ZALORA PERSONAL DATA PROTECTION POLICY

INTRODUCTION

ZALORA takes its responsibilities in relation to protecting your Personal Data and compliance with Applicable Laws very seriously. We are committed to properly managing, protecting and processing your Personal Data in accordance with this Policy, which shall apply to all Personal Data we collect from you through our Platforms.

Please read and review this Policy, which will inform you how we collect, use, process and disclose your Personal Data. We may also collect and process your Personal Data under any exceptions to Applicable Laws, which are not set out in this Policy. We trust that it will assist you in making an informed decision whether to provide us with any of your Personal Data.

For the purposes of understanding ZALORA's Personal Data Protection Policy ("Policy"), capitalised terms used in this Policy shall have the following meanings:

During our relationship with you, we may collect Personal Data from you. Examples of the types of Personal Data we may collect include your name, contact details, mailing and delivery addresses, email address, birthday, network and device data, your shopping or browsing behaviours, facial image, voice recording (for customer service calls) and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us. We will notify you when you must provide such Personal Data. Where it is mandatory to provide such Personal Data, please note that if you do not provide such Personal Data to us, then we may not be able to provide our services to you. We may also request other Personal Data from which is not marked as "mandatory" where it is entirely voluntary for you to provide such Personal Data (though please note that such personal data are used for the purpose of improving our understanding of our Platforms' and users and providing better products and/or services).

If you provide us with Personal Data relating to a third party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

By (1) clicking "Yes" on our Policy pop-up or any web form referring to this Policy on any of our online platforms, (2) submitting your Personal Data to us when signing up for an account on the Website or App, (3) browsing our Website or App, or (4) ordering any of our products and services, you are agreeing to the terms of this Policy, (5) submitting your Personal Data to us when participating in any competitions hosted on the Platforms, or (6) signing up to the Affiliate Programs, or Community Influencer Programs or any other programs organised by ZALORA, you acknowledge you are agreeing to the terms of this Policy.

We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect Personal Data from you when:

1. You register an account on the Website or the Apps;
2. You sign up to receive our newsletter(s) or update(s);
3. You make a transaction regarding the products available on our Website and Apps;
4. You activate or use any payment-related functions available on our Website and Apps or provided by our third party service providers;
5. You sign up to our Affiliate Programs, or Community Influencer Programs or any other programs organised by ZALORA;
6. You use any of our related services, such as subscribing to our newsletter, product notifications;
7. You browse our products and services or otherwise interact with our Platforms;
8. You accept our cookies on your device;
9. You interact with our Customer Service Team or other representatives, for example, via our chatbot, chat apps, messaging platforms, webform, emails, telephone calls, video calls, letters, or face-to-face meetings;
10. You interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;
11. You interact with us on our livestream channel, such as liking or commenting on a stream/video
12. You participate in our promotions, competitions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
13. We receive references from business partners and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;
14. You or your authorized representative submits your Personal Data to us for any purpose reasonably authorized by you, for example if such representative is purchasing our product or service to be delivered to you or as a gift;
15. Our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
16. When you voluntarily submit your Personal Data to us for any reason.

During the course of your use of our PlatformsWebsite and App and our provision of the products and services, you agree that you have provided your consent to the transfer of your personal data from us to the third parties for the purposes set out in this Privacy Policy or any other terms provided by our third parties and/or affiliates. Your credit card details may be collected, processed and stored directly by our third-party payment service providers pursuant to their terms of use and privacy policies. We may collect your bank account details to process refunds.Please also take note of our Cookies Policy below in respect of the data collected and used by third-party cookies and trackers on our Website and Apps.

We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.

Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the products and services you have requested.

HOW WILL YOUR PERSONAL DATA BE USED?

We may, via various mediums and modes of communications (where applicable), use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:

1. register and maintain your user account and to verify your identity or age;
2. register and maintain your Affiliate Program account, Community Influencer Program account or any other accounts connected to programs organised by ZALORA;
3. process your order for our products or services, process or collect your payment for the order;
4. deliver or perform the products or services you purchased, including our couriers calling or messaging you to obtain your delivery instructions;
5. verify and carry out payment transactions (including any credit card payments, bank transfers, remittances, or e-wallet transactions) in relation to payments related to you and/or services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to relevant third parties such as our payment service providers;
6. facilitate your use of payment-related services;
7. process your returns or refunds in accordance with our Terms and Conditions;
8. process your enquiries and resolving your complaints in accordance with our Intellectual Property Infringement Policy;
9. provide you with supporting services and functions related to your Website or App activity and/or user account, or which you have subscribed to, such as saved items in cart, wish list, brand or product notifications;
10. administering ZALORA’s loyalty or point redemption programme(s);
11. administering any competitions and communicating with you in relation to matters relating to such competitions, such as communicating competition terms and conditions, additional requirements, and winner announcements;
12. communicate with you in relation to (i) your queries, requests and feedback, (ii) material changes to our Website or Apps Terms of Service, Policy or other terms and conditions, and (iii) matters relating to the operation of your account;
13. personalise and improve your customer experience when you visit the Platforms, for example by prioritizing products and services appearing in your search results or feed;
14. monitor and enforce compliance with our Terms and Conditions, including dispute resolution;
15. comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law; and
16. ensure our Platforms function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Platforms.

