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Privacy Policy

yuu Privacy Policy

Last updated: [17 August 2020]

1. We care about your privacy

We care about protecting and respecting your privacy.  In order to serve you better and provide you with the best customer experience, we need to collect some personal data about you.  This Privacy Policy will help you understand how we collect and use your personal data, who we share your personal data with, and how you can control the way your personal data is collected and used by us.

If you access or use our website (www.yuurewards.com) (which we will refer to as “Site” in this Privacy Policy) or mobile application ("App"), or register to join as a member of our yuu Rewards Club ("Membership"), then this Privacy Policy is deemed to be agreed by you and will apply to you. If you do not agree with this Privacy Policy, please stop using our Site or App, and do not apply for a Membership. 

Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and will always give you the choice to opt out of such uses.

2. Who are we?

yuu Rewards Club is a lifestyle rewards programme ("yuu") that enables members to earn and redeem yuu points ("Points") in return for products, discounts, services, or vouchers (“Rewards”) from participating businesses (“Partners”). yuu is owned and operated by DFI Development (HK) Limited (“DFI”, "we", "us", “our”), the data controller, and an affiliate of Dairy Farm International Holdings Limited ("DFIHL").  Personal data we collect about you will be used in line with this Privacy Policy.  

3. How do we collect data?

Your personal data will either be provided by you, or will be collected by us, DFIHL, or any affiliates of DFIHL (“Dairy Farm Group”) or our Partners, or captured automatically. For example, we collect your personal data when you complete your Membership application, when you transact with a Partner and accumulate Points on your Membership account ("Account"), when you redeem a Reward, when you send us emails or when you browse our Site or App.

4. Are you over 18?

Our Site, App and yuu are only intended for people over the age of 18. However, if you are under the age of 18, you may only use our Site or App, or apply for a Membership if this has been authorised by your parent or legal guardian and you have obtained their consent to use our site or App, or become a yuu Member, on the basis of this Privacy Policy.

5. What information do we collect about you?

It may be necessary for you to provide us with certain personal data in order for you to receive the benefits of yuu, our Site or App. We will let you know when such data is essential for Membership. All other personal data is up to you to provide or not, as you prefer.

(a) Your Membership

If you are a yuu member ("Member"), some of the personal data we may collect about you includes:

  • your full name, month and year of birth, email address, telephone number, postal address, username, and password;
  • your Membership number ("yuu ID"), points balance, Account status and activities relating to your Account;
  • your transaction history or payment details when you purchase anything from our Partners and you use your Membership to accumulate Points (including the product or service purchased, the date of purchase, where you made your  purchase, the cardholder's name, credit card number, expiry date and billing information);
  • information about the Rewards you redeem; and
  • your shopping preferences, including brand preferences and the types of products and services you may be interested in.

(b) When you visit our Site or App

We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:

  • your visits to our Site or App, such as your browsing history, how long you stay on our Site or App, and how often you visit;
  • your location information as provided by your mobile or other device when you interact with our Site or App, including your IP address and general geographic location; and the device that you use to browse our Site or App (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.

(c) Other information

We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).

6. How do we use your information?

We will only use your personal data for the purposes set out below.

(a) Account administration

To help administer and maintain your Account, including:

  • creating and updating your Account;
  • verifying your identity;
  • creating a single profile about you, including combining your information with any other personal data already held by us or any members of the Dairy Farm Group;
  • processing Points issuance and Reward redemptions;
  • completing transactions, including processing or facilitating payments;
  • sending you updates about new features and benefits relating to yuu; and
  • enabling features that allow you to personalise your Account on our Site or App, such as bookmarking your favourite Partners.

(b) Customer support

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

(c) Marketing

To provide you with marketing and promotional materials ("Marketing Communications"), if you choose to receive them. Please see the section on Direct Marketing below for more information. 

(d) Personalisation

To create personalised Marketing Communications tailored to your interests and preferences, and to provide you with the best possible customer experience in relation to our Site, App and your Membership. We may also use data analytics tools to determine whether our or any Dairy Farm Group members' offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, or to customise the content and types of offers, products, services and Rewards that we present to you.

