PRIVACY POLICY
I. INTRODUCTION
DFS Group Limited and its affiliates (“DFS”, “our”, “us”, or “we”) respect the privacy rights of our customers and others whose personal data we process.
This Privacy Policy (“Policy”) governs how we collect, store, use, process and disclose the information that you give us online through DFS.com or any mobile app or digital platform (including the DFS WeChat Mini Program or any other digital platform operated by us or on our behalf from time to time) we may make available (together, the "DFS Platform(s)") or via a third-party website, in connection with one of our events or in one of our stores. This Policy is subject to all applicable data protection laws and regulations.
By accessing or using the DFS Platform, making requests to reserve products, placing orders for or purchasing our products or using our services, you agree that we will process your Personal Data in the manner described in this Policy.
We may revise this Policy from time to time on notice to you by posting the amended terms on the DFS Platform. By continuing to access or use the DFS Platform, make requests to reserve products, or place orders for or purchase our products after an updated Policy is posted, you are agreeing to the revised Policy.
The DFS Platform includes third-party platforms and may contain links to third-party platforms. DFS does not control these third-party platforms or the companies or individuals who maintain them. We are not responsible for the actions of these third parties, or for any of your Personal Data that you provide to them after you leave the DFS Platform.
This Policy was written in English. To the extent any translated version of this Policy we make available conflicts with the English version, the English version controls.
If you are making requests to reserve products in one of our stores in Europe, or are purchasing products in or using services provided by one of our stores in Europe, we refer to you in this Privacy Policy as a "European Customer", and the "European Customer-Specific Terms" in Section XIV of this Privacy Policy will also apply to you.
II. YOUR PERSONAL DATA
We may collect the following information relating to you:
“Personal Data” means any information that relates to you from which it is practicable to ascertain your identity either directly or indirectly. Subject to applicable law, this may include the following:
• information you provide to us when you open an online account, download and register through a mobile app, make purchase on the DFS Platform or sign up for Loyal T or other DFS membership online or in-store, participate in a survey, competition, prize draw, giveaway or offeror sign up to attend one of our events, which may include the following:
o Name prefix (e.g., Mr., Ms.) and full name;
o Primary and secondary telephone numbers;
o Personal identifier (such as an identification card number or travel document details);
o Email address;
o National ID (where separately agreed);
o Physical address;
o Your account details with any third-party social media platform or other third-party service which you use from time to time to access the DFS Platform; and
o The name, personal identifier (such as an identification card number or travel document details) and mobile numbers of any person you nominate to complete your purchase and collect products from one of our stores on your behalf; and
o Country of residence;
• information we collect as you browse the DFS Platform, such as Location Data, Log Data, page views and links to third-party sites you access through the DFS Platform;
• information we collect as you make requests to reserve products through the DFS Platform, including details of the products you have reserved and your preferred location of pick-up;
• information we collect when you purchase our products, including details of the products you have purchased, payment instructions, details in your passport, your boarding pass or other travel related information (which may include demographical data such as age, gender, passport number and citizenship, date of birth and country of residence), your preferred location of product delivery or pick-up, and other transaction details;
• information you provide to us through the DFS Platform or when you interact with our customer service representatives (whether online or offline), in-store personnel and other personnel, such as your feedback, reviews, opinions or complaints about the DFS Platform, or our products and services;
• if you are a job applicant, information you provide us with as part of your job application and as part of any subsequent interview process, such as your professional references, and information about your education and job background; and
• if you are a contractor or commercial visitor to our premises.
"Location Data" means information regarding your location when you access the DFS Platform, including the IP address of the device or Internet service you use to access the DFS Platform, the location of your device when you access the DFS Platform, and your activity status.
"Log Data" means technical information we automatically collect when you use or access the DFS Platform, whether through cookies or otherwise as set out in Section V, including any unique identifier associated with your device, your browser settings and other information.
Where you provide us with any Personal Data relating to any other person (such as any person you nominate to complete your purchase and collect products from our stores on your behalf) you warrant and undertake that you have obtained and will maintain that person's consent to the collection and use of that person's Personal Data by us in accordance with this Privacy Policy and that you have explained to that person that their Personal Data must be processed by us in order to complete the purchase.
When you visit one of our brand partners in-store or participate in a branded promotion or event, our brand partners may also ask if you want to sign up to receive marketing communications directly from them about their events, products and services. If you provide your personal details to any of our brand partners, the use of that information will be governed by their privacy policy and cannot be managed through DFS. Please ask the relevant sales associate for details about their privacy policy and how you can manage your marketing communications preferences with them.
