Privacy Policy

Your privacy is important to us. Kamakura Foods Ltd. (referred to as “Wada Bento”, “we”, “us” or “our”) is concerned to ensure that all data collected by Wada Bento is handled in strict compliance with the relevant provisions of the Personal Data (Privacy) Ordinance (Cap. 486).

This Privacy Policy is designed to assist users in understanding how we collect, use, disclose and/or process the personal data users have provided us through our website and through our vending machines, as well as to help users make an informed decision before providing us with personal data.

Provision of Personal Data

Personal Data means any data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable.

Wada Bento collects personal data provided by user to Wada Bento such as during account creation.

  1. Personal data supplied by customers may be used for any of the following purposes and/or for other purposes as may be agreed between our customer and us and/or as required by law:
    1. registering, operating or maintaining customer account with us;
    1. purchasing goods and/or subscribing for services rendered by us;
    1. facilitating and following up customer transactions with us, including but not limited to processing of any payment instructions, and customer enquiries to us;
    1. marketing of goods and/or services and/or upcoming events of us, our parent company and/or its respective subsidiaries and/or affiliated companies and/or our business partner;
    1. conducting data analysis and research to improve our products, services, advertising and customer communications;
    1. enabling us to comply with our obligations, to communicate with customers or to comply with industry practices; and/or
    1. serving any purposes relating to any of the foregoing.
  2. We will not store any personal details related to customers bank or credit or debit card or Octopus details used when purchasing goods through Wada Bento services. Payments for purchases will be completed through third-party payment platforms. Customer banking details will not be shared with Wada Bento.
  3. For purchases made through Octopus or credit or debit card, we store the card number used for the purchase to assess how often one customer purchases from Wada Bento services.
  4. We promise to implement appropriate technical and organisational measures for ensuring that only personal data which are necessary for each specific purpose of the processing are processed. We shall implement data protection impact assessment which include:
    1. consideration of how personal data will be processed and for what purposes;
    1. assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s);
    1. assessment of the risks to individuals in processing the personal data;
    1. use of techniques such as data minimisation and pseudonymisation will be considered where applicable and appropriate.
  5. We will not release personal data supplied by customers to third parties except in accordance with the Ordinance or in the event of such release is requested by:
    1. governmental and/or regulatory and/or statutory authorities and/or court orders in compliance with applicable laws; or
    1. third party service providers which provide supporting services to us; who (i) are under duty of confidentiality to us with respect to the use, hold, process, retain and/or transfer of personal data supplied by customers; and (ii) have the need to know or handle such personal data; or
    1. third party buyers or assignees in the event of a reorganisation, merger, or sale of us.
  6. Personal data supplied by customers may be provided to third parties for direct marketing activities (i.e. cross-marketing) only in accordance with the requirements set out under the Ordinance.

Non-personal Data

  1. We collect non-personal data when users visit and use our website, such data is entirely anonymous, and it is not practicable to identify the individual from the data. We use an independent third-party company to measure and analyse usage across our website.

The data is aggregated for statistical analysis to collect information on the usage of our website. 

  • We collect non-personal data when users visit and use our vending machines; such data is entirely anonymous and is not practicable to identify individual customers from the data. We use that data to measure and analyse customer purchasing behaviour. 

We analyse customer behaviour visiting or using our vending machines by using non-facial recognition-based video analysis. 

  • The technology we use extracts the information on customer behaviour from the video image in real-time.
    • The attributes about customers extracted from the non-facial-based video is limited to perceived age group. 
    • The video is at no point stored by Wada Bento, and the information collected is anonymous and does not enable us to identify individual customers. 
    • The information only provides us with anonymous information on customer purchasing behaviour.