Data Protection Principle 4(1) Of The Personal Data (Privacy) Ordinance

This principle 4(1) requires data users to take all practicable steps to protect security of collected personal data against unauthorised or accidental access, processing, erasure, loss or use.

ImagineX Management Company Limited ("ImagineX")

ImagineX is a brand management and distribution Hong Kong company for international fashion and beauty businesses. ImagineX encourages and manages loyalty membership programmes for its partnered brands.

As a well-established brand management and distribution company for international fashion and beauty businesses, ImagineX holds and processes a significant amount of personal data of customers and employees. The Personal Data Privacy Commissioner ("the Commissioner") considered that stakeholders (in particular customers) have a reasonable expectation for ImagineX to implement a high standard of data security measures for its information systems.