The following Privacy Policy covers our websites, garome.net, which is owned and operated by Garome Company Limited, a body corporate doing business in the Hong Kong Special Administrative Region of the People’s Republic of China (referred to as “GAROME”, “we”, “us”, or “our”). It is our goal to bring you information tailored to your personal interests but, at the same time, protect your privacy. Please read the following to learn more about our privacy policy.

By using GAROME site, submitting information or using any of our products and/or services, you are agreeing with and accepting the terms and the practices outlined in this Privacy Policy. If you do not agree with and accept this Privacy Policy, please do not use the GAROME site, provide information to us or use our products and/or services.

This Privacy Policy covers GAROME’s collection and use of any personal data that we gather when you are on the GAROME site and when you are using our services. Also, this Privacy Policy covers GAROME’s use of any personal data that our business partners may share with us. This Privacy Policy does not cover personal data (if any) that may be collected elsewhere, including without limitation offline and on other sites linked to and from the GAROME site as well as the practices of third parties that GAROME does not control or own, or individuals that GAROME does not employ or manage.

This Privacy Policy may be modified from time to time so check back often. Your continued access of the GAROME site or provision of your personal data to us or continued use of our products or services (as the case may be) following the posting of changes or revisions to the terms of our Privacy Policy will constitute your agreement with and acceptance of the changes or revisions to the Privacy Policy.

Introduction

Thank you for visiting thetinysmile.com. This Privacy Policy is written to better explain how we collect and use your personal data. This Privacy Policy is a binding contract and you must agree to it in order to use our services.

Personal Date You Provide To Us

The GAROME site generally collects personally identifying information (such as, for example, your name, email address, contact address, phone number, payment information, date of birth, etc.) with your specific knowledge and consent. This includes but is not limited to when you place orders with us, register for our newsletter and website, and complete a survey. You can choose not to provide us with certain personal data, but we may not be able to process your orders, transactions or applications, or you may not be able to take advantage of our special features.

Personal Data We Collect When You Buy From Us

In order for you to place an order with us, you must provide us your name, e-mail address, mailing address, Paypal information and telephone number etc. If you do not provide the required personal data to us or if the data provided is inaccurate, we may not be able to process your order. We will use your personal data to process your order and for the purposes as set out in this Privacy Policy, and we will not disclose any personal data that you provide to us except in accordance with the provisions of this Privacy Policy.

Automatic Information

Our servers may automatically collect automatic and/or aggregate information about your computer or electronic device when you visit our websites, including without limitation the website that referred you, Internet Protocol (“IP”) address, the type and configuration of the internet browser of your computer or electronic device, browsing preference such as language settings and font size, geo-location information and operating system of the computer or electronic device used for accessing our websites, and other usage and traffic information. GAROME Limited uses this automatic and/or aggregate information to analyze trends, gather and prepare statistics or demographic information and administer our websites so that we may provide improved web experiences to our users. Such automatic and/or aggregate information is not collected in a manner that would identify you personally. We may provide automatic and/or aggregate information, which is not personal data, to our partners about how our users collectively use our websites. We may share this information with our partners, so that they may further understand the usage of their areas and our websites, so that they too can provide you with a better web experience. There may also be occasions when we are legally required to disclose or provide access to our database in order to cooperate with police investigations or other legal proceedings or otherwise comply with any applicable laws or regulations, court order or lawful requests from any government authority. In those instances, the data is provided only for that purpose. For the avoidance of doubt, this Privacy Policy in no way restricts or limits our collection and use of such automatic and/or aggregate information.

Use and Provision of Personal Data

We may collect, use, store and provide your personal data for any of the following purposes, including:

• To enhance or improve user experience, the GAROME Site and/or our products and/or services, or to facilitate our performance of our services or any services offered by GAROME.

• To register, verify, process and maintain your account on the GAROME site.

• To process, verify, operate, manage, administer and maintain membership programs for our users, including but not limited to the GAROME VIP Membership Program, GAROME Referral Program, etc.

• To process your orders and/or transactions on the GAROME site and/or for our products and/or services.

