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April 26, 2023
PRIVACY POLICY
This privacy policy (the “Policy”) provides you with information about how DFS Group Limited collect your personal data, and about the cookies which are used by DFS Group Limited on websites belonging to DFS.
If you reside in, or plan to travel to, or make requests to reserve products at any of our shops, or purchase products or use services provided by any of our shops, People's Republic of China (https://www.dfs.com/en/hong-kong/privacy-policy-hk), the Pacific Islands (https://www.dfs.com/en/guam/privacy-policy-guam), the United States of America(https://www.dfs.com/en/new-york/privacy-policy-new-york), Australia (https://www.dfs.com/en/sydney/privacy-policy-sydney), Italy (https://www.dfs.com/en/venice/privacy-policy-venice) or France(https://www.dfs.com/en/samaritaine/privacy-policy-samaritaine), please read the relevant privacy policies.
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.
This Policy outlines the way in which the company DFS Group, whose registered office is at 15/F One Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong, and its affiliates as joint controllers (“DFS”), collect and process the personal data which concerns you (hereinafter, your “Data”).
This Policy is subject to all applicable data protection laws and regulations.
DFS has appointed an internal Data Protection Officer.
If you have any questions relating to the collection and/or processing of your Data by DFS, please contact the data protection officer at the following address: dpo@dfs.com
We collect personal information about you from various sources. For example, we collect and obtain information:
- Directly from you
We collect personal information you provide, such as when you make a purchase, register for an account or create a profile, sign up for one of our program(s), contact us, respond to a survey, book a reservation, make an appointment for in-store or virtual services, register for an event, interact with us in store (including in-store digital experiences) or via the DFS Customer Service, participate in a sweepstakes, contest, or other similar campaign or promotion, respond to a survey, apply for a job, or sign up to receive emails, text messages, and/or postal mailings.
Your Data is notably obtained from:
- DFS CIRCLE sign up and upgrade;
- Book an experience;
- Concierge and alteration services;
- Reservation and purchase of products,
- Product delivery;
- Click & Collect services;
- Refund tax services;
- Gift cards
- Loan of equipment
- in one of our stores. The staff in DFS US’ stores may also collect your Data and carry out Data processing within the framework of their activities.
- Using cookies and other automatic data collection technologies
- via online through the website https://www.dfs.com/,
- via 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)") When you visit our the website https://www.dfs.com/ (hereinafter, the “Website”), use one of our 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)"), open or click on emails we send you, or interact with our advertisements, we or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see Section 6 “Cookies and Similar Technologies” below.
- Through in-store and other offline technologies
In some cases, we record customer service calls for quality assurance. We also use Closed Circuit Television or CCTV in our stores for safety, security, fraud, loss prevention, and operational purposes. In addition, some of our stores utilize technology that transmits a Bluetooth signal to and/or works with your mobile device running DFS Website and/or DFS Platforms (e.g. the beacon). If you have enabled the beacon on your mobile device, we collect device information and other unique identifiers and Location Data when you visit our stores.
- From our third-party partners
We obtain information from third parties that we have partnered with, such as brands, application providers, third-party websites and other third parties we choose to collaborate or work with.
- From social media platforms and networks
If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including Instagram, Facebook, Twitter, Google, You Tube, and Pinterest) in connection with our Website or DFS platforms, we collect information that you share with us, or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.
- From Other Sources
For example, we may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you.
Children Data
Protecting the safety and privacy of children is very important to DFS. We do not knowingly collect or use the Data of minors under the age of majority in accordance with local legislations in force.
If you are under the minimum age requirement, please do not submit any Data without the express consent and participation of your parent or guardian.
If you believe that we have collected Data about a minor without such consent, please contact us at dpo@dfs.com and we will delete this information.
The Data which relates to you and which is collected by DFS is mainly:
· First name and last name;
· Civil status;
· National ID;
· Country of residence;
· Company name;
· Email address;
· Mailing address;
· Mobile and telephone numbers;
· Contact preferences;
· Date of birth;
· Bank details in the context of sales;
· Purchase and reservation history;
· Preferences and interests;
· IP address;
· Cookies and trackers;
· Login data;
· Chat conversations;
· Image, video, and other media.
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 Policy and that you have explained to that person that their personal data must be processed by us in order to complete the purchase.
Your Data is either:
· collected based on your consent; or
· required for the completion of your orders according to a contract; or
· collected for the purpose of pursuing a legitimate interest of DFS (e.g. the development of our commercial activity or to prevent fraud and counterfeiting)
· collected to fulfil DFS legal requirements.
You have no obligation to provide any information requested by us. However, if you choose to withhold requested information, we may not be able to provide you with any goods and services that depend on the collection of this information (particularly where our collection of this information is required by law).
Your Data is therefore collected and/or processed notably for the following purposes: View Details
In the particular case where you wish to communicate with DFS staff through third-party instant messaging services, DFS cannot guarantee the confidentiality and security of your Data or any other information exchanged through such messaging services. Companies offering this type of messaging services are themselves responsible for processing of your Data and comply with their own data protection and confidentiality policies. In this specific context, the processing of your Data by third-party messaging services remains outside DFS’s control: DFS therefore declines any responsibility in the context of this use.
Your Data will be processed by DFS and its business partners. We may share or transfer your Data as follows:
- within the DFS Group and LVMH Group worldwide, especially with the following departments:
· Concierge and alteration services;
· DFS Communication Department for the management of your requests and questions, and for sending you newsletters;
· DFS Security Department for managing the cybersecurity of the Website;
· DFS Legal and Internal Control Departments for the management of any possible fraudulent acts or legal actions.
- 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 brands whose products are sold on DFS Platforms or in our stores;
- 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, including at the negotiation stage;
- 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.
Except for these cases, your Data will not be transferred or made accessible to any third parties, subject to any restructuring of DFS, including a total or partial asset transfer, merger, absorption, acquisition, demerger and in general any reorganisation operation, subject to appropriate security and confidentiality measures.
You consent to the processing and storage of your Personal Data in locations other than the location from which you access the DFS Platform.
Since DFS is an international group and works with data processors located abroad, the recipients of your Data may also be located abroad, in countries/regions where runs its activities such as Singapore, the People’s Republic of China (PRC), Hong-Kong, and Japan (this list is not exhaustive).
Any transfer of Data will be governed by appropriate guarantees, notably contractual safeguards, in accordance with the regulations applying to the protection of personal data. DFS has taken all reasonable steps to ensure the security and confidentiality of your Data when it is accessed or stored in locations other than the one from which you access the DFS Platforms.
In accordance with the regulations in force, you have the following rights:
· Withdrawal of consent: you can withdraw at any time your consent for of any processing of personal data based on your consent, without affecting the lawfulness of processing based on your consent before its withdrawal.
· Access: you can ask us to confirm whether we process your personal data and, as the case may be, inform you of the characteristics of such processing, allow you to access such data and give you a copy of it.
· Rectification: you can ask us to rectify or complete inaccurate or incomplete personal data.
· Erasure: you can ask us to erase your personal data in the following cases: when it is no longer necessary for the purposes of which it was collected; you have withdrawn your consent and there is no other legal basis on which your data are processed; you objected to the processing of your personal data and DFS has no compelling legitimate grounds to refuse it; your personal data has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request notably if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
· Objection: (including to marketing) you can request not to receive direct marketing communications from DFS and for DFS not to disclose your Data to others for direct marketing purposes
These rights may be exercised at any time by contacting DFS’ Data Protection Officer at the addresses given in Article 2 of this Privacy and cookie Policy, or by following the relevant instructions on our marketing communications or following the instructions as set out in certain service-specific guidance.
Your request to exercise your rights will be processed as soon as possible and a reply will be given to you within 30 days at the latest (except for New-Zealand residents, see section above), except in the case of complex requests.
Please note that fees can be charged in some cases, and DFS’ DPO will inform you whether or not these fees apply.
If you are located or travelling to Macau
In addition with the rights mentioned in Section 9. “Your Rights”, you also have:
· Right not to be subject to automated decision-making: you have the right not to be subjected to a decision producing legal effects, which produce legal effects concerning you or significantly affecting you; and are based solely on the automated processing of data intended to evaluate personal aspects related to them, in particular: (i) performance at work, (ii) creditworthiness, (iii) reliability; or (iv) conduct.
When you are travelling to Singapore
In addition with the rights mentioned in Section 9. “Your Rights”, you also have:
· Data portability: you may give a porting organisation a request, called a 'data porting request,' that the porting organisation transmits to a receiving organisation any applicable data specified in the data porting request.
If you are located or travelling to Indonesia
In addition with the rights mentioned in Section 9. “Your Rights”, you also have:
· Restriction: it means that, in some cases, you have the right to ask DFS to temporarily freeze the use of some of your data
· Data portability: you have the right to obtain and/or use your Data in an appropriate form and/or in a commonly used structure or a format that can be read by electronic systems or interoperable between electronic system
· Right not to be subject to automated decision-making: you have the right to object to decision-making based solely on automated processing related to your profile
If you are located or travelling to the United Arab Emirates
In addition with the rights mentioned in Section 9. “Your Rights”, you also have:
· Restriction: it means that, in some cases, you have the right to ask DFS to temporarily freeze the use of some of your Data
· Data portability: it means that you have the right to (i) receive the personal data that is held by, or on behalf of, DFS concerning you, which you have provided to DFS in a structured, commonly used, and machine-readable format; and (ii) transmit that data to another data controller without hindrance from DFS to which the personal data. This right applies when the processing is based on (i) consent pursuant to Sections 5(1)(a) or 7(2)(a) of the 2021 Regulations; or (ii) a contract pursuant to Section 5(1)(b) of the 2021 Regulations; and the processing is carried out by automated means.
· Right not to be subject to automated decision-making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you
If you are travelling to New Zealand
In addition with the rights mentioned in Section 9. “Your Rights”, you also have:
· Data Portability: you can exercise your right to data portability, within the scope and limit of the Telecommunications Act 2001.
Please note, DFS will respond to your request, as soon as is reasonably practicable, and in any case not later than 20 working days after the day on which your request is received, except in the case of complex requests.
You may contact any competent supervisory authority, such as the one in the State of your habitual residence, place of work or of an alleged infringement of the legislation with any claims concerning the way in which DFS collects and processes your Data.
You may also contact us at the details above if you have a complaint about how we have handled your information. We will investigate your complaint and will use reasonable endeavours to respond to you in writing as soon as possible. If we fail to respond to your complaint within a reasonable time or if you are dissatisfied with the response that you receive from us, you may have the right to make a complaint to the Office of the Information Commissioner.
In the event of a change to this policy, DFS will inform you of the update of its Privacy policy, by mentioning it on the Privacy policy page of its Website and/or by email. By continuing to access or use the DFS Website and/or DFS Platforms, 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.
