In this course · 4 of 8
Course 5
Customers, data and payments
8 lessons · 8 min
- 1What does the Trade Descriptions Ordinance require of online product listings?
- 2Is there a cooling-off period for online purchases in Hong Kong?
- 3What product safety rules apply to consumer goods sold online in Hong Kong?
- 4What do I need to do with customer data to comply with Hong Kong privacy law?
- 5Do I need consent to send marketing emails or WhatsApp messages in Hong Kong?
- 6How do Stripe, PayPal and other payment gateways work for a Hong Kong online store?
- 7How can an online company open a bank account in Hong Kong?
- 8Can an online store sell gift cards or store credit without a licence?

The short answer
Customer names, addresses, emails and phone numbers are personal data under the Personal Data (Privacy) Ordinance (PDPO). A Hong Kong store must collect only what it needs, tell customers why, keep it secure, not keep it longer than necessary and let people access and correct it. The six data protection principles apply.
The Personal Data (Privacy) Ordinance (PDPO) applies to the store as a "data user" whenever it handles personal data of living people. Its Schedule 1 sets out six data protection principles in plain terms:
- Purpose and means of collection: collect only data that is needed and adequate, by lawful and fair means, and tell people why you collect it and who it may go to (a privacy statement or notice at checkout).
- Accuracy and retention: keep data accurate, and do not keep it longer than needed.
- Use: use data only for the purpose collected or a directly related one, unless the customer agrees.
- Security: protect data from unauthorised access or loss, including when it is held by platforms or contractors.
- Openness: publish your policies and practices.
- Access and correction: let people see and correct their data.
The Office of the Privacy Commissioner for Personal Data (PCPD) can investigate complaints and issue enforcement notices, and some breaches are offences. Sending data to a third party for marketing, or buying a customer list, has extra rules. On data breaches, check the PCPD's current guidance, since the notification regime has been under review.
Legal basis and sources
The law
- Personal Data (Privacy) Ordinance (Cap. 486), Schedule 1
General information for business owners, not legal, tax or professional advice. Rules change, so check the sources or ask a licensed professional before you act.
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