III. PURPOSE
We may use your Personal Data for any of the following purposes. If you are a European Customer, we have underlined the relevant "legal basis" under EU law for which we may process your Personal Data:
• to process your requests to purchase products or reserve products for subsequent purchase by you, including, as applicable, to process payments for products subsequently purchased and complete the delivery of products purchased by you at your requested location;
• to meet our contractual obligations to our landlord and airport authorities;
• to process your purchases and perform tax operations in our physical stores;
• to process your payment instructions when you purchase our products;
• to provide you with location-based services through the DFS Platform, such as personalized content;
• for customer service including assessing any complaint or payment dispute;
• to manage your registration to the DFS Platform or your subscription to Loyal-T or other DFS memberships from time to time;
If you are a European Customer, the above categories are processed on the basis of contractual necessity.
• to detect and prevent crime including fraud or other violations of applicable law;
• to keep records as may be required of DFS under applicable laws and regulations (whether in your jurisdiction of residence or elsewhere);
• to comply with applicable laws and regulations (whether in Hong Kong or elsewhere) and/or any request or demand by any law enforcement agent, regulatory authority or other government official (whether in Hong Kong or elsewhere);
If you are a European Customer, the above categories are processed on the basis of legal obligation.
• for archival and backup purposes in connection with the ordering and sale of our products;
• to better understand how you access and use the DFS Platform in order to improve and personalize the presentation of the DFS Platform to you;
• to conduct research, statistical analysis and behavioral analysis in relation to the DFS Platform, shopping habits and our products;
• to perform an automated processing of your personal data for the purposes of conducting analysis and sending communications based on your shopping preferences and interest, when you consented to receive marketing communications as set out in Section VIII below;
• to administer and protect our business and the DFS Platform, including troubleshooting, system maintenance, support, reporting and hosting of data, detection of intellectual property infringement or misuse of the DFS Platform;
• if you are a job applicant, to process your application as set out in Section VI;
If you are a European Customer, the above categories are processed on the basis of our legitimate interest to ensure the lawfulness and correct functioning of the DFS Platform and to improve our Services.
• to offer you marketing materials and advertising as set out in Section VIII; and
• to allow you to participate in surveys and other activities about our products.
If you are a European Customer, the above categories are processed on the basis of your explicit consent.
To the extent permitted by applicable law, we may also collect Personal Data for other purposes directly related to any of the foregoing and for any other purposes as may be agreed to between you and us from time to time.
We may from time to time also use aggregate information about our customers to analyze and develop the products and services we offer, the effectiveness of our advertising and marketing and for related purposes. This information will not identify any individual in particular.
Where we need to collect Personal Data required by applicable law, or under the terms of a contract we entered into with you, and you fail to provide that Personal Data requested by us, we may not be able to provide you the requested service or complete your transaction.
IV. LOCATION OF COLLECTION AND STORAGE
You consent to the processing and storage of your Personal Data in locations other than the location from which you access the DFS Platform.
V. COOKIES AND SIMILAR TECHNOLOGIES
We automatically analyze trends and monitor usage statistics of parts of the DFS Platform operated by us by tracking activity and behavior on the DFS Platform, the previous and following sites visited, the browser used and the device’s IP address. Similar technologies may be used on parts of the DFS Platform which are operated by third parties. Depending on which part of the DFS Platform you visit and/or use, you may be able to access or browse the DFS Platform without registering and logging in or telling us who you are or revealing your Personal Data. Unless you provide us with Personal Data some of the functionality made available through the DFS Platform, in particular any request to reserve our products, will not be available.
We use “cookies”, beacons (small pieces of information sent to and stored on your computer) and similar technologies (together "cookies") on the DFS Platform to help manage your access and use of the DFS Platform, analyze your use of the DFS Platform and our web page traffic, customize our services, measure promotional effectiveness and maintain Internet security. In particular, we use:
• Technical cookies to help identify you and maintain your signed-in status. We offer certain features that are available only through the use of cookies. You are always free to decline our cookies or modify cookie settings if your browser or operating system permits, but please note that doing so may interfere with your use of the DFS Platform and/or limit the functionality available to you, in particular, your ability to request reservation of our products through the DFS Platform.
