We, Oodles Systems Limited (“we”, “us” or “our”, as the case may be), a company registered in HKSAR, with its registered office located at Flat/RM A&B, 6/F, Yin Da Commercial Building, 181 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong, operates oodles.com.hk which comprised of various web pages and websites, and the Oodles iOS and Android mobile applications, software or services offered through the Website and/or by us related to the Website (collectively, the "Website") and are committed to protecting your privacy.


This Privacy Policy is made for compliance with the Personal Data (Privacy) Ordinance, Chapter 486, Laws of HKSAR and provides information on how we treat personal information that we collect and receive, including information related to your past use of our products and services. Personal information is information about you that is personally identifiable like your name, address, email address, or phone number, and that is not otherwise publicly available.


The Website and the Services provided by us are not intended to be used by people under the age of 18. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact the One Collection Data Protection Officer at privacy@oodles.com.hk.

In this Privacy Policy, unless the context otherwise requires, the following expressions shall have the following meanings:

  • “We”, “us” or “our” means Oodles Systems Limited, any holding, subsidiary and affiliate and all associated companies of Oodles Systems Limited;

  • “Website” means the oodles.com.hk website, including various web pages including but not limited to (i) 720.oodles.com.hk, (ii) scanner.oodles.com.hk, (iii) cube.oodles.com.hk, (iv) transformer.oodles.com.hk, (iv) design.oodles.com.hk, (v) match.oodles.com.hk, (vi) mall.oodles.com.hk, (vi) home.oodles.com.hk, operated by us incidental thereto;

  • “Services” means the Oodles iOS and Android mobile applications, computer software or online/offline services offered through the Website and/or and any other applications by us related to the Website;

  • “You” or “your” means the person using the Website or the Services; and

  • “HKSAR” means the Hong Kong Special Administrative Region of the People’s Republic of China.


Where appropriate in this Privacy Policy:

  • Words importing the masculine gender shall include the feminine gender and the neuter gender and vice versa (unless the context otherwise requires);

  • Words importing the singular number shall include the plural number and vice versa (unless the context otherwise requires);

  • The expression “person” shall mean and include a company, society, corporation, firm, partnership, joint venture, trust, state, agency of a state, or an individual and in the case of an individual his or her executors, administrators, committee, receiver or other person lawfully acting on behalf of every such person; and

  • Clause and other headings are for ease of reference only and shall not affect the interpretation of this Privacy Policy.

The Website can contain links to and from the websites of our partners, advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

When you interact with us, whether by using the Website or communicating with us, we may collect the following information from you:

We collect the following types of information about you:

  • Account and profile information that you provide when you register for an account or sign up for our products or the Services, including but not limited to your name, email address, phone number, residential/business/office address (collectively, “Account Data”);

  • Information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);

  • Content you provide through use of our products or the Services, for example Store and product information by merchants; product reviews and ratings from customers (collectively, “User Content”);

  • Communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data”);

  • Information about your device or connection, for example your internet protocol (IP) address, log-in data, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our products or the Services and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data”); and

  • Information about your use of or visit to the Website, for example your clickstream to, through, and from the Website, products you viewed, used, or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page (collectively, “Usage Data”).

We collect the above information when you provide it to us or when you use or visit the Website. We may also receive information about you from other sources, including:

  • Our personnel, agents, advisors, consultants, and contractors based in HKSAR, Taiwan, Mainland China in connection with our operations or the Services, for example our staff engaged in the fulfilment of your order, processing of your payment, and provision of support services;

  • Other services linked to your account, for example if you register or log in your account using your Facebook credentials, we receive your name, your profile picture, your mobile phone number and email address to authenticate you, as permitted by your Facebook profile settings;

  • Our business partners and service providers based in HKSAR, Taiwan, Mainland China who provide reselling and customer support services in HKSAR, Taiwan and Mainland China, and analytics applications.

We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, political orientation, religion, trade union membership, genetics, biometrics, health, or sexual orientation.

  • To provide you the Services and the Website, including allowing you to order and receive products by using the Website, administering your account and optimizing your experience, we need to use the information that we collect in a number of different ways.

  • We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using the Services, we and our partner will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt out instructions in the promotional emails we send you.

  • We may use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to the Website or usage of our mobile application, our service providers may also use the information about your interactions with other websites or applications to target advertisements for products available from us. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.

  • We may also carry out research, analysis and surveys and collect views on your use of the Website. We may keep tracking of your spending on the Website to see if you can benefit from our exclusive loyalty programs as the VIP Customer Program and Access. Additionally, we may use your information to confirm your identity and perform credit checks or anti-fraud checks in order to ensure your and our financial security.

  • Please note that we will not sell your information without your consent (including your name, address, email address, financial information) to any third party.

  • We set out hereunder the detailed purposes for which we collect your information and what specific information is collected:

  1. ​To register and manage your account in the Website, we need to collect information including your name, email, password and other additional details we or you may wish to add in your account, like phone number, address and gender.

  2. To fulfil the orders you make through the Website, we need to collect information including your name, address, phone number, order details, like the products you are buying, the size and price thereof.

  3. To collect payment from you, we need to collect information including your payment information, which comprises the credit/debit card’s number, holder’s name and CCV (we will not store such information and only transfer it to our authorized payment provider).

  4. To provide you with our customer services (including helping you to solve any issue you have when using the Services, updating you about any change to our terms and conditions of services, or contacting you to know your experience with us), we need to collect information including your name, email, password and address and your contact history with us (including phone records of your conversations with us).

  5. To monitor the quality of our customer services, we need to collect information including your name, email, password and address and your contact history with us.

  6. To administer, maintain and optimize the Website and Services, we need to collect information including your device information (such as your device IP address and device type), Cookie identifiers and browsing information.

