences, such as allergies and health conditions that may be important to know in connection with the provision of food and beverages.
We use this information to provide you with Services in a manner that is suitable to your needs.
Information to satisfy your requests for related services: food and beverages preferences and requests (applicable to provision of food and beverages services).
We use this information to:
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provide you with and charge for Services and related information; and/or
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facilitate any special requests or assistance and to customise our Services (including products) to you.
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1.2 In general, we may use the Personal Data set out above to assure your future comfort and attention to your individual needs, and/or assist in developing new services and products and to improve our existing services and products. It is in our legitimate interest to continuously improve and develop our Services. In addition, we may use the above information to comply with our legal obligations, to safeguard our legal rights including (without limitation) in relation to the defence of any claims, and to cooperate with law enforcement agencies, government authorities, regulators and/or the court in connection with proceedings or investigations anywhere in the world. We are obliged to meet our legal obligations, and it is in our legitimate interest to safeguard our legal rights.
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1.3 There are several ways by which we may collect your Personal Data from you:
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we may collect your Personal Data from you directly by engaging with you, for example, through our Apps, when you make a direct booking on our Websites, or when you book or purchase our service or product in-person;
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we may also collect Personal Data from third parties, including agents and online service providers that make restaurant reservations on your behalf, facilitate online payments or purchases or that are otherwise involved in the reservations process or delivering our Services to you; and
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we may also collect Personal Data from you through your activity on social media platforms that link to us such as Facebook fan pages or WeChat Official Account, or when you share content, photographs or follow us. Please note that these social media platforms will have their own privacy policies and procedures governing the processing of your Personal Data.
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1.4 If you provide us with Personal Data about other individuals (e.g., family members), regardless of whether you are visiting the restaurant together, you must obtain such individuals’ authorisation or consent to provide us with their details and let them know where they can find a copy of this Privacy Policy.
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1.5 We may combine information that we have collected offline with information we collect online. We combine information across devices, such as computers and mobile devices. We may also combine information we receive from a third party with information we already have.
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2. How we share Personal Data
2.1 Only where necessary will we share your Personal Data with third parties. Situations where this may occur include the following:
(b) Third party service providers who process Personal Data on our behalf to help us undertake the activities described in the Section 1 â–º We may permit selected third parties such as service providers, agents and contractors to use your Personal Data for the purposes set out in Section 1 (How we collect and use Personal Data) above, including:
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specialised agents helping us to provide advertisements and promotional campaigns and events and analyse their effectiveness, to manage your communications and questions to us, to maintain the relationship with you, to provide personalised services for you, and to send marketing communications to you with your consent in advance;
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third party vendors helping us to deliver products or services to you, such as post offices and couriers;
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payment service providers and credit reporters helping us to assess your credit score, to verify your information (if and when this is required for signing certain contracts) and to process your online payment;
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third party vendors helping us to provide table management service and customer care; and
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consulting firms helping us to manage client relationship and to provide reports and analysis of market research and customer surveys.
(c) Law enforcement agencies, government authorities, regulators, and the court to comply with our legal obligations or to handle incidents/ claims â–º We may disclose your Personal Data when required by relevant laws or by court order or requested by other government or law enforcement authorities to assist with proceedings or investigations. In such circumstances, unfortunately, we may not be able to seek your consent to, or notify you in advance of, such disclosure.
(d) Third parties to safeguard our legal rights and property â–º We may disclose your information to third parties in order to:
i. enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
ii. detect, prevent or otherwise address security, fraud or technical issues; or
iii. protect the rights, property or safety of us, our customers, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
(e) Third parties who require such data in connection with a change in the structure of our business â–º We may also disclose your Personal Data to a prospective buyer, new owner or other third party involved in any of the following transactions or change to our business (including any negotiations regarding any such transaction or change): (i) sale, transfer, merger, consolidation or reorganisation of any part(s) of our business, or merger with, acquisition or formation of a joint venture with any other business; or (ii) sell or transfer any of our assets (in which case the Personal Data may be sold as part of those assets).
2.2 All third-party service providers providing services to or for us are prohibited from retaining, using or disclosing your Personal Data for any purpose except where strictly necessary for the Services (i.e., for the purposes described above).
2.3 This Privacy Policy does not apply to third-party service providers (e.g., table booking websites) who may collect personal information from you and may share it with us. In these situations, we strongly advise you to review the applicable third-party provider’s privacy policy before providing your personal information.