• Profiling cookies that use pixel tags and other tracking technologies developed by third party advertising partners to serve advertisements on behalf of their retail clients, including DFS, across the Internet, including to you after you have visited the DFS Platform. These advertising partners engage in remarketing, online behavioral advertising and ad delivery and reporting. These advertising partners may collect anonymous information about your browser as it makes visits to websites across the Internet (including the DFS Platform) and your interaction with our advertising and e-mail communications. This anonymous information may also be used to tailor advertising for you and others elsewhere on the Internet. DFS will have access to the information collected by these advertising partners and can use it in combination with Personal Data you provide to DFS to enhance your experience on the DFS Platform.
• Third party analytical cookies which are software tools that provide analysis about how you interact with the DFS Platform. They gather specific information about the pages you visit and whether you have visited the DFS Platform multiple times but do not provide DFS with details such as your name and address. Examples of analytical tools that we use are Google Analytics and Adobe Analytics.
If you are a European Customer, from the moment you first access to the DFS Platform and, in any case, until you made a choice, you will be asked to consent to the use of profiling cookies and third-party analytical cookies. Consent may be provided by scrolling the DFS Platform or closing the banner.
You may decide to block, erase, deactivate cookies or other similar technology using settings of your browser or device. Each browser (and in some circumstances, each version of the same browser) and each device has a specific procedure to erase or deactivate cookies. Your preferences concerning cookies shall be set separately for each browser or device used, as the functionalities and options offered may vary. We recommend consulting the support pages of your browser or device to obtain more information.
VI. JOB APPLICANTS
You can complete and submit applications for employment on the DFS Platform. If you wish to be considered for employment with DFS, you must provide us with the Personal Data requested by the application form. If you do not provide such Personal Data, we cannot process your application. The information you provide will be used solely for purposes relating to potential employment with DFS.
VII. CONTRACTORS AND COMMERCIAL VISITORS
When visiting our premises you may be requested to provide us with Personal Data. We collect this Personal Data for health and safety, security and safeguarding purposes.
VIII. DIRECT MARKETING
With your consent, we may use your contact details forming part of your Personal Data for the purpose of sending you direct marketing that offers or advertises our products, which may include, without limitation, beauty and health products, fragrances and toiletries, fashion and accessories, food and beverage (including wines and spirits), watches and jewelry, household and lifestyle products, luxury products and gift items.
With your consent, we may contact you by mail, telephone, social media, SMS, text/picture/video message, fax and email. These communications may include:
• communicating to you about new product launches and other promotional activities;
• communicating to you about our promotional events including member exclusive events, store openings and workshops;
• communicating in and out of store services, promotions and events;
• DFS membership programs, birthday offers, sampling, digital campaigns, roadshows, and in-store promotion updates;
• communicating joint promotions or events with commercial partners (such as shopping malls, department stores, banks, websites, charities or non-profit organizations); and
• cross brand joint promotions and/or events with brands within the DFS Group of companies (where permitted by applicable law).
We will not share your Personal Data with advertisers without your consent.
If you want us to stop using your Personal Data for such direct marketing please: notify our Data Protection Officer at the address set out in Section XIV; follow the relevant instructions on our marketing communications; or follow the instructions as set out in certain service-specific guidance.
If you no longer wish to receive our newsletter, you can click the unsubscribe link at the footer of the newsletter.
IX. DISCLOSURE
Other than as permitted under this Policy or as otherwise consented to by you, we will not share or transfer your Personal Data to any other third parties for their processing for any purposes.
We may share or transfer your Personal Data as follows:
• within the DFS Group and LVMH Group worldwide;
• with agents, contractors, third party service providers (such as those providing delivery, recruitment, administrative, telecommunications, computer services and other services in connection with the managing, processing and storage of your Personal Data) who will process your data on our behalf and following our instructions based on specific arrangements;
• with regulatory authorities, airport authorities, landlords and concession partners, and customs and tax authorities;
• if we or any member of the DFS Group is acquired or decides to sell or reorganize any relevant part of our business, to any actual or proposed acquirer, assignee, transferee or successor who agrees to assume our obligations to you under this Policy;
• with financial institutions, card or other payment instrument issuers, credit providers or debt collection agencies; or
• in order to comply with applicable laws or regulations (whether of your jurisdiction or elsewhere) or to protect our rights or property; in order to comply with a court order, subpoena or other legal process; in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or where we believe it is necessary to comply with applicable laws or regulations.
