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Privacy Policy

Privacy Policy


    • Purpose of this Privacy Policy

White Crane Group Limited, a company incorporated and existing under the laws of Hong Kong and trading as Bare Essentials (referred to in this Privacy Policy as “White Crane Group”, “we”, “us” or “our”) is committed to respecting and protecting your privacy. This Privacy Policy sets out how we look after your personal data when you visit us at www.bareessentials.com (the “Site”).

We take your privacy seriously. We are keen to obtain, retain and process your personal information (including any special data) in accordance with all applicable laws including the Personal Data (Privacy) Ordinance (Cap. 486, the laws of Hong Kong) (“PDPO”).

This Privacy Policy forms part of the Terms and Conditions of Website User.

It is important that you read this Privacy Policy when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

The Site is not intended for children and we do not knowingly collect data relating to children.

  • Data Controller

White Crane Group is a “data controller” of your personal data.

This means that we (a) “control” your personal data, including making sure that it is kept secure; and (b) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or as otherwise permitted by law.

  • Contact Information and Complaints

If you have any questions about this Privacy Policy or any questions regarding our use of your personal data, please contact our data privacy manager at by emailing us.

Our full contact details are:

White Crane Group Limited

4/F, Wai Lam House,

12 Lan Kwai Fong,

Central, Hong Kong

If you are currently staying in Hong Kong, you have the right to make a complaint at any time to the Privacy Commissioner for Personal Data. We would, however, appreciate the chance to deal with your concerns before you approach your country’s or territory’s supervisory authority, so please contact us in the first instance.

  • Changes to this Privacy Policy and Personal Data

This Privacy Policy is regularly reviewed and was last updated on 11 August 2019. We may amend or update our Privacy Policy from time to time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.



The types of personal data we collect, use and store about you will depend on the services you have requested from us and/or the nature of your interaction with us. When using the Site, we may collect and process the following personal information about you:

  • (a) your first name, last name, username or similar identifier, date of birth, nationality and gender (“Identity Data”);
  • (b) your billing address, delivery address, email address and telephone numbers (“Contact Data”)
  • (c) your bank account and payment card details (“Financial Data”);
  • (d) details about payments to and from you and other details of products and services you have purchased from us (“Transaction Data”);
  • (e) your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site (“Technical Data”);
  • (f) your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (“Profile Data”);
  • (g) information about how you use our Site and other services, for example, how often you come to our showrooms and events (“Usage Data”); and
  • (h) your preferences in receiving marketing from us and our third parties and your communication preferences (“Marketing and Communications Data”).

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    • Direct Interactions

We collect Identity Data, Contact Data and Financial Data about you that you provide to us by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:-

  • (a) apply for our products or services;
  • (b) register on our Site;
  • (c) subscribe to our newsletter;
  • (d) request other marketing material to be sent to you;
  • (e) enter a competition, promotion or survey; or
  • (f) give us feedback or contact us in any way or form.
  • Automated Technologies and Interactions

As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

  • Third Parties

We are also working closely with third parties (including, for example, analytics providers and other third party providers of services).

We will receive personal data about you from such third parties as set out below:-

  • (a) Technical Data and Usage Data from analytics providers such as Google and Facebook;
  • (b) Contact Data, Financial Data and Transaction Data from providers of payment services such as Stripe;
  • (c) Contact Data from delivery services such as Hong Kong Post and SF Express;
  • (d) Contact Data from mailing list providers such as Mailchimp; and
  • (e) Identity Data and Contact Data from publicly available sources such as the Companies Registry of Hong Kong.

All of our employees are subject to obligations of confidentiality regarding information which they have access to in the course of their employment including the personal information of customers. All personal information is held in secure computer storage facilities. We take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Site – any transmission is at your own risk. Once we have received your information we will use our strict procedures and security features to protect it.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


We will only use your data for a lawful purpose. We plan to use your personal data for the following purposes:-

Purpose Type of Data
Registration as a new customer Identity Data;

Contact Data.

Processing and delivery of your order Identity Data;

Contact Data;

Financial Data;

Transaction Data;

Marketing and Communication Data.

Management of our relationship with you

(i.e. notifications about changes to Privacy Policy and asking you to leave a review or take a survey)

Identity Data;

Contact Data;

Profile Data;

Marketing and Communication Data.

Enabling you to partake in a prize draw, competition or complete a survey Identity Data;

Contact Data;

Profile Data;

Usage Data;

Marketing and Communication Data.

Administration and Protection of our Site

(including troubleshooting, data analysis, testing, system maintenance, support reporting and hosting of data)

Identity Data;

Contact Data;

Technical Data;

Delivery of relevant website content and advertisements to you and understanding the effectiveness of the advertising we serve to you Identity Data;

Contact Data;

Profile Data;

Usage Data;

Marketing and Communication Data;

Technical Data.

Using data analytics to improve our Site, products/services, marketing, customer relationships and experiences Usage Data;

Technical Data.

