Privacy Policy – Watsons Australia
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Last Updated: March 2025
Our Privacy Principles
AS Watson Retail (HK) Limited (“Watsons” or “we” or “us” or “our”), is a member of the AS Watson group of companies (“ASW Group”), which is part of the multinational conglomerate CK Hutchison Holdings Limited and its affiliated or related companies (“CK Hutchison Group”). We take your privacy seriously. Here are our 5 privacy promises to you:
1. We will ALWAYS ensure that your personal information is used in line with applicable data protection laws.
2. We will ALWAYS be transparent with you about how we use your personal information. This includes informing you about what information we collect, what we do with it, with whom we share it and who you should contact if you have any concerns.
3. We will ALWAYS provide you simple options to say 'STOP' when you are no wish to receive our marketing communications.
4. We will ALWAYS take all reasonable steps to protect your personal information and make sure no unauthorized person accesses it.
5. We will ALWAYS respond to any questions on processing of your personal information without undue delay.
Our Privacy Policy
We are committed to safeguarding your privacy rights and ensuring that your personal information is protected.
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This Privacy Policy explains the types of personal information we collect and how we process and protect that data in connection with the services we offer. This includes information collected offline in our stores or through our customer services, and online through our websites, applications (including mobile apps) and third party platforms (together referred to as “Sites”).
This Privacy Policy also applies to our targeted or personalised content, including online offers and advertisements for products and services, which you may see on third party websites, platforms and applications (“Third Party Sites”) based on your online activity. These Third Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third Party Sites.
1. WHO IS RESPONSIBLE FOR WHAT HAPPENS WITH YOUR DATA?
We are responsible for processing your personal information on our Sites.
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2. HOW DO I MAKE ENQUIRIES ABOUT MY PERSONAL INFORMATION?
If you have a question in relation to how we process your personal information you can contact our Privacy Office via email watsons_cs_eservice@asw.com.hk.
3. WHAT IS PERSONAL INFORMATION?
Personal Information generally refers to information that can directly or indirectly identify you ("Personal Information"). This typically includes information such as your name, address, email address, and telephone number, but can also include other information such as IP address, shopping habits, information about health and beauty, information about your lifestyle or preferences such as your hobbies and interests. Information about health are called “special categories of Personal Information” that require special protection because of their sensitivity.
4. WHAT HAPPENS WHEN YOU PROVIDE US WITH YOUR PERSONAL INFORMATION OR WHEN WE OTHERWISE RECEIVE YOUR PERSONAL INFORMATION?
We collect your Personal Information directly in a number of ways, for example when you provide us with your information to register as a customer for our Sites or as a member of any of our loyalty programs, register for prize draws, games or competitions, subscribe to our newsletter, receive information or mailings, use our applications, buy a product or service from us, complete a survey, complete a beauty or health diagnostic test, make a comment or enquiry or contact our customer services.
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When you provide us with your Personal Information, we will process it in accordance with this Privacy Policy. If you do not wish us to process your Personal Information in this way, please do not provide us with your personal information.
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We may also receive your Personal Information from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties. If you do not want us to receive your Personal Information from other sources, please communicate your preferences directly with the relevant sources.
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We process your Personal Information to provide you with our services as further explained below. In certain instances, we only process your Personal Information if you have given us permission to do so, for example in most cases where we process your Personal Information for marketing purposes, use Cookies (as defined in Clause 6.2 below) or location data or where we process your sensitive personal information. In other instances we may rely on other legal grounds for processing your Personal Information, such as performance of the contract with you or legitimate interests, like fraud prevention.
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If you become a member of any of our loyalty programmes, we may infer in a transparent manner - and only where permitted by applicable law - that you would like us to process your Personal Information for marketing purposes. You can always opt out of marketing communications without detriment to your loyalty benefits.
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Where we process your Personal Information on the basis of your consent, we will ask for your consent explicitly and only for a particular purpose. We will also ask you to provide additional consent if we need to use your Personal Information for purposes not covered by this Privacy Policy.
