Privacy Policy
What we collect, why, who else sees it, and what you can make us do about it.Effective 22 September 2026
Who holds your data
Establish Records Limited, of Hong Kong, is the data user responsible for personal data collected through jefferochan.com.
This policy is also our Personal Information Collection Statement: it is where we tell you, when we collect your data, what it is for, who else receives it, whether you have to give it and what happens if you do not, and how to see or correct what we hold.
Write to info@jefferochan.com about anything in this policy.
What we collect, and when
We collect only what the thing you are doing requires.
- Buying something: your name, delivery address, telephone number and email address. We need every one of them — a courier will not carry a parcel without a name, an address and a contactable number, and a receipt cannot be sent without an email address.
- Making an account: your email address, a password, a nickname and your gender, which the sign-up form marks as mandatory — an account cannot be made without them. The password is held by Google’s authentication service and never by us in a form we can read. Your nickname is how our emails greet you; your gender is shown beside it on your own account page, and is used for nothing else. Optionally a username, a telephone number and a date of birth.
- Paying: nothing. Your card number is typed into our payment processor’s own secure form, embedded in our page but not ours, and it never reaches this company. We are told the brand of the card and its last four digits, so that a receipt can be recognised against a statement, and a reference for the payment. We never see, hold or store a full card number, and we never hold the security code at all.
- Simply visiting: the request itself, as any web server receives — an IP address, a browser type, a page and a time. Our host keeps these as ordinary operational logs.
We do not collect any of the kinds of data Hong Kong law treats as sensitive, and we do not ask for identity documents.
Why we hold it
Each piece is held for the purpose it was given, and for purposes directly related to it:
- to take payment for an order, and to prove it was taken
- to pack an order, hand it to a courier, and answer where it is
- to send the confirmation, the receipt and any message about that order
- to run an account where somebody has asked for one
- to keep the accounting records the law requires a Hong Kong company to keep
- to detect and prevent fraud and abuse of the site
We do not sell personal data, and we never will.
Who else sees it
Running a shop means handing parts of an order to the people who do the work. Each of these receives only what its job needs, and only for that job.
| Who | What for | What they are given |
|---|---|---|
| Our payment processor | Payments | the amount, the currency, and whatever the payment method itself needs — a card number is typed into the processor’s own secure form, never into ours, and never reaches this company |
| The postal service or courier carrying your parcel | Delivery | the recipient name, delivery address, telephone number, and a description and value of the contents for customs — or only a tracking number, where we are just following a parcel |
| Our email delivery service | the email address a letter is sent to, and the letter | |
| Accounts, abuse prevention and typefaces | for anybody who makes an account, the email address, the password and the sign-in times; where reCAPTCHA runs, device and behaviour signals Google gathers in the browser; and on every page, the request for a font file, which carries an IP address as any request does | |
| Our hosting and database providers | Running the site | every request to the site, as any web host receives, and the shop’s records — this is where orders and accounts are kept |
| Public address lookup services | Address entry | the partial address being typed, sent to the government or postal service of the country the address is in |
| Streaming and social platforms | Links and embeds | nothing unless a visitor follows a link, or opens a page carrying an embedded post or player — at which point that platform sees the visit as its own |
Where it goes
Some of those services hold data outside Hong Kong — in the United States, in Europe and elsewhere. That is unavoidable for a shop of this size: the payment processor, the host and the database are international services, and a courier carrying a parcel abroad must be given the address abroad.
Where a parcel crosses a border, the destination’s customs authority is given the contents and value of the parcel because the law of that place requires it.
How long we keep it
- Order records, including the address a parcel went to: at least seven years, which is the period a Hong Kong company must keep its business records for. After that we may keep the record of the sale itself — what was sold, when and for how much — for as long as the company exists, but we remove the name, address and contact details from it, unless something about that order is still unresolved.
- Account details: until you close the account, and then deleted, except where a record must stay attached to an order for the reason above.
- The basket you have not checked out: until you empty it, or a year, whichever comes first.
- The record of when you agreed to hear from us, or stopped: kept after the account is closed, for the reason given under Direct marketing below.
- Server logs: as long as our host keeps them, which is a matter of weeks.
An order whose account has been closed keeps the delivery details and loses its link to the person, because the order still has to exist as a record of a sale.
What you can make us do
Under Data Protection Principle 6 and sections 18 and 22 of the Personal Data (Privacy) Ordinance you may:
- ask whether we hold personal data about you, and ask for a copy of it — a data access request
- ask us to correct it if it is wrong — a data correction request
Write to info@jefferochan.com. We will answer within 40 days, as the Ordinance requires. The Ordinance allows a data user to charge a fee for complying with a data access request; we do not intend to charge one, and if that ever changes the fee will be stated here first.
If you are not satisfied with how we have handled your data you may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong.
Direct marketing
When you make an account, and at any time afterwards on your account page, there is a box that reads “Send me news of upcoming performances, new releases and the odd exclusive offer.” It is not ticked unless you tick it.
If you tick it, we intend to use your email address and your nickname to send you, by email, news of performances, of new releases, and of offers on our records and merchandise. That is direct marketing, and Hong Kong law does not allow us to do it without your consent. Ticking the box is that consent. Leaving it empty is a refusal, and we will not market to you.
You can withdraw at any time and at no cost, by unticking the box on your account page or by writing to info@jefferochan.com, and we will stop. Every marketing email will also carry a way of stopping them.
We keep a record of each time you said yes or no, and we keep it after an account is closed, because it is our evidence that we had your consent when we wrote to you. It holds the email address, the account it came from, what was said and when — nothing else.
We do not give or sell personal data to any other company for its own marketing, and we will not.
Nothing in this section covers the emails an order generates. A confirmation, a receipt, a message saying your parcel has been posted and a reply to your own enquiry are part of performing the contract, not marketing, and you cannot be opted out of them while an order is live.
Cookies and what the browser keeps
This site sets no advertising cookies, no analytics cookies, and no third-party tracking of any kind. There is no tracking pixel on any page and no advertising network is present.
What it does keep in your browser:
- a sign-in token, if you have an account and are signed in
- your basket, so it survives a reload — kept in the browser, not on our server, until you check out
- small conveniences such as which view of the shop you last chose
Google’s reCAPTCHA, which guards account creation, sets its own cookies and gathers its own device signals in your browser; that is Google’s processing under Google’s privacy policy, and it happens only on the pages where it appears.
Because none of the above is used for advertising or for tracking you across other sites, there is no consent banner. Clearing your browser’s storage for this site removes all of it and costs you nothing but your basket.
Keeping it safe
Everything travels over an encrypted connection. Passwords are held by Google’s authentication service, hashed, and are not recoverable by us. Card numbers never reach us at all. Access to the shop’s records is limited to the people who run it and is behind its own sign-in.
No system is perfectly secure, and we do not claim otherwise. If a breach ever occurs which is likely to cause you real harm, we will tell you and we will notify the Privacy Commissioner.
Children
This site is not aimed at children and we do not knowingly collect personal data from anybody under 16. If you believe a child has given us data, write to info@jefferochan.com and we will remove it.