3. How we transmit, protect, and store Personal Data
Security of communications
3.1 We take commercially reasonable administrative (e.g., information security and access policies), technical, and physical safeguards designed to protect the Personal Data that we possess. Despite such efforts, however, please note that no company can fully eliminate risks or guarantee complete security of Personal Data. We cannot guarantee the security of your Personal Data transmitted through the Services or otherwise via the Internet – any transmission is at your own risk. Unauthorised entry or use, hardware or software failure, and other factors may also compromise the security of your information. Further, while we strive to put in place appropriate contractual protections, we are unable to guarantee the security of Personal Data hosted on databases run by third parties, and to the extent legally permissible, we bear no liability for uses or disclosures of personal information or other data arising in connection with theft of the information or other malicious actions.
3.2 We store certain customer information and reservation details in our customer information system and reservation system on our subcontractor’s secure servers. Our server resides behind various measures such as firewalls, authentication, access control, integrity protection, encryption and anti-virus tools designed to protect Personal Data collected from you against unauthorised or accidental access.
International Personal Data transfers
3.3 We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside Hong Kong to countries which have laws that do not provide the same level of data protection as Hong Kong.
3.4 Whenever we transfer your personal data out of Hong Kong to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the transfers between BLD to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent or taking into account adequacy assessments.
Storage of Personal Data
3.5 Your Personal Data will be stored for the period of time required to fulfil the relevant purpose described in Section 1 (How we collect and use Personal Data) above unless otherwise required or permitted by law. If information is used for two purposes, we will retain it until both purposes have been fulfilled, but we will stop using it for a purpose once that purpose is fulfilled.
4. Your rights
4.1 You may enjoy certain rights under applicable data protection laws in relation to your Personal Data that we hold. Some of these rights only apply in certain circumstances (as set out in more detail below). If you wish to exercise any of these rights, please reach out to us in accordance with Section 5 (Contacting us) below and we will handle your request in line with the applicable law and regulations.
(a) Access: you may ask us to provide you with access to your Personal Data and further details on the use we make of your Personal Data and who we share your Personal Data with.
(b) Correction: you may ask us to correct any inaccuracies in the Personal Data we hold about you.
(c) Complaint: if you are not satisfied with our use of your Personal Data or our response to any exercise of these rights, you may complain to the Privacy Commissioner for Personal Data in Hong Kong.
(d) Direct Marketing: You may choose to stop receiving personalised advertising or marketing promotions from us when using the Services by following the instructions of any marketing materials provided via email or by contacting us.
4.3 Where we act as a data processor, you should contact the data user to exercise any of your rights.
4.4 Notwithstanding the foregoing, we may from time to time send you announcements when we consider it necessary to do so (for example, when we need to inform you about maintenance, security or safety matters at our restaurant). These are essential system and Service-related announcements, and you are not able to opt-out of these notifications, which are not promotional in nature.
Updating information
4.5 We will use reasonable endeavours to ensure that your Personal Data is accurate. In order to assist us with this, you should notify us of any changes to your Personal Data that you have provided to us by contacting us in accordance with Section 5 (Contacting us) below.
5. Contacting us
5.1 If you have any questions about this Privacy Policy or our processing of your Personal Data, or otherwise want to exercise any rights you may have, please contact us at:
Address: Bamboo Lifestyle & Dining Limited, 8/F St George’s Building, 2 Ice House Street, Central, Hong Kong SAR
Phone: +852 2926 2888
Email: contact@bamboo-lifestyle-dinning.com
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6. Cookies
6.1 Our Websites and Apps use cookies and other technologies to distinguish you from other users of the relevant website. Cookies are small files which, when placed on your device helps us provide you with a good experience when you browse our Websites and also allows us to improve our Websites. For detailed information on the cookies that we use and the purposes for which we use them, please refer to our Cookies Policy.
7. Changes to the Privacy Policy
7.1 In the future, we may need to make changes to this Privacy Policy. All changes will be included in the latest Privacy Policy published on our Websites or Apps, so that you will always understand our current practices with respect to the Personal Data. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy. If required by the applicable laws and regulations, we will notify you of any major changes to this Privacy Policy. Unless otherwise required by the applicable laws and regulations, you will be deemed to have accepted and agreed the revised Privacy Policy then in effect by visiting our websites or using our services after such changes.
8. Other sites and languages
8.1 Our Websites or Apps may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you provide any personal information to such third-party websites.
8.2 Except as otherwise prescribed by law or as expressly set out, in the event of any discrepancy or inconsistency between the English version and any other language version of this Privacy Policy, the English version shall prevail.
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