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Please refer to Section 6 of this Privacy Policy for details of the various types of Personal Information we may collect, the relevant purposes and the legal basis for such processing.
5. WHAT HAPPENS IF OUR CUSTOMER IS A CHILD?
Our Sites are intended for adults, but there could be instances where some customers under the age of 18 view or purchase products on our Sites. If we know that a customer is under the age of 18, we will not use such customer’s Personal Information for marketing purposes unless parental consent is provided to us.
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To provide parental consent to marketing, please ask your parent or guardian to call or write to Watsons’ contact details as listed in Section 2 (applicable to loyalty card or online account members only).
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In some cases, we will infer from your actions that you obtained parental consent. We then reserve the right to decide whether you will receive our marketing until you reach the eligible age.
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Note however that access to certain parts of our Sites and/or eligibility to receive prizes, samples or other rewards may be limited to users over a certain age. We may use your Personal Information to carry out age verification checks and enforce any such age restrictions.
6. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL INFORMATION?
6.1 We process the following categories of Personal Information for the following purposes:
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6.2 We process the following categories of Personal Data for direct marketing purposes (only where we have already obtained your prior consent or indication of no objection to do so):
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For the purposes of this Privacy Policy, the term “Retail Goods or Services” comprises means the sales of goods or provision of services in relation to any of the following (whether through physical or online channels): food, water & beverages, restaurants, catering, groceries, houseware & household products, general merchandise, health & beauty, lifestyle, pharmaceuticals, medical and healthcare services, online consultation services, fragrance & cosmetics, baby products, wine and liquor, cigarettes and cigars, stationery, books and paper products, confectionary, toys, clothing, shoes, textiles, fashion accessories, eyewear, bags & luggage, jewellery, watches, furniture, plants and accessories, office supplies, sports & leisure equipment, phones & mobile devices & related accessories, electronics & electrical appliances, computer software & games, music, pet products, pet care and veterinary services, fuel, motor vehicle services, photography and printing services, educational products and services, wellness and bodycare products, extendible product warranty protection or similar loss or damage protection, SIM card sales and subscriber subscription or pre-paid or post-paid telecommunications services, bill acceptance, telecommunications products and services and/or any ancillary or supplemental products and services.
6.3 Cookies and Similar Technologies
We use cookies, pixel tags, web beacons and similar technologies (together referred to as “Cookies”) to improve our products and your experience on our Sites by collecting information on how you use our Sites. Some of the Cookies we use are required to enable core site functionality, for example to provide secure log-in or to remember how far you are through an order,but we also use Cookies that allow us to analyze site usage (so we can measure and improve performance), and advertisement Cookies which are used by advertising companies to serve ads that are relevant to your interests.
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We may also tailor our Sites and our products to your interests and needs, by collecting information about your device and linking this to your Personal Information so as to ensure that our Sites present the best experience on our Sites for you. The types of data we may collect from you when you visit the Sites include:
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​• information about the mobile device used and the characteristics of such mobile device;
• information about the type of browser you use;
• details of the web pages you have viewed;
• your IP address;
• the hyperlinks you have clicked; and
• the websites you visited before arriving at our Site.
Our websites are initially set up to accept Cookies. You can opt-out of or delete historical cookies by changing the settings on your web browsers; however, if you do so, you may find that certain features on our website and/or our app do not work properly
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6.4 About using our Sites
When you choose to use access or download our Sites or allow connectivity via Wi-Fi connections to your device, we receive information about your location and mobile device, including a unique identifier for your personalised device, your GPS data or wireless networks data (WLAN). Location data is neither stored nor transmitted to third parties. If you agree with the localisation function and/or enable the notifications function on your device mobile, we can provide you with location-based services including advertising, search results and personalised content. When you are near one of our Stores, then we can use push email communications or notifications (such as recommended promotion and recommended products) to you based on your geo-location data services and/or immediately previous on-line activities if you have provided your consent to receive such communications and advertising.
