PRIVACY POLICY
Last updated: 27th September, 2018
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. We have adopted this Privacy Policy (“Policy”) to govern 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 DFS or on DFS' behalf from time to time), we may make available (together, our "Site") or via a third-party website, or in one of our stores. This Policy is subject to all applicable data protection laws and regulations.
By accessing or using our Site, making requests to reserve products, or placing orders for or purchasing our products, 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 our Site. By continuing to access or use our Site, 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.
Our Site may contain links to third-party sites. DFS does not control these third-party sites 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 our Site.
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.
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. 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, making any purchase on the Site or sign up for Loyal T or other DFS membership online or in-store, 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 Site; 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 Site, such as Location Data, Log Data, page views and links to third-party sites you access through the Site;
• information we collect as you make requests to reserve products through the Site, 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, your preferred location of product delivery or pick-up, and other transaction details;
• other information you provide to us through the Site or when you interact with our customer service representatives, in-store personnel and other personnel, such as your feedback, reviews, opinions or complaints about the Site, or our products and services; and
• 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.
"Location Data" means information regarding your location when you access the Site, including the IP address of the device or Internet service you use to access our Site, the location of your device when you access the Site, and your activity status.
"Log Data" means technical information that we automatically collect when you use or access the Site, 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 usS in order to complete the purchase.
III. PURPOSE
We may use your Personal Data for any of the following purposes:
• 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 process your payment instructions when you purchase our products;
• to provide you with location-based services through the Site, such as personalized content;
• for customer service, including assessing any complaint or payment dispute and/or protecting and enforcing our rights;
• for the detection and prevention of crime including fraud, intellectual property infringement, misuse of our Site 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);
• 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), evaluate your creditworthiness;
• for archival and backup purposes in connection with the ordering and sale of our products;
• to offer you marketing materials and advertising as set out in Section VII;
• to better understand how you access and use the Site in order to improve and personalize the presentation of the Site to you;
• to conduct research, statistical analysis and behavioural analysis in relation to our Site and our products;
• to allow you to participate in surveys and other activities about our products;
• to administer and protect our business and Site, including troubleshooting, system maintenance, support, reporting and hosting of data;
• if you are a job applicant, to process your application as set out in Section VI; and
• 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.
Where we need to collect Personal Data 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 Site.
V. COOKIES AND SIMILAR TECHNOLOGIES
We automatically analyze trends and monitor usage statistics of our Site by tracking activity and behavior on our Site, the previous and following sites visited, the browser used and the computer’s IP address. You may browse our Site without telling us who you are or revealing your Personal Data. Depending on each Site you visit and/or use, you may be able to browse the Site without registering and logging in or telling us who you are or revealing your personal data. However, some of the functionality made available through the Site, in particular, any request to reserve our products, will not be available unless you provide us with Personal Data.
We use “cookies”, beacons (small pieces of information sent to and stored on your computer) and similar technologies ("cookies") on our Site to help manage your access and use of the Site, analyze your use of the Site, customize our services, measure promotional effectiveness and maintain Internet security. We use 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 cookies if your browser or operating system permits, but please note that doing so may interfere with your use of our Site and/or limit the functionality available to you.
DFS also works with advertising partners that use cookies, pixel tags and other tracking technologies to serve advertisements on behalf of their retail clients, including DFS, across the Internet, including to you after you have visited our Site. 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 our Site) 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 then use it in combination with Personal Data provided by you to DFS to enhance your experience on our Site.
VI. JOB APPLICANTS
We also offer interested visitors to our Site to complete and submit applications for employment with DFS. If you wish to submit an application and 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 in the application will be used solely for purposes relating to potential employment with DFS.
VII. 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 regarding new product launches and other promotional activities;
• communicating to you regarding our promotional events including where applicable, 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 third parties (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.
We will honor your request for us to not use your Personal Data for such direct marketing purposes noted above. If you wish to make such a request, please: (i) notify our Data Protection Officer at the address set out in Section XIII; (ii) follow the relevant instructions on our marketing communications; or (iii) follow the instructions as set out in certain service-specific guidance.
Please note that we will not share your Personal Data with advertisers unless you have given us your consent to do so.
VIII. 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 administrative, telecommunications, computer and other services to us in connection with the managing, processing and storage of your Personal Data);
• 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; or
• with financial institutions, card or other payment instrument issuers, credit providers or debt collection agencies; or
• (i) in order to comply with applicable laws or regulations (whether of your jurisdiction or elsewhere); (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations.
We may from time to time also use aggregate information about our customers to analyse 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.
IX. 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 country may not be equivalent to those in your jurisdiction of residence. However, we will perform 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.
X. 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.
XI. 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 your rights under this Section XI, you may direct such request to our Data Protection Officer using the contact details in Section XIII. Please note that, to the extent permitted under application law, we may charge you a reasonable fee for providing such access.
XII. AGE RESTRICTIONS
DFS recognizes a special obligation to protect Personal Data of young children. Therefore, children under 13 years of age (or such other age as may be determined by applicable law) should not use our Site.
XIII. DATA PRIVACY OFFICER
If you would like to make any inquiries about your Personal Data or request that we cease use of your Personal Data for the above purposes, please contact our Data Protection Officer at:
DFS Group Limited
Data Protection Officer
8/F., Chinachem Golden Plaza, 77 Mody Road
Tsimshatsui East, Kowloon, Hong Kong
or via email at dpo@dfs.com or dfs.legal@dfs.com
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