  7. To perform fraud and credit checks and check if we can do business with you, we need to collect information including your name, email, address, credit/debit card details, browsing history, purchase history, date of birth, gender, device information (such as IP address and device type), any national identifiers (like driver’s license or ID card) and any publicly available information (like social media profiles or news).

  8. To send you marketing communications and personalized offers, we need to collect information including your name, email, phone number, address, date of birth, purchase history, browsing history and behavior, device information, shopping preferences, Cookie identifiers, internal identifiers and nationality.

  9. To manage our loyalty programs, we need to collect information including your name, email, phone number, address, date of birth, purchase history, browsing history and behavior, device information, shopping preferences, nickname, Cookie identifiers, internal identifiers, nationality, spend tiers and wealth.

  10. To analyze your behavior and purchases in the Website, we need to collect information including your name, email, phone number, address, date of birth, purchase history, browsing history and behavior, device information, shopping preferences, nickname, Cookie identifiers, internal identifiers, nationality, spend tiers and wealth.

  11. To carry out research, analysis, enquiries and surveys on your use of the Website, we need to collect information including your name, address, email, device information, demographic information (including gender, place of residence/carrying on business and household/business income) and content of survey responses.

  12. To advertise and retarget advertising, we collect your email, cookie identifiers and device information.

  • We set out hereunder the legal basis for which we collect your information:

  1. for performance of a contract with you; and/or

  2. for our legitimate interests in retaining you as a customer and running our business; and/or

  3. for protecting us and/or our customers from fraudulent activities and compliance with our legal obligations; and/or

  4. for conducting electronic direct marketing of similar products and services which you have acquired by using the Website; and/or

  5. for improving our services, the Website and your experience with us.

To provide the Website and Services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:

  • We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and the Services.

  • If you use any third-party software in connection with our products or the Services, for example any third-party software that the Website integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of any third-party software providers before you use any third-party software.

  • The Website may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of any third-party websites before you submit information to them.

  • We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.

  • If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to the third party in connection with such transaction. We will notify you if such transaction is completed and inform you of any choices you may have regarding your information.

  • We use Microsoft Azure data hosting service based in the Hong Kong to host the information we collect.

  • We have adopted the following measures to protect the security and integrity of your personal information:

  1. information is encrypted using TLS/SSL technology;

  2. your account is password-protected;

  3. access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and

  4. our information collection, storage, and processing practices are reviewed regularly.

  • We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  • While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

  • Merchants may copy and store customer’s information out of our system which cannot be controlled by us. You as customers should check with respective Merchants’ privacy policies.

  • We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

  • We use the following categories of cookies on the Website:

  1. Strictly necessary cookies – these are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.

  2. Analytical/performance cookies – these allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are easily finding what they are looking for.

  3. Functionality cookies – these are used to recognize you when you return to the Website.

  4. Targeting cookies – these record your visit to the Website, the pages you have visited, and the links you have followed.

  • If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website.

  • You can withdraw your consent to these cookies at any time through the following options:

  1. Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;

  2. Any other type of cookies, you can clean the cookies through your browser settings.

  • Please note that refusing cookies does not mean you will no longer receive online advertising. It means that the company or companies from which you opted out will no longer deliver advertisements tailored to your web preferences and usage patterns, and you may receive a greater number of advertisements that are irrelevant to you and your preferences.

  • Many web browsers support “Do Not Track” technology. While we strive to offer you choices when you use the Website and Services, we cannot promise that we will be able to receive or honor the web browser “Do Not Track” signals.

  • We retain the data you provide to us for as long as you have your account with us and thereafter for such reasonable period as you may have questions or a claim in relation to the Services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.

  • In some circumstances you can ask us to delete your data as set out below.

  • After you have terminated your use of the Services, we may store your information in an aggregated and anonymized format.

  • You have the right to:

  1. be informed of what we do with your personal information;

  2. request a copy of personal information we hold about you;

  3. require us to correct any inaccuracy or error in any personal information we hold about you;

  4. request erasure of your personal information (note, however, that we will not always be able to comply with your request of erasure for record keeping purposes, completing transactions, or complying with our legal obligations);

  5. object to or restrict the processing by us of your personal information (including for marketing purposes);

  6. request to receive some of your personal information in a structured, commonly used, and machine-readable format, and request that we transfer such information to another party; and

  7. withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).

  • You may opt out of receiving marketing materials from us by using the unsubscribe links in our communications, or by contacting us. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications and/or information from us that are necessary for the use of our products or the Services.

  • As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

  • Any request under paragraph 10.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

  • We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than one month if your request is particularly complex or if you have made a number of requests.

Our products and the Services are not directed to individuals under 18. We will not knowingly collect personal information from individuals under 18. If we become aware that an individual under 18 has provided us with personal information, we will take steps to delete such information. Contact us if you have reason to believe that we have mistakenly or unintentionally collected information from an individual under 18.

  • If you have any questions or concerns about this Privacy Policy, please contact us:

  1. by emailing us at privacy@oodles.com.hk; or

  2. by writing to the Data Protection Officer, at Flat/RM A&B, 6/F, Yin Da Commercial Building, 181 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong.

  • Please contact us in the first instance if you have any questions or concerns about your personal data collected by us. If you have unresolved concerns, you have the right to file a complaint with the Office of the Privacy Commissioner for Personal Data in HKSAR.

We may amend this Privacy Policy from time to time. If we make any substantial changes in the way we use your information we will notify you by posting a prominent notice on the Website.

  • The terms of this Privacy Policy are governed by and shall be construed in accordance with the laws of HKSAR.

  • The courts of HKSAR shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with the terms of this Privacy Policy.