X. INTERNATIONAL TRANSFERS
DFS is a global company, hence your Personal Data may be collected in, transferred to or accessed by DFS, our affiliates, suppliers and/or agents located in jurisdiction outside of your jurisdiction of residence. Please be aware that the privacy protection and legal requirements, including the rights of authorities to access your Personal Data, in some countries may not be equivalent to those in your jurisdiction of residence. However, we will perform a security assessment for the international transfers of Personal Data to the extent required by applicable law and take reasonable actions to protect your privacy, such as obtaining your consent or de-identify your Personal Data.
If you are a European Customer, when your Personal Data is transferred in countries which are not part of the EU, we will adopt necessary safeguards which include contractual agreements as Standard Contractual Clauses set forth by the EU Commission. As permitted by law, you may be entitled to request information concerning safeguards adopted for transfer to non EU Countries, including contractual agreements put in place, by contacting the DPO at the address set out in Section XIV.
XI. SECURITY
We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of your Personal Data. The safety and security of your Personal Data also depends on you, so you should keep your log-on credentials and passwords secure and confidential.
XII. YOUR RIGHT TO ACCESS AND CORRECTION
Subject to applicable law, you may have the right to request access to, correct and/or delete Personal Data we hold about you. Where required by law, we will facilitate your exercise of your rights.
If you wish to exercise such rights, you may direct your request to our Data Protection Officer using the contact details in Section XIV. Please note that to the extent permitted under application law we may charge you a reasonable fee for providing such access.
If you are a European Customer, you have certain additional rights under applicable law which are described in the European Customer-Specific Terms in Section XV.
XIII. AGE RESTRICTIONS
DFS recognizes a special obligation to protect Personal Data of young children. Therefore:
• Children under 16 years of age who are European Customers should not use the DFS Platform.
• In other jurisdictions, children under 13 years of age (or such other age as may be determined by applicable law) should not use the DFS Platform.
XIV. DATA PRIVACY OFFICER
You can contact our Data Protection Officer in the relevant jurisdiction at:
For Italy:
Mrs. Paola Pucci
Studio Toffoletto De Luca Tamajo e Soci
Via Rovello 12, Millan 20121, Italy
or via email at dpo@dfs.com
For other countries:
Data Protection Officer
DFS Group Limited
8/F., Chinachem Golden Plaza, 77 Mody Road
Tsimshatsui East, Kowloon, Hong Kong
or via email at dpo@dfs.com
XV. EUROPEAN CUSTOMER-SPECIFIC TERMS
If you are a European Customer, the below terms are incorporated into this Privacy Policy, and override the remainder of the Privacy Policy to the extent of any inconsistency.
a) DATA CONTROLLER
The Data Controller is:
• With regard to purchases in the Venice store, and performance of related tax operations: DFS Italy S.r.l. having its registered office at Milan, Corso Venezia no. 61 (Italy);
• With regard to online product reservation for subsequent purchases in store, your subscription to Loyal-T, and commercial/marketing activities on the website and related to Loyal-T: DFS Group Ltd, having its registered office at 8/F, Chinachem Golden Plaza, 77 Mody Road Tsimshatsui East, Kowloon, Hong Kong.
DFS Group Limited's representative in the EU is DFS Italy S.r.l.
b) YOUR RIGHTS
You may have the right:
• to request access to your Personal Data and obtain information concerning processing operations.
• to rectify your Personal data, or to have incomplete Personal Data completed, including by means of providing a supplementary statement.
• to request the erasure of your Personal Data, as well as the restriction of the processing, in the cases specified under applicable law.
• to request Personal Data you provided us in a structured, commonly used and machine-readable format and to request the transmission of those Personal Data to another controller, subject to specific conditions set forth under the law.
• to object to direct marketing activities, and to processing of Personal Data based on legitimate interest.
In addition, if you believe that your Personal Data have been processed unlawfully, you have the right to lodge a complaint to the competent data protection authority, such as that of your habitual place of residence.
c) DATA RETENTION
Your Personal Data will not be retained for a period of time exceeding what is necessary for the purposes for which it was collected and processed, in accordance with applicable law. In particular, your personal data will be retained for the time necessary to provide you with requested services, managing your transaction, registration or LoyalT subscription as well as for the function of the DFS Platform, unless you opt-out. In case of job applicants, we retain data until the closure of the job opening you have applied to.
We may also retain your Personal Data for the purposes of defending a right or a legal claim in judiciary proceeding or to fulfill a legal obligation, in accordance with applicable laws.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
d) AMENDMENTS TO THIS PRIVACY POLICY
In case of amendments to this Privacy Policy which might significantly affect your rights as a registered user, we will provide you with prior notice.