Suggestions and recommendations about goods or services that may be of interest to you Identity Data;

Contact Data;

Profile Data;

Usage Data;

Marketing and Communication Data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please feel free to contact us any time.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We may contact you by post, telephone, email or other electronic messaging service with offers of products, services or information that may be of interest to you. Where the soft opt-in does not apply we will have secured your consent to this before we market to you.

You can ask us to stop sending you marketing messages at any time by:-

  • (a) by emailing us at any time; and
  • (b) by following the opt-out links on any newsletter or marketing message sent to you.

Where you opt-out of receiving these marketing messages or newsletters, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions (which we will continue to process in order to perform a contract with you or as a result of our regulatory or legal obligations).


If you submit your personal information in connection with an offer, survey or free prize draw we may transfer the information you provide to third parties with whom we are running the offer, survey or free prize draw.

Where you have asked not to be contacted by third parties during the registration process for the promotion the third party will only be permitted to use the information for the purposes of administering the offer, to notify winners, deliver the prize(s) to winners, to make the winners list publicly available pursuant to applicable laws or anything strictly necessary to administer the offer, survey or free prize draw.


We may share your details among our companies at home and abroad including our joint ventures and with any future owners of the Site. Please be ensured that any such transfer would only occur in accordance with any applicable laws including, but not limited to, section 33 of the PDPO.

We may employ other companies and individuals to carry out functions on our behalf including delivering packages, sending mail, providing marketing assistance, analysing data and providing customer service. In order to carry out their functions these companies and individuals may require access to your personal information, but we shall only disclose such relevant personal information as is needed by them to perform their functions.

Where requested to do so, we may co-operate with any court, tribunal, regulatory body, police authority or other similar authority in any investigations or proceedings concerning you or your use of the Site. This may include disclosing information about communications transmitted via the Site to such authorities where required or under a legal obligation to do so.

We regard our databases of information (which will include your personal information) as an important part of our business and we will not give or sell this information to any outside organisation for use in its marketing or solicitation without your consent.


“Cookies” are small bits of electronic information that a website can transfer to your hard drive to help tailor and keep records of your visit to that website. If you visit the Site, cookies are used to allow us to better customise your visit to your individual preferences, helping us provide you with the best possible service on the Site. This is statistical data about our users’ browsing actions and does not identify any individual. Most major websites use cookies and their use is standard on the Internet.

A cookie cannot give us access to your computer or to information beyond what you provide us and we don’t store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience on our Site. If you do not wish to enable cookies, you’ll still be able to browse the Site and use them for research purposes.

We use cookies to:

  • (a) simplify the logging on process for registered users;
  • (b) help ensure the security and authenticity of registered users;
  • (c) provide the mechanisms for online shopping;
  • (d) enable monitoring of traffic and usage patterns;
  • (e) to report aggregate information to our advertisers; and
  • (f) remember the settings of any profile you set up on the website.

On visiting our Site you will be sent anonymous cookies to keep track of your browsing patterns and build up a demographic profile. In addition, if you have clicked on a Lil-Lets advertisement on another site that links to the Site you may be sent an anonymous cookie that will allow us to analyse advertising effectiveness and manage our relationship with our associated websites. Please note that our advertisers may also use cookies, over which we have no control.

Whilst you do not need to allow your browser to accept cookies in order to browse much of the Site or to access many of our services, you must have cookies enabled if you wish to shop online or access any areas reserved for registered users. Most browsers allow you to turn off the cookie function. If you want to know how to do this please look at the help menu on your browser, but this may restrict the use of some parts of the Site.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.


We or third parties on our behalf may use web beacons in combination with cookies on the Site, in our emails or in our advertisements. Web beacons help us understand how visitors interact with the Site and enable us to measure the effectiveness of the Site and our advertising, for example by counting the number of individuals who have visited the Site via a particular advert.

A web beacon is typically an electronic image that is placed on a site, email or advert which allows a website to record the simple actions of the user opening the page that contains the beacon. Web beacons provide us with details of how the Site is navigated, how many individuals visit specific pages, the time material was viewed, the types of browsers and computer operating systems used and the Internet Protocol addresses from which you connect to the Site. This is information that is available to any web server you visit and web beacons do not give any extra information away. Web beacons are simply a convenient way of gathering simple statistics and managing cookies and by being able to recognise you this allows us to improve your experience of the Site by enabling us to tailor and personalise your visit.

Where web beacons are used in connection with cookies then they may be rendered ineffective by either opting out of the cookies or changing the cookie settings in your browser.

You can find out more about the way web beacons work on www.allaboutcookies.org.

  1. LINKS

The Site may contain links to other websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

Please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these. We recommend that you read the privacy statements immediately on entering other websites.


If you are currently staying in Hong Kong, you are entitled, in accordance with the PDPO, to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them.

Requests for access to or to correct personal data should be emailed to us.

In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.