Most mobile devices allow you to turn off location services and push notifications on your device. Should you wish to do so, please access your own device and vary the settings for notification on your device to reflect your own preference to be notified (or not) following the relevant instructions under your device.
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7. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymised or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your Personal information) with third parties who may or may not be located overseas, as detailed in this section. By using our Sites, you agree to allow us to share your Personal information with third parties and to the cross-border transfer of your Personal Information in accordance with this section. Regardless of where we store or process your Personal Information, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.
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7.1 Partners
Your Personal Information may be shared with our trustered business partners (“Partners”) to facilitate the processing of loyalty points issuance and redemption and related transactions, as well as for data analytics purposes in order to improve their operations, services or products.
Please be aware that our Partners may themselves directly collect Personal Information from you if you give it to them when you purchase any goods or services at their store, or if you register with them as a customer. The handling of your data collected by our Partners will be governed by the relevant Partner's separate privacy policy (and not this Privacy Policy), and we are not involved or responsible for the collection and handling of such data.
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7.2 ASW Group and CK Hutchison Group
Your Personal information may be transferred to any members of AS Watson Group and/or CK Hutchison Group for any of the purposes we have set out in Section 6 above. However, we will not provide your Personal information to any member of AS Watson Group and/or CK Hutchison Group in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.
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7.3 Our service providers
Your Personal information may be shared with our service providers (including agents and contractors) which process Personal information on our behalf to help us administer and operate our business and our Sites to conduct data analytics, to help aggregate and anonymise the personal information, or to carry out any of the purposes set out in Section 6 above. These may include IT vendors, back-office and front-end or ancillary service providers, logistic and delivery service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on our behalf for any of the purposes set out in Section 6 above.
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7.4 Professional advisors and assignees
When necessary, we may share your Personal information with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your Personal information may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.
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7.5 Government and regulatory authorities
We will disclose your Personal information to courts, law enforcement, regulatory or other governmental agencies if we are required to do so by law, or by a warrant, subpoena or court order.
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7.6 Other recipients
We will transfer your Personal information in the following scenarios:
a) To data analytical firms, such as Google Analytics Inc. (to the extent that such Personal information is not aggregated or anonymised);
b) in an emergency, such as life, health or property of an individual; and/or
c) with your consent to proceed to share your Personal information with third parties where required by law.
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8. TO WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL INFORMATION?
Many of our trusted third parties and Group companies are based in countries that provide an adequate level of data protection, such as the European Economic Area ("EEA"), Singapore and Hong Kong to ensure your Personal Information are safeguarded with sufficient protection at a level as required by our own standards.
When we need to transfer your Personal Information to a trusted third party or Group company based in a country where data protection laws are considered not to offer the same level of protection, we ensure adequate data protection safeguards by relying on other legitimate means, such as the Privacy Shield certification and/or Standard Contractual Clauses.
More details on the transfer mechanism can be obtained from our Privacy Office (see contact details in Section 2).
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9. HOW LONG DO WE PROCESS YOUR PERSONAL INFORMATION?
We will store your Personal Information only until the aforementioned purposes for which we have collected or received your Personal Information are fulfilled and once our statutory obligations to preserve records have expired as further described in Section 5.
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10. WHAT ARE YOUR RIGHTS?
If certain requirements are fulfilled and subject to applicable local laws, you have the right to:
• obtain from us confirmation as to whether or not we process Personal information from you and, where that is the case, access to your Personal information;
• rectification of inaccurate Personal Information
• request the erasure of Personal Information
• withdraw your consent for marketing communications (by logging into your account under “Marketing Preferences” or using the unsubscribe link in any of our marketing communications); and
• withdraw your consent for use of Cookies (via adjusting the setting under your web browser)
11. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We maintain appropriate technical and organizational measures to protect the Personal Information you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Information.
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12. CAN WE CHANGE OUR PRIVACY POLICY?
We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy here. We encourage you to visit this area frequently to stay informed.