• To conduct and process any contests, sweepstakes and/or surveys that we may from time to time organize in relation to the GAROME site, our business, products and/or services, and to announce the winners of the relevant contests and/or sweepstakes (as the case may be) on the GAROME site or any other medium/channels as may be required under the applicable laws.

• To communicate with you about changes/revisions to our Privacy Policy, Terms & Conditions, our websites or respond to inquiries.

• To send e-mails and/or other communications about our websites and/or other fashion, cultural content, art, music, design and/or lifestyle products and/or services, related news, or updates for Ka-pok.com, provided that we have obtained your explicit consent to do so.

• To detect, investigate, identify and protect against and/or prevent fraudulent transactions and other misuses of our websites and/or other activities on the GAROME site which may violate our Privacy Policy, Terms & Conditions or may be illegal.

• To enforce our Terms & Conditions and Privacy Policy

• To provide third party service provider(s) engaged by us to provide services for or in relation to the GAROME site, to process data on our behalf, to provide information technology support to us and/or conduct maintenance of our servers, data banks and databases, including but not limited to IT contractor(s), website analytic service provider(s), data processor(s) and service provider(s) for database management systems.

• To purchaser(s)/assignee(s) as part of any reorganization, merger, transfer or sale of our business.

• To comply with or as permitted by any applicable laws or regulations, court order or lawful request from any government authority.

Cookies

Cookies and Their Use On Our Website

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

• Make our website work as you'd expect

• Enable you to login to our members area, forums, and blog

• Remember your settings during and between visits

• Improve the speed/security of our website

• Allow you to share pages with social networks like Facebook and Twitter

• Personalise our website to you to help you get what you need faster

• Continuously improve our website for you

We do not use cookies to:

• Collect any personally identifiable information (without your express permission)

• Collect any sensitive information (without your express permission)

• Pass personally identifiable data to third parties

• You can learn more about all the cookies we use below, and find out more technical information about what cookies are at www.whatarecookies.com (or try an Internet search).

Granting Us Permission to Use Cookies

If the settings on your software that you are using to view our website (your browser) are adjusted to accept cookies, and you continue to use our website, we take it to mean that you accept our usage of cookies.

Note most Internet browsing software facilities disable cookies per website, and you are free to do this, but note that our website will not work as you would expect. For example, you will not be able to register as a member, log in to our members area, forums, or blog.

Our Own Cookies

Various functional elements of our website set cookies. These are to enable you to register as a member, login to our members area, forums, and blog.

We don’t set cookies to collect personal information without your express permission. We don’t use cookies to pass on personally identifiable data to third parties.

Social Website Cookies

So you can easily ‘Like’ or share our content by using the Facebook, Twitter, and other social network buttons we have included on our website.

Each social network button may set its own cookies and you can find out more on the relevant websites.

The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks and websites.

Anonymous Visitor Statistics Cookies 

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows which helps to identify when our website isn't working as it should for particular technologies), how long they spend on our website, what page they look at etc. This helps us to continuously improve our website. These statistics are all anonymous.

Third Party Websites

The GAROME site may contain links to third party websites, advertisers or services that are not owned or controlled by us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites, advertisers or services or their use of your personal data. If you access a third party website from our websites, you do so at your own risk and you understand that neither this Privacy Policy nor our Terms & Conditions apply to your use of such sites. We would encourage you to review the privacy policies and terms of use of any third party website, advertisers or service that you visit or use before providing your personal data to those third parties, and we shall not be liable in relation to your activities on or with those other third party websites, advertisers or services.

Third Party Access To Your Personal Data 

Without prejudice to the provisions in Clause 5 above, we endeavor to do our best to protect your personal data from being accessed by third parties. However, since we may employ outside maintenance personnel or use third party service providers to provide website, information technology and/or data processing services to us or to host our material, there are third party entities which may have custody or access to your information. Because of this, it is necessary that you permit us to give access to your personal data to such third party entities to the same extent that you authorize us to do so. For greater certainty, every authorization which you grant to us in this Privacy Policy, you also grant to any third party entities that we may hire, contract, instruct or otherwise retain the services of for the purpose of operating, hosting, maintaining, repairing, or otherwise improving or preserving our websites or its underlying files or systems, or for data processing on our behalf, or for providing information technology support to us, and/or for conducting maintenance of our servers, data banks and/or databases (as the case may be). To the fullest and maximum extent as is permitted under the applicable laws, you agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.