(collectively, the "Purposes")

In addition, we may, via various mediums and modes of communications (where applicable), use and disclose your Personal Data for the following purposes, to:

1. send you marketing communications in relation to our Retail Goods and Services (as applicable), any promotions in relation thereto, or the Platforms, including notifying you of our marketing event, initiatives and promotions, competitions, lucky draws, loyalty or point redemption programs and other promotions;
2. send you marketing communications in relation to the Retail Goods and Services (as applicable) or promotions in relation thereto of business partners who provide such Retails Goods and Services (as applicable), including promotional mail together with your order;
3. deliver ads which are related to our Retail Goods and Services (as applicable) which may be of interest to you on the Platforms or other websites, apps or online platforms;
4. enable businesses to deliver ads which are related to their Retail Goods and Services (as applicable) which may be of interest to you;
5. provide you with our add-on or premium services such as ZALORA VIP;
6. invite you to our private customer events;
7. process your participation in our promotions, competitions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
8. process your participation in ZALORA’s or its business partners' loyalty or point redemption programs;
9. conduct market and customer research, analysis or tracking;
10. promote our products and services on our Platforms;
11. manage the administrative and business operations of ZALORA and complying with internal policies and procedures;
12. improve your customer experience across all touchpoints and training our Customer Service Team, such as by recording and monitoring phone calls; and
13. any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page;

(collectively, the "Additional Purposes")

We may also use your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws.

Note: We cannot use your Personal Data to send you any marketing communications without your consent. If you have given us your consent, you may withdraw your consent in accordance with paragraph 6 (Request to Withdraw Consent) below. If you withdraw your consent for us to use and process your Personal Data the Purposes or the Additional Purposes (except relating to sending you marketing communications), we may no longer be able to provide you with the related products, services or benefits associated with our promotion.

WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:

1. ZALORA’s affiliated entities;
2. employees, consultants, temporary workers;
3. ZALORA Marketplace sellers, who supply and deliver the products or services you ordered through the Website or Apps;
4. payment processors, who process your payment on the Website and the Apps;
5. third party payment service providers in order for them to offer payment-related services to you;
6. third party logistics providers, such as courier services which will deliver your order to you;
7. business partners who separately maintain an account with you for loyalty or referral or point redemption programs;
8. business partners or vendors in connection with the processing and administering of any promotion, competition, event, service, loyalty or point redemption programme organised by us;
9. professional advisers and consultants who provide legal and other advisory and consultancy services;
10. agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
11. any other party whom you authorize us to disclose your Personal Data to.

We may also disclose your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws.

We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.

DISCLOSURE OF YOUR PERSONAL DATA OUTSIDE OF ZALORA

We will only disclosure Personal Data outside of ZALORA [without your consent] if we have a good-faith belief that disclosure of the Personal Data is reasonably necessary to:

1. Meet any applicable law, regulation, legal process, or enforceable governmental request.
2. Enforce applicable ZALORA Terms and Conditions, including investigation of potential violations.
3. Detect, prevent, investigate or otherwise address any actual or suspected fraud, harmful or illegal activity, security, or technical issues.
4. Protect against harm to the rights, property or safety of ZALORA, our users, a third party or the public as required or permitted by law.

We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.

HOW CAN I ACCESS OR CORRECT MY PERSONAL DATA?

You may access or correct your name, e-mail address, birthday, shipping and billing addresses, contact numbers and other Personal Data by logging in to your user account on the Website or Apps under "Account Information" and clicking the "Edit" button under each relevant field.

For Personal Data that cannot be corrected by you by logging in to your user account on the Website or Apps, you may request to access and correct such Personal Data by submitting a written request to us via our customer service feedback form (available on https://www.zalora.com.hk/contact/ ) or by emailing our Data Protection Officer at here. We may need to request additional information from you to confirm your identity before providing the access or making the correction.

