Last Updated: 06 November 2023
Our Privacy Principles
(“Watsons” or “we” or “us” or “our”) is a member of the A.S. 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 data is used in line with applicable data protection laws.
2. We will ALWAYS be transparent with you about how we use your personal data. 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 no longer wish to receive our marketing communications.
4. We will ALWAYS take all reasonable steps to protect your personal data and make sure no unauthorized person accesses it.
5. We will ALWAYS respond to any questions on the processing of your personal data without undue delay.
We are committed to safeguarding your privacy rights and ensuring that your personal data is protected.
1. WHO IS RESPONSIBLE FOR WHAT HAPPENS WITH YOUR DATA?
Central Watson Company Limited is responsible for processing your personal data on our Sites.
2. WHAT IS PERSONAL DATA?
Personal Data generally refers to information that can directly or indirectly identify you ("Personal Data"). 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 is called “special categories of Personal Data” that require special protection because of their sensitivity.
3. WHAT HAPPENS WHEN YOU PROVIDE US WITH YOUR PERSONAL DATA OR WHEN WE OTHERWISE RECEIVE YOUR PERSONAL DATA?
We collect your Personal Data directly in a number of ways, for example, when you provide us with your information to register as a customer on our Sites or as a member of our loyalty program, register for prize draws, games or competitions, subscribe to our newsletters, 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.
We may also receive your Personal Data from other sources, including information passively received from available sources such as operators of any Third-Party platforms and Third-Party Sites as referred above and information from Our Partners (as defined in Section 6.1 below). If you do not want us to receive your Personal Data from other sources, please communicate your preferences directly with the relevant sources.
If you become a member of our loyalty program, you may still receive service notices or non-direct marketing communications about the program despite you have opted out of receiving direct marketing communications from us without detriment to your loyalty benefits.
Where we process your Personal Data on the basis of your consent, we will ask for your consent explicitly and only for a particular purpose.
4. 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 Data for direct marketing purposes unless parental or guardian consent is provided to us.
To provide parental consent to marketing, please ask your parent or guardian to call or write to Central Watson Company Limited, contact details as listed in Section 12 (applicable to loyalty card or online account members only).
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 Data to carry out age verification checks and enforce any such age restrictions.
5. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
5.1 We process the following categories of Personal Data for the following purposes:
What Personal Data may we collect?
What is the purpose of the processing?
How long do we store your Personal Data?
Browsing on our Sites
Information about the type of browser you use when visiting our Sites, your IP and device address, hyperlinks that you have clicked, websites you visited before arriving at our Sites and information collected by Cookies or similar tracking devices. Your user name, profile picture, gender, networks and any other information you choose to share when using Third-Party Sites (such as when you use the "Like" functionality on Facebook).
See Section 5.3 below for more information about Cookies.
Please check the Cookie Consent Tool to learn about the storage periods for each Cookie.
The retention period of Cookies varies from the duration of your visit to the Site depending on the purpose of the Cookie. You can reject or delete historical cookies by changing the settings on your web browsers.
Purchasing products / Agreeing to a Service
Name, title, postal address, email address, home telephone number, mobile number, loyalty card number, passwords, order history, payment history, payment information (i.e. bank or credit card details), order history/wishlist, age/date of birth, gender, information on the handling of your request (including information relating to controlled drugs and other medicine or beauty products that you order), and other Personal Data you voluntarily provide to us.
We process Personal Data to provide you with our products or services that you request from us, including sending you products or samples that you have requested.
As long as you keep shopping with us. If you have no activity after three years, we will delete or anonymise your Personal Data, unless we are required by law to store it for a longer period.
Name, title, postal address, email address, home telephone number, mobile number, loyalty card number, passwords, order history, payment history, payment information (i.e. bank or credit card details), order history/wishlist, age/date of birth, gender, information on the handling of your query, posts and other content you submit to our Sites, and further information submitted by you in relation to a purchase or service request or other query (including sensitive personal information).
We process your Personal Data whenever you contact us and when we respond to your enquiries, comments and complaints.
For general enquiries and comments relating to service issues, store standards, stock availability etc., we will store such data for three years from the last communication with you. Communications relating to personal injuries, accidents and other health and safety issues may need to be kept for a longer period in case of legal claims or settlements.
Suggesting products & services which may interest you
Name, title, postal address, email address, home telephone number, mobile number, loyalty card number, order history/wishlist (including purchases you make on our Site, mobile app, in-store or pharmacy), payment history, age, date of birth, gender, products you view on our Site, brands you prefer, favourite store, actions you take on our website (including comments made by you in using our Sites) or when viewing our emails, answers you provide in surveys or competitions, your shopping habits and preferences and information about your lifestyle, such as your hobbies and interests.
To suggest tailored products or services (including those from us, our Partners (as defined in 6.1 below) and other relevant third parties) that we think may be of interest to you based on your shopping history and behaviour, your preferences, and our market segmentation strategies. We may do this by sending you - via post, email, newsletter, SMS, push notifications or phone - details of products, services, special offers, promotions and other information. We may also contact you to offer you the opportunity to take part in customer research surveys, promotions, prize draws or competitions. You may also receive in-store promotions (such as special coupons) from us when you have an account with us or are a member of any of our loyalty programs.
As long as you keep shopping with us and/or using our loyalty card. If you are a registered shopper and/or are a loyalty card member and you have no activity after three years, we will delete or anonymise your Personal Data, unless we are required by the law to store it for a longer period. If you purchase online and check-out as a guest, we will retain your data for one year from the date of transaction.
If you have signed up to any of our newsletters, we will retain your data until you unsubscribe.
Competitions, events and games
Name, title, postal address, email address, home telephone number or mobile number, age, date of birth, gender, images collected during any events, user generated content or any other relevant Personal Data that you submit – as required for the competition or game.
To carry out prize draws, games or competitions which you chose to participate in and to determine the winner or to provide the prize if you win.
Three months after the competition or game is completed, unless we are required by law to store them for a longer period.
Name, title, postal address, email address, home telephone number or mobile number, information about products you order (including health products or drugs if you order from our online pharmacy), order history, details about your purchase, payment information, payment history and age.
To process your online purchase and deliver the product to you as ordered. Your payment and delivery related Personal Data may be transferred to payment and courier service providers to process your payments and deliver your orders, respectively.
As long as you keep shopping with us. If you have no activity after 3 years, we will delete or anonymise your Personal Data or If you have no transactions, 3 years from the date you registered an account with us unless we are required by law to store it for a longer period.
If you check out as a guest, we will retain your data for one year from the date of transaction. After 1 year, we will delete or anonymise your Personal Data.
In-app features (such as in-app storage of e-coupons, comments and postings, etc.)
Actions you take when you access or use the relevant in-app features in our Sites (including comments, personal images, and other content or information submitted by you).
With your consent, we may access your contact list for the purposes of sharing e-coupons to eligible members.
If you choose to use our in-app beauty filter features, we will process your image to fulfill your request. For some in-app features, the images collected will only be stored in your personal device and will not be collected by us.
We will ask for your separate permissions for our app to access your camera or your contact list. If you change your mind, you will be able to revoke them any time by changing the settings on your device. Please note that rejecting or switching off these permissions will limit the features you can use in our app.
We use facial recognition technology already included in your phone (such as TrueDepth API) or other software for depth of facial mapping information to create augmented reality effects within the app. We do not share information with third parties and do not store or process in any other way the data which our app accesses and uses via this technology.
As long as you are a member of any of our loyalty programs or shopping with us. If you have no activity after three years from the date you registered an account with us, we will delete or anonymise your Personal Data, unless we are required by law to store it for a longer period in the event that such data is collected and stored by us.
Name, title, postal address, email address, home telephone number or mobile number, information about products you order using the Loyalty Program, transactions relevant for the Loyalty Program, account status and details regarding points collected and redeemed, payment information (i.e. bank details), payment history and age.
To provide you with all services under the Loyalty Program including exclusive offers and points schemes.
As long as you are a member of any of our loyalty programs. If you have no activity after three years, we will delete or anonymise your Personal Data, unless we are required by law to store it for a longer period.
Fraud prevention and other administrative services, such as registration
Name, title, postal address, email address, home telephone number or mobile number, information about health or diagnostic data, payment information (i.e. bank details), payment history, age.
To carry out administrative services, including processing any application you submit to us for providing the services, preventing or detecting fraud or other crimes, verifying your identity and credit/payment status, or processing payment instructions. Your payment- related Personal Data may be transferred to payment service providers to process your payments or the police for fraud prevention purposes.
As long as you keep shopping with us. If you have no activity after three years, we will delete or anonymise your Personal Data, unless we are required by the law to store them for a longer period.
Tele-Consultation / e-Pharmacy
Name, phone numbers, age, gender, other details documented on your identification document (if applicable), health data (including medical concerns, self-reported symptoms, existing medications, allergies and diagnosis), postal address, email address, insurance information (if applicable), message exchanges between you and our customer service staff, payment information (i.e. bank or credit card information), and other relevant Personal Data that you may require to submit for the provision of the tele-consultation/ e-pharmacy services from time to time.
Facilitating your use of tele-consultations, e-pharmacy and other similar online services.
Providing, coordinating, or managing healthcare and related services by us or one or more healthcare providers; integrating onto healthcare / pharmacy management systems and applications operated or managed by us or our service providers in order to provide you with healthcare related services (including tele-consultations, e-health consulting and screening, and any other programs related to the provision of online health services).
As long as you keep using our tele-consultation, e-pharmacy or similar online services. If you have no activity with us after 3 years, we will delete or anonymise your Personal Data unless we are required by law to store it for a longer period.
5.2 We process the following categories of Personal Data for Direct Marketing purposes (only where we have already obtained your prior consent to do so):
What Personal Data may we collect?
What is the purpose of the processing?
How long do we store your Personal Data?
Sending direct marketing communications and sharing your limited data with social media networks to better identify and target relevant direct marketing communications outside of our Sites to you
Name, title, postal address, email address, home telephone number, mobile number, loyalty card number, order history/wishlist (including purchases you make on our Sites, mobile app, in-store or pharmacy), payment history, age, month of birth, gender, products you view on our Sites, brands you prefer, favourite store, actions you take on our website (including comments made by you in using our Sites) or when viewing our emails, answers you provide in surveys or competitions, your shopping habits and preferences and information about your lifestyle, such as your hobbies and interests.
To send you direct marketing communications and/or suggest offers and promotions which may interest you from (i) us and Our Partners (as defined in Section 6.1 below)) related to Retail Goods or Services (as further defined below), and (ii) other companies within the CK Hutchison Group only in relation to telecommunications goods and/or services, e-commerce services (including trading platforms and online auctions), payment services, financial, investment and insurance products and services, hotel and tourism services and real property and related services, and (iii) other Third-Party merchants that we cooperate with offering Retail Goods or Services, financial, investment, insurance, banking and credit cards services, and payment services transportation, travel, hospitality and accommodation services, travel insurance, green and recycling initiatives, sports, leisure, recreation and entertainment, e-commerce (including online trading and payment platforms and online auctions and/or any ancillary or supplemental products and services) only where we have already obtained your prior consent to do so to send you direct marketing communications suggest offers and promotions that we think may be of interest to you based on your shopping history and behaviour, your preferences, and our market segmentation strategies. We may do this by sending you - via post, email, newsletter, SMS, push notifications or phone - details of products, services, special offers, promotions and other information. We may also contact you to offer you the opportunity to take part in customer research surveys, promotions, prize draws or competitions. You may also receive in-store promotions (such as special coupons) from us when you have an account with us or are a member of our loyalty program.
Where we have obtained your prior consent, we may share your name, email address, phone number and your hobbies and interests based on your shopping history and behaviour or engage in audience building or customer matching activities with social media networks such as Facebook and Google) to send you direct marketing and advertisements outside of our own websites. You may opt-out from direct marketing or can oppose targeted advertising by notifying us or by directly adjusting your account settings with these social media networks.
As long as you keep shopping with us and/or using our loyalty card, and also have not opted-out from direct marketing. If you are a registered shopper and/or are a loyalty card member and you have no activity after three years, we will delete or anonymise your Personal Data, unless we are required by the law to store it for a longer period. If you purchase online and check-out as a guest, we will retain your data for one year from the date of transaction.
If you have signed up to any of our newsletters, we will retain your data until you unsub
5.3 Cookies and Similar Technologies
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 Data 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:
• 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
5.4 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.
6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Your Personal Data may be shared by us with our trusted business partners which offer Retail Goods or Services (“Our Partners”), such as Third-Party merchants providing the relevant Retail Goods or Services with whom we may from time to time cooperate with to offer you with those goods or services, to facilitate the processing of earning and redemption of loyalty points and related transactions, as well as for data analytics purposes in order to improve their operations for and supply of the relevant Retail Goods or Services to you.
Provided we have obtained your prior consent, your Personal Data may be shared by us with Our Partners when we engage in customer matching with our members and Our Partners’ customers to undertake data analytics of common customers who may have shown an interest in receiving any offers tailored to the products offered by Our Partners and/or us.
6.2 ASW Group and CK Hutchison Group
Your Personal Data may be transferred from us to other members of ASW Group and/or CK Hutchison Group which offer Retail Goods or Services (each a “Group Company”) for any of the purposes we have set out in Section 5 above (including for any such Group Company to engage in direct marketing-related activities in the manner as set out in Section 5 above for or on our behalf, provided that you have not opted-out from direct marketing). However, we will not provide your Personal Data to any Group Company in order for them to send you direct marketing communications or materials regarding their own products and services under their own capacity, unless we obtain your prior explicit consent.
6.3 Our service providers
Your Personal Data may be shared with our service providers (including agents and contractors) which process Personal Data 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 data, or to carry out any of the purposes set out in Section 5 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 5 above.
6.4 Professional advisors and assignees
When necessary, we may share your Personal Data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your Personal Data 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.
6.5 Government and regulatory authorities
We will disclose your Personal Data 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.
6.6 Other recipients
We may transfer your Personal Data in the following scenarios:
To data analytical firms, such as Google Analytics Inc. (to the extent that such Personal Data is not aggregated or anonymised) where your Personal Data was collected by cookies or similar tracking technologies across our Sites and other parties’ sites for these data analytical firms’ own benefit;
To social media platforms such as Facebook or Google, when we engage in audience building or customer matching activities of our loyalty members with social media platforms including Facebook members or Google customer segmentation;
In an emergency, such as to safeguard the life, health or property of an individual; and/or with your consent
To proceed to share your Personal Data with third parties where required by law.
7. TO WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA?
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 Data are safeguarded with sufficient protection in compliance with applicable Data Protection Laws.
When we need to transfer your Personal Data 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 Standard Contractual Clauses.
More details on the transfer mechanisms can be obtained from our A.S. Watson Group and/or CK Hutchison Group (see contact details in Section 12).
8. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?
We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired as further described in Section 5.
9. HOW DO WE PROTECT YOUR PERSONAL DATA?
We maintain appropriate technical and organisational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, and/or unauthorised disclosure of, or access to your Personal Data.
Our Sites may contain hyperlinks to other websites provided by third parties. We do not control these Third-Party websites or apps or any of the content contained on those websites or apps. Once you have left our website or apps, we cannot be responsible nor accept any liability for the protection and privacy of any information which you provide to other sites or apps. You should exercise caution and look at the privacy policies of the other sites that you visit.
10. WHAT ARE YOUR RIGHTS?
If certain requirements are fulfilled and to the extent permitted by the Personal Data Protection Act, you have the right to:
Obtain from us confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data
Objection to the Processing of Personal Data
Restriction of Processing of Personal Data
Right to Request your Personal Data to be transmitted directly to another controller
Right to Request your Personal Data to be erased / removed
Right not to be subject to Automated Decision-Making
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
To exercise your rights, including your right to erasure, you can simply fill up our dedicated webform. Alternatively, you can contact the A.S. Watson Group and/or CK Hutchison Group (see Section 12 for contact details) or get in touch with our Customer Service Team.
12. HOW DO I MAKE ENQUIRIES ABOUT MY PERSONAL DATA?
If you have any question or request in relation to how we process your personal data, you can contact our A.S. Watson Group and/or CK Hutchison Group via email at firstname.lastname@example.org or via post at Watsons Thailand 23rd Floor, Sirinrat Building 3388/23-24 Rama IV Rd., Klongton, Klongteoy, Bangkok 10110