(e) Optimisation and improvements

We may use your personal data to understand and improve our Site, App or yuu operations, or our Partners' or Dairy Farm Group members' operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us, our Partners and our Dairy Farm Group members to enhance services or products, develop new features and benefits, and amend business, marketing and strategic operations and plans.

(f) Legal and administration purposes

We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.

7. Who do we share your information with?

To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymised or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your personal data) with third parties who may or may not be located overseas, as detailed in this section. By using our Site or App, or applying for a Membership, you agree to allow us to share your personal data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your personal data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.

(a) Partners

If you are a Member, your personal data may be shared with our Partners to facilitate the processing of Points issuance, Points redemption and related transactions, as well as for data analytics purposes in order to improve their operations, services or products.

Please be aware that our Partners may themselves directly collect personal data from you if you give it to them when you purchase any goods or services at their store, or if you register with them as a customer. The handling of your data collected by our Partners will be governed by the relevant Partner's separate privacy policy (and not this Privacy Policy), and we are not involved or responsible for the collection and handling of such data.

(b) Dairy Farm Group

Your personal data may be transferred to any Dairy Farm Group members for any of the purposes we have set out above. However, we will not provide your personal data to any Dairy Farm Group member in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.  

(c) Service providers

Your personal data may be shared with our or any Dairy Farm Group members' service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate yuu, our Site and our App, to conduct data analytics, to help aggregate and anonymise the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on behalf of our Dairy Farm Group members, for any of the purposes set out above.

We only use trustworthy service providers, who are under an obligation to only use your personal data in accordance with this Privacy Policy.

(d) Professional advisors and assignees

When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.

(e) Government and regulatory authorities

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy, shall be subject to the exclusive jurisdiction of the courts of Hong Kong.

8. Aggregated and anonymised data

Aggregated or anonymised data that does not include any personally identifiable information, may be used by us, our Partners, our Dairy Farm Group members or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.

9. Direct Marketing

If you have opted to receive offers and promotions from us, we may use your personal data to:

  • send you direct marketing communications in connection with the latest news, events, updates, offers, contests and promotions in relation to yuu;
  • send you direct marketing communications in connection with the latest news, events, updates, contests, promotions, offers, products, services and Rewards offered by our Partners or Dairy Farm Group members, which relate to retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications;
  • analyse your preferences, online behaviour and transactional history in order to gain insights, so that we can customise the content and types of news, events, updates, contests, promotions, offers, products, services and Rewards that we present to you via our Site, our App, our direct marketing communications, social media or other communication means; and
  • in conjunction with any seasonal events, lucky draws and contests or other promotional activities.

We may send you direct marketing communications and market research invitations by email, through your online Membership user account or in-app notifications on your mobile device, when you access the Site or App, or through online banner advertisements, post, telephone or SMS.

Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time not to receive any direct marketing communications from us. Please see the section on Your rights below.

10. Can our Partners or affiliates send you marketing materials?

We will not provide your personal data to our Partners or our Dairy Farm Group members for them to send you marketing materials, unless you allow this. 

If any of our Partners or Dairy Farm Group members wish to directly send you any marketing materials regarding their own products and services directly, then they must obtain your separate consent for this.  We are not involved in any marketing done directly by our Partners or Dairy Farm Group members that is unrelated to yuu. However, we may send Marketing Communications to you on behalf of our Partners or Dairy Farm Group members, subject to your consent and in accordance with the Direct Marketing section above. If you agree to receive any marketing materials directly from our Partners or Dairy Farm Group members, then please carefully read our respective Partners' own privacy policies.

11. How do we keep your information secure?

We take the confidentiality and security of your information seriously. We take all reasonable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification. All transactions under the terms and conditions of this Privacy Policy are based on the encryption of data exchanged between you and us on our secure Site and App. 

12. How long do we keep your data for?

We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it on our servers.

13. Your rights

(a) Access and correction

You have the right to access and correct your personal data held by us, at any time, by sending an email to our Data Protection Officer at [email protected].

In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.

(b) Opt-out of direct marketing

At any time, you can ask us to stop using your personal data to send you direct Marketing Communications, or you can customise how you would like to receive direct Marketing Communications from us. You can exercise your rights to do this by:

  • changing your settings on your online Membership user account or in the Site; or
  • following the unsubscribe instructions in the Marketing Communications we send to you.