We will do our best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws.

Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.

We will send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by ZALORA within the year before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose or unless you and we agree that

Subject to obtaining your consent, we may send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.

REQUEST TO WITHDRAW PROCESSING

If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please inform us as follows:

1. to withdraw consent from receiving marketing or promotional communications via SMS and/or other modes of telecommunications: please unsubscribe by following the instructions provided there in; or
2. to withdraw consent from marketing or promotional emails: please click on the Unsubscribe link in the marketing or promotional emails or submit a written request via email to customer@hk.zalora.com; or
3. updating your settings in your account.

Note that, depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of our products or services.

Once we receive notification that you wish to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials or communications during this period.

If you withdraw your consent to receive marketing or promotional materials through a specific communication mode (e.g. SMS), we may still contact you for other purposes in relation to the products and services via other communication modes you have subscribed to (e.g. email).

You may (a) withdraw your consent for the collection, use and/or disclosure of any of your Personal Data or (b) make a request to delete your Personal Data in our possession or under our control by submitting a written request via email to customer@hk.zalora.com. We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent and it may take up to thirty (30) days for this to be reflected in our systems. Once this is complete, we will no longer collect, use and/or disclose your Personal Data, except for compliance, regulatory or other legal purposes.

ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.

We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized or accidental access, collection, use, disclosure, copying, modification, leakage, loss, damage, erasure, or alteration of your Personal Data. However, we will not be responsible for any unauthorized or accidental access, collection, use, disclosure, copying, modification, leakage, loss, damage, erasure, or alteration of Personal Data by third parties which is attributable to factors beyond our control.

When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised.

If Personal Data is transferred out of Hong Kong, we will comply with Applicable Laws in doing so. This includes: (i) obtaining your consent, unless an exception exists under Applicable Laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.

INFORMATION COLLECTED BY THIRD PARTIES

ZALORA uses the services of third party vendors, who may implement cookies on the Website. Advertisements on the Website may be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including Personal Data, collected by such third party cookies are subject to the privacy and data protections policies of the third party vendors and are not under our control.

You may reject third party cookies through the settings on your browser. Note that this may result in the loss of Website functionality, restrict your use of the Website, or delay or affect the way in which the Website operates.

Google Analytics

ZALORA uses certain Google Analytics functions. Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking.

ZALORA may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.

ZALORA also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show ZALORA ads on sites across the Internet. ZALORA and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors' past visits to ZALORA, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to ZALORA.

When you log on to the ZALORA website, ZALORA with the help of Google Analytics may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this Policy.

DISCLAIMER REGARDING THIRD PARTY SITES AND ITS SECURITY

We do not guarantee the security of Personal Data and/or other information that you provide on third party sites. As part of our ongoing efforts to provide value to you, we may choose various third party websites or applications to link to, and frame within our Platform and services. Your acceptance and use of the third party service provider’s platform and/or services shall be subject to terms and conditions as may be agreed between you and the third party service provider and at your own risk. Upon your acceptance of the third party service provider’s offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider) shall be subject to the applicable privacy policy of the third party service provider, who shall be the data controller of such data. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. Any queries or complaints relating to your acceptance or use of the third party service provider’s platform and/or services shall accordingly be directed to the relevant third party service provider.

CONTACTING US

For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Data Protection Officer via one of the following methods:

(a) ZALORA Hong Kong customer service	:	customer@hk.zalora.com or here
(b) Email address	:	dpo@hk.zalora.com

Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.

GOVERNING LAW

This Policy and your use of this Website shall be governed in all respects by the laws of Hong Kong, and the parties hereto irrevocably submit to the non-exclusive jurisdiction of the Hong Kong courts.

UPDATES ON DATA PROTECTION POLICY

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, ZALORA may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion.

Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Website. Any amended Policy will be posted on our website and can be viewed at https://www.zalora.com.hk/privacy-policy. By continuing to use our Platforms and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.

You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.

MISCELLANEOUS

Nothing in this Policy shall limit your rights under Applicable Laws.

The provisions of this Policy shall be severable, and if any provision, or part-provision, of this Policy shall be held or declared to be illegal, invalid, or unenforceable, such illegality, invalidity, or unenforceability shall not affect any other provision, or part-provision, of this Policy, and the remainder of this Policy, disregarding such illegal, invalid or unenforceable provision, or part-provision, shall continue in full force and effect as through such illegal, invalid, or unenforceable provision, or part-provision, had not been contained in this Policy.

This Policy will be in the English language and the Chinese language. In the event of any inconsistency between the English version and the Chinese version, the English version shall prevail.