Additionally, we may store your personal data or share them with other third parties as set out in Clause 5 for the relevant purposes as set out in this Privacy Policy. Please refer to Clause 5 above for further information regarding our purposes of use and transfer of personal data and the relevant data transferees that may be involved. Without prejudice to the foregoing, the following is a non-exhaustive list of other entities that we may store, share, or transfer your information with in accordance with the provisions of this Privacy Policy:

• Google Analytics

• Google AdSense

• Parse.ly

• ComScore

• ChartBeat

Marketing and Communication

When registering for a GAROME account, you will be given the option to opt-in to receiving our promotional and direct marketing materials and/or updates through the GAROME newsletter and the GAROME’s ‘new in’ and promotional emails. If you would prefer to opt-out from these emails, you can do so at any time by using the unsubscribe link at the bottom of the e-mail.

We will also be using your personal data for our direct marketing. Please refer to Clause 5 above for further information regarding the relevant purposes of use of personal data for our direct marketing and the classes of marketing subjects concerned. We would use your personal data for direct marketing in accordance with the provisions of this Privacy Policy, and we will not use or provide your personal data to third parties for direct marketing unless we have obtained your explicit or written consent to do so (as the case may be) in accordance with the requirements of Hong Kong’s Personal Data (Privacy) Ordinance.

Law Enforcement

We may disclose your personal data to a third party to comply with or as permitted by any applicable laws or regulations, court order or lawful request from any government authority. In the event that we receive a subpoena affecting your privacy, unless there are any prohibitions/ restrictions under the applicable laws, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either.

Security of Information

We use SSL certificates to help secure the GAROME site. However, we make no representations as to the security or confidentiality of your personal data. You understand and agree that no transmission of data over the internet is guaranteed to be completely secure. It is in our interest to keep our websites secure, but we recommend that you use anti-virus software, firewalls, and other precautions to protect yourself from security threats.

California Online Privacy Protection Act

We are not located in California, but we do permit California residents to access our websites and order from us. It is our intent to comply with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the act. In summary, you must presume that we collect electronic information from all visitors. You may contact us at info@thetinysmile.com with any questions.

13. AMENDMENTS

We may amend this Privacy Policy from time to time, and the amended version will be posted on our website in place of the old version. We will also include the date that the currently displayed Privacy Policy took effect to help you determine whether there have been any changes since you last used the website. The changes in this Privacy Policy become effective as soon as the changes are published to the website. If you continue to use the website after the changes become effective, it will signify your agreement to be bound by such modifications or revisions.

If you do not agree with the revised/updated Privacy Policy, you must immediately cease using our website and service.

Severance If any provision of this Privacy Policy is held to be invalid or unenforceable for any reason by a court of competent jurisdiction, such provision shall be deemed to be severed from this Privacy Policy. Such unenforceability or invalidity shall not in any way affect the enforceability and/or validity of the remaining provisions of this Privacy Policy which shall continue in full force and effect.

Contact

Any inquiries about your rights under this Privacy Policy, or any other matters regarding your privacy, can be directed to info@thetinysmile.com. You have the right to request access to and/or correction of your personal data held by us. If you wish to make such a request, please contact us by email at garomeofficial@gmail.com and mark “Attention: Personal Data Access / Correction Request” on your correspondence.

We intend to use your personal data for direct marketing as set out in this Privacy Policy, however, we cannot so use your personal data without your consent or indication of no objection. Should you choose not to consent to such use of your personal data for direct marketing purposes, please indicate your objection by ticking the opt-out box below. You can also inform us through email or any written format at any time if you would like us to cease use of your personal data for any direct marketing purpose as stated in this Privacy Policy. Please note that if you have not checked the below opt-out box to indicate your objections to such direct marketing, but have clicked the below button to confirm you have read, understood, agreed and accepted the above, this constitutes your indication of no objection to our use of your personal data for direct marketing.