We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you.

We are not involved or responsible for any marketing materials sent directly by our Partners or Dairy Farm Group members that are unrelated to yuu. If you would like to stop receiving any marketing materials from our Partners or Dairy Farm Group members, please contact them directly in order to unsubscribe from their mailing lists.

14. Online tracking technology

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.

We use cookies and other similar identification technologies such as web beacons and pixel tags on our Site, App, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our Site or App; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our Site and App; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our Site, our App and the websites of our Partners or Dairy Farm Group members.

You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.

15. Links to other sites

Our Site and App may contain links to other third party websites and applications, including those of our Partners or Dairy Farm Group members (“Third Party Sites”). We do not own or control, and are not responsible for the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our Site or App, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.

16. How do we manage updates to this policy?

From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by emailing you at the email address you provided us, and/or by posting a notice of these changes on our Site.

17. How to contact us

If you have any questions or comments concerning this Privacy Policy, you can contact our Data Protection Officer at [email protected]

 

Yuu to Me Privacy Policy

Last updated: 20 May 2021


1. We care about your privacy
We care about protecting and respecting your privacy.  In order to serve you better and provide you with the best customer experience, we need to collect some personal data about you.  
This Privacy Policy will help you understand how we collect and use your personal data, who we share your personal data with, and how you can control the way your personal data is collected and used by us.
If you access or use our mobile e-commerce service (“E-Comm Service”), or register to create an account (“User Account”) to use the E-Comm Service, then this Privacy Policy will apply to you.
Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and will always give you the choice to opt out of such uses.
 

2. Who are we?
The Dairy Farm Company, Limited (“Dairy Farm”, "we", "us", “our”) operates the E-Comm Service, and is the data controller. Personal data we collect about you will be used in line with this Privacy Policy.   
 

3. How do we collect data?
Your personal data will be provided by you, collected by us or our indirect or direct subsidiaries or affiliates (“Dairy Farm Group”), or captured automatically when you access or use our E-Comm Service. For example, we collect your personal data when you create a User Account, browse or make purchases through the E-Comm Service, and when you send us emails.
 

4. Are you over 18?
If you are under the age of 18, you must obtain your parent or guardian’s consent to use our E-Comm Service or apply for a User Account.
 

5. What information do we collect about you?
It may be necessary for you to provide us with certain personal data in order for you to use our E-Comm Service. We will let you know when such data is essential. All other personal data is up to you to provide or not, as you prefer.
 

(a) Your User Account
•    If you register for a User Account to use our E-Comm Service, some of the personal data we may collect about you includes: your mobile phone number, which we will use to send authentication codes via SMS to verify your identity;
•    your full name, gender, month and year of birth, education history, marital status, email address, telephone number.  This information helps us provide you with better personalized recommendations for products and promotions, but is not mandatory.  You may choose not to provide this information to us. Doing so will not affect the basic functions of the E-Comm Service;
•    account status and activities relating to your User Account.
 

(b) When you make purchases using the E-Comm Service
•    If you use the E-Comm Service to make online purchases, some of the personal data we may collect about you includes:
•    your product searches on the E-Comm Service, to provide autocomplete functionality or to provide you with information about products related to your search.  Please note that your search results do not constitute personal data unless we combine it with other information about you which would allow us to identify you.  If we do so, we will treat your search keywords as your personal data and store and secure your personal data as described under this Privacy Policy.  We may also use this personal data to improve our services;
•    your shopping preferences and choices with respect to favourites, purchases, follow/bookmarks and share functions offered on the E-Comm Service.  While using the E-Comm Service, you may indicate your interest in certain products and brands, and share this information with us or our third party partners through the E-Comm Service.  
•    your transaction history or payment details when you purchase anything through our E-Comm Service.  When you place an order through the E-Comm Service, you will be required to provide the recipient’s full name, address and mobile phone number.  The order form will set out your identification information (for example your photo or video, your name, telephone number etc.), the recipient’s address (or installation address for applicable products), the products/services you purchase, the order number, time of order, payment amount and payment method.  We collect this information (“Order Information”) in order to complete and secure your transaction, to allow you to review your order, and to provide related customer services to you. We also use Order Information to verify your identity, confirm the transaction, process payment and complete delivery, assist you with queries about your order and provide other after-sales services.  Further, we use Order Information to detect irregular activities to protect your transactions and User Account;
•    your identity, Order Information and contact information in order to verify your identity when you request any after-sales services and dispute resolution services.  If you send general enquiries or complaints to us, we may use your Order Information and any information you provide to our customer service representatives (including through any surveys) to provide services to you and make improvements to our services.
 

(c) When you visit our E-Comm Service
We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:
•    your visits to our E-Comm Service, such as your browsing history, how long you stay on our E-Comm Service, and how often you visit;
•    your location information as provided by your mobile phone or other device when you interact with our E-Comm Service, including your IP address and general geographic location (including GPS location and WLAN access point, Bluetooth and other connectivity information); and the device that you use to browse our E-Comm Service (e.g. your operating system, type of device, browser type and version, language preferences, resolution, internet service provider ID (PLMN), mobile application crashes and other system activity, and third party sites you were using before interacting with our services).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.
 

(d) When we provide additional services
We may offer the additional services described below to better personalize products and services offered to you and improve your shopping experience, and request that you provide additional personal information by granting permission for the E-Comm Service to access your devices’ location information, camera/webcam, photo album, microphone and address book.  If you do not provide the information described below, or revoke permissions granted, your use of the basic functions of the E-Comm Service will not be affected, however you may not be able to receive the additional services.  Please note that your decision to revoke permissions will not affect information previously collected and used based on your prior authorization.
•    Personalized recommendation service based on location information. We collect your location information to determine your location to recommend goods or services available in your area.  We will only collect information about your geographical location at specific points in time, and will not combine information about your location collected over different points in time to establish a trail of your movement.  For example, we may recommend supermarkets or stores nearest to you.
•    Additional features based on cameras / webcams.  You can use this additional feature to complete video shooting, picture taking, QR code scanning and other functions.
•    Additional features based on picture uploading.  After granting permission for the E-Comm Service to access photo albums on your device, you may use this feature to upload your photos to change your avatar, communicate with customer service representatives, and for verification purposes.  We may use the photos uploaded by you to identify goods or services you wish to purchase, or use comment so other messages containing photos uploaded by you.
•    Additional features based on voice technology.  After granting permission for the E-Comm Service to access the microphone on your device, you can contact customer service representatives and interact with the customer service bot. We will record your conversation to respond to your customer service or dispute resolution requests.
 

(e) Other information
We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).
 

6. How do we use your information?
We will only use your personal data for the purposes set out below.
 

(a) Account administration
To help administer and maintain your User Account, including:
•    creating and updating your User Account;
•    verifying your identity;
•    creating a single profile about you, including combining your information with any other personal data already held by us or any members of the Dairy Farm Group;
•    providing you with a log-in ID for your User Account to access our E-Comm Service;
•    maintaining, updating, administering and processing a record of your activities on our E-Comm Service, including any purchases or orders made by you through our E-Comm Service for any products or services (“Orders”) and any points or rewards in relation to any Rewards Programme;
•    completing transactions, including processing or facilitating payments;
•    sending you updates about new features and benefits relating to our E-Comm Service; and
•    enabling features that allow you to personalise your User Account on our E-Comm Service, such as bookmarking your favourite products or brands.
 

(b) Customer support
To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services, and to assist you with any delivery, refunds, returns or exchanges for any Orders.
 

(c) Marketing
To provide you with marketing and promotional materials ("Marketing Communications"), if you choose to receive them.  Please see the section on Direct Marketing below for more information.
 

(d) Personalisation
To create personalised Marketing Communications tailored to your interests and preferences, and to provide you with the best possible customer experience in relation to our E-Comm Service and your User Account. We may also use data analytics tools to conduct profiling and to determine whether our or any Dairy Farm Group members’ offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, or to customise the content and types of offers, products, and services that we present to you.
 

(e) Optimisation and improvements
We may use your personal data to understand and improve our E-Comm Service, or our partners’ operations, or our Dairy Farm Group members’ operations, through various means, such as the use of analytics tools, research, surveys and feedback forms.  This will enable us, our partners, and Dairy Farm Group members to enhance services or products, develop new features and benefits, and assess and amend business, marketing and strategic operations and plans.
 

(f) Legal and administration purposes
We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law in connection with your User Account, our E-Comm Service, or as requested by any law enforcement or regulatory authorities, courts or other governmental agencies.  We may also use your personal data in relation to any legal proceedings concerning you.
 

(g) Online purchase
To administer, process and manage your Orders, including any delivery, arrangement for collection, refunds, returns or exchanges.
 

7. Who do we share your information with?
To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymised or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your personal data) with third parties who may or may not be located overseas, as detailed in this section. By using our E-Comm Service, or applying for a User Account, you agree to allow us to share your personal data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your personal data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.
 

(a) Partners
If you create a User Account with us, your personal data may be shared with our partners to facilitate the processing of payments and delivery, conduct profiling and risk analysis of your User Account, and related services and transactions, as well as for data analytics purposes in order to improve their operations, services or products.
 

(b) Dairy Farm Group
Your personal data may be transferred to any Dairy Farm Group members for any of the purposes we have set out above. However, we will not provide your personal data to any Dairy Farm Group member in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.
 

(c) Service providers
Your personal data may be shared with our or any Dairy Farm Group members’ service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate our E-Comm Service, to conduct identity verification, profiling and data analytics/processing, process Orders and payments, arrange delivery, conduct marketing activities, to help aggregate and anonymise the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators and marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on behalf of our Dairy Farm Group members, for any of the purposes set out above.
We only use trustworthy service providers, who are under a duty of confidentiality to us and/or our affiliates, and are only permitted to use your personal data in accordance with this Privacy Policy.
 

(d) Professional advisors and assignees
When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers.  Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.
 

(e) Government and regulatory authorities
This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
 

8. Aggregated and anonymised data
Aggregated or anonymised data that does not include any personally identifiable information may be used by us, our Dairy Farm Group members or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.
 

9. Direct Marketing
If you have consented to receive offers and promotions from us, we may use your personal data to:
•    send you Marketing Communications in connection with the latest news, events, updates, contests, promotions, offers; products, services and rewards offered by us, our partners, or our Dairy Farm Group members, which relate to our E-Comm Service, reward programmes, retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications (“Marketing Subjects”);
•    analyse your preferences, online behaviour and transactional history in order to gain insights, so that we can customise the content and types of news, events, updates, contests, promotions, offers, products, services and rewards that we present to you via our E-Comm Service or Marketing Communications, social media or other communication means; and
•    in conjunction with any seasonal events, send you Marketing Communications in connection with lucky draws and contests or other promotional activities relating to the Marketing Subjects.
We may send you Marketing Communications and market research invitations by email, through your User Account or in-app notifications on your mobile device, when you access the E-Comm Service, or through online banner advertisements, post, telephone or SMS.
Before providing you with Marketing Communications, we will ask for your consent.  You can choose at any time not to receive any Marketing Communications from us.  Please see the section on Your rights below.
 

10. Can our partners and affiliates send you marketing materials?
If you have agreed to receive Marketing Communications from us, our Dairy Farm Group members or our partners may occasionally act as our service providers and send Marketing Communications on our behalf. However, we will not provide your personal data to our Dairy Farm Group members or our partners for them to send you marketing materials regarding their own products or services, unless you allow this.
If any of our partners or Dairy Farm Group members wish to send you any marketing materials regarding their own products and services directly, then they must obtain your separate consent for this.  We are not involved in any marketing done directly by Dairy Farm Group members that concerns any reward programmes, or products or services offered or provided by them, or by our partners that is unrelated to the E-Comm Service.  If you agree to receive any marketing materials from our partners or Dairy Farm Group members, then please carefully read our respective partners’ or Dairy Farm Group members’ own privacy policies.
 

11. How do we keep your information secure?
We take the confidentiality and security of your information seriously. We take all reasonable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification. All transactions under the terms and conditions of this Privacy Policy are based on the encryption of data exchanged between you and us on our secure E-Comm Service.
 

12. How long do we keep your data for?
We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it on our servers.
If your User Account is inactive for three (3) months or longer, we reserve the right to remove your personal data from your User Account. If you subsequently attempt to log into your User Account, you may need you to re-verify your identify or re-enter your personal details to continue using the E-Comm Service.
 

13. Your rights
 

(a) Access and correction
You have the right to access and correct your personal data held by us, at any time, by sending an email to our Data Protection Officer at [email protected].
In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.
 

(b) Opt-out of direct marketing
At any time, you can ask us to stop using your personal data to send you Marketing Communications, or you can customise how you would like to receive Marketing Communications from us. You can exercise your rights to do this by:
•    changing your settings on your User Account; or
•    following the unsubscribe instructions in the Marketing Communications we send to you.
We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your User Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you.
We are not involved or responsible for any marketing materials sent directly by our partners or Dairy Farm Group members that concern any reward programmes, or products or services offered or provided by them that are unrelated to the functions of the E-Comm Service.  If you would like to stop receiving any marketing materials from our partners or Dairy Farm Group members, then please contact them directly in order to unsubscribe from their mailing lists.
 

14. Online tracking technology
Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website or mobile application.
We use cookies and other similar identification technologies such as web beacons, ETags and pixel tags on our E-Comm Service, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our E-Comm Service; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our E-Comm Service; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our E-Comm Service and the websites of our partners and Dairy Farm Group members.
You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.
 

15. Links to other sites
Our E-Comm Service may contain links to other third party websites and applications, including those of our partners and our Dairy Farm Group members (“Third Party Sites”).  We do not own or control, and are not responsible for, the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our E-Comm Service, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.
 

16. Information you provide about others
Please ensure that you are legally authorized to share with us any information that contains personal data of another person.
 

17. How do we manage updates to this policy?
From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by emailing you at the email address you provided us, and/or by posting a notice of these changes on our E-Comm Service.
 

18. How to contact us
If you have any questions or comments concerning this Privacy Policy, you can contact our Data Protection Officer at [email protected].

 

We value your privacy and want to be transparent with why we collect your information
E-commerce Service Personal Information Collection Statement (PICS)

If you access or use this E-Comm Service or register to create an account (“User Account”) to use this E-Comm Service, then you are deemed to have agreed to this Personal Information Collection Statement.  This E-Comm Service is owned and operated by The Dairy Farm Company, Limited, the data user and an affiliate of Dairy Farm International Holdings Limited ("DFIHL"). You must be at least 18 years old to use this E-Comm Service.

 What do we collect?
It may be necessary for you to provide us with certain personal data in order for you to use our E-Comm Service. For example, we collect your personal data when you create a User Account, browse or make purchases through this E-Comm Service, and when you send us emails. We will let you know when such data is essential. All other personal data is up to you to provide or not, as you prefer.

 How do we use your information?
 We will use your personal information to:
1.     administer and maintain your User Account and provide customer support (e.g. update your account, verify your identity, create a single profile about you by combining your personal data already held by us, DFIHL or any affiliates of DFIHL (“Dairy Farm Group”), providing you with a log-in ID for your User Account, maintaining, updating, administering and processing a record of your activities on this E-Comm Service, complete any transactions including processing or facilitating payments, send you updates about new features and benefits, and communicate with you);
2.     in accordance with Section 9 of the Privacy Policy, provide you with marketing and promotional materials if you choose to receive them, create personalized communications tailored to your interests and preferences, and provide you with the best possible customer experience;
3.     improve our operations through various means, such as the use of data analytics tools, research, surveys and feedback forms; this will enable us to enhance our services or products, develop new features and benefits, and assess and amend business, marketing and strategic operations and plans; and
4.     investigate or handle any incidents, claims or disputes, defend or bring any claims or actions, or comply with applicable law or any requests from any regulatory authority, court or government agency.

Who do we share your information with?
To fulfil any of the above purposes, we may share your personal data with our Dairy Farm Group members, professional advisors, any Dairy Farm Group members’ service providers, and regulatory authorities, courts and other governmental agencies.  The service providers process personal data on our behalf to help us administer and operate this E-Comm Service, conduct data analytics, aggregate and anonymise personal data, or carry out any of the above purposes. We may also share your personal data with any third party in connection with a merger, acquisition, consolidation, restructuring, sale of assets, financing or any similar scenarios.  However, we will not share your personal data with any third party for them to send you any direct marketing materials regarding their own products or services.

Your rights
You have the right to request access to and correction of your personal data held by us at any time, by sending an email to our Data Protection Officer at [email protected].