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Privacy Policy

SOGO Hong Kong Company Limited and Ronson Kwok Asia Pacific Limited ("SOGO" or "we" and "us" and "our" shall be construed accordingly) owns and operates SOGO department store and SOGO CLUB in Hong Kong.
 
This privacy policy describes how SOGO uses and discloses personal information of customers collected through our websites and online eStore services, including sogo.com.hk, SOGO Rewards Programme Hong Kong Mobile Application ("Application") and other SOGO owned or operated websites and online services that link to this policy (this "Policy") (collectively, the "Sites"), through our programmes and in our physical SOGO department stores ("Services"). This Policy does not apply to websites, apps and services that display or link to different privacy statements. Websites, apps and services co-branded with other partners may display or link to a joint privacy statement or separate privacy statements of our partners in addition to our Policy. SOGO has no control over the content of the linked apps, websites and/or webpages or the way in which the operators of those apps, websites and/or webpages deal with your Personal Data. You should review the privacy policy for those third party apps, websites and/or webpages to understand the ways in which your Personal Data may be used by those third parties. By accessing the Sites or utilizing the Services, you hereby consent to the use of your information, including your personal information, any information of others provided by you, as described in this Policy.

A. COLLECTION OF PERSONAL DATA
A.1 Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our Services.
A.2 Personal information that may be collected by SOGO for creation the SOGO Rewards Account and registering as the SOGO Rewards Member through our websites or Application may include:
- name, month of birth, gender, mobile number, email address, age group (collectively "Personal Data").
A.3 We may also collect information ("Information") about you such as:
- If you buy goods at our eStore or through our programmes or otherwise, what you buy, where you buy, how frequent you buy and rewards you earn, the balance of the SOGO Rewards points;
- If you buy goods at our eStore using credit card, the card number (4 digits) and card transactions.
- If you use your Mobile Application or buy goods at our eStore to accumulate SOGO Rewards points or redeem rewards, information such as your device ID and your location.
A.4 Please note that it is mandatory for you to provide certain categories of Personal Data (as specified at the time of collection). In the event that you do not provide any Personal Data marked as mandatory, we may not be able to provide you with our offers, rewards, products and/or services (including allowing you to register as SOGO Rewards member).

B. USE OF PERSONAL DATA
B.1 We may use the Personal Data and Information about you for purposes described in this Policy. Our use include:
(a) processing and managing your purchase and use of our products and services including operating, processing, maintaining and/or managing your SOGO Rewards Account and programme participation; (b) verifying your identity; (c) providing you with rewards, birthday promotions, vouchers or services under SOGO Rewards or lucky draws (where applicable); (d) providing you with customer services and taking actions in responding to your queries, feedback or claims; (e) communicating with you about your orders or purchases, our services, our brands, products, events or other promotional purposes, co-branded offers and partner offers, your accounts and programme participation, a competition or contest or lucky draws that you have entered and your requests for information; (f) performing research or statistical analysis in order to improve our products and services and for marketing and promotional purposes; (g) providing marketing materials in accordance with B.4 below and creating personalised promotions by combining your personal information with non personal information about you such as the amounts and types of purchases you make or nay benefits or awards your receive through the programmes.
B.2 SOGO may share and transfer (whether in Hong Kong or abroad) your Personal Data or Information in limited ways, such as:
(a) we may share Personal Data to others with your consent; (b) we may share information with SOGO and its subsidiaries and licensees and our other affiliated companies for marketing of our department stores and retail related purposes; (c) we may share information with companies that provide support services to us such as data entry services providers, customer database management services, credit card processors or other payment services providers, mailing houses, website hosts, secure data disposal services providers, customer contact services that helps us to market our products and services, promotions, product rewards, vouchers, redemptions and customer services ("Third Party Service Providers").
B.3 When necessary we may also disclose and transfer (whether in Hong Kong or abroad) your Personal Data and Information (a) upon lawful request in response to legal process or comply with law; (b) to enforce our agreements with you, our corporate policies and terms of use relating to your use of SOGO products and services through the Sites or the Services, (c) our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations for purposes specified in B.1 and B2 above or (d) to protect the rights, property or safety of SOGO or affiliates, its subsidiaries and licensees, our employees, agents, customers and others but only when it is reasonable to do so.
B.4 We may share unidentified aggregate data, customer statistics or anonymized information with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt to our products and services.
B.5 Any Personal Data supplied by you will be retained by us and will be accessible by our employees, the Third Party Service Providers and third parties referred to in B.2, 3 and 4 above, for or in relation to any of the purposes stated in B.1 herein.
B.6 We may permit individuals who are staff members of SOGO ("Staff Members") to use SOGO Rewards (including but not limited to registering as a SOGO Rewards Member and using the various functions provided by SOGO Rewards) but such Staff Members must at all times comply with all applicable codes of conduct and/or other relevant company policies of us and/or their relevant employer(s) when using SOGO Rewards. Notwithstanding anything stated herein, in the event it is found that a Staff Member misuses SOGO Rewards in his/her capacity as a Staff Member (including but not limited to using any confidential or other similar insider information to obtain an unfair advantage from any promotions or offers offered by SOGO Rewards), we will report the said matter to the relevant authorities for investigation and/or disciplinary purposes.
B7. If you participate in any blog or forum on our Sites, any personal information that you post on our Sites may be shared with other forum participants and Site visitors.

C. AUTOMATIC DATA COLLECTION THROUGH COOKIES AND WEB BEACONS
We may automatically collect website uses information when you visit our Sites. This information may include information about your Internet service provider, your operating system, browser type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. Our collection of website use information may involve the use of cookies and Web beacons. Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Sites and your experience. We use cookies to see which areas and features are popular and to count visits to our Sites. Web beacons are electronic images that may be used on our Sites or in our emails. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.

D. RIGHT TO ACCESS/CORRECT PERSONAL DATA
SOGO offers different choices for you to request to access, update, or change your Personal Data.
(a) Follow the opt-out instruction in promotional emails we send to you or contact our data privacy officer below:
Customer Services Department
SOGO Hong Kong Company Limited
555 Hennessy Road,
Causeway Bay, Hong Kong
Email: csteam@sogo.com.hk
(b) Log in to your SOGO Rewards Account and manage your profile by changing the options or opting out the communication channels (SMS/MMS, phone, email and correspondence address) preferences and to update your personal information.
(c) If you opt out of receiving promotional communication from us, we may send you non-promotional communications such as emails about your accounts information.
(d) SOGO will retain your Personal Data for one year, after termination or expiration of your SOGO Rewards Account or SOGO Rewards membership; sales records will be retained in system for analysis purpose.

E. UPDATES
We may amend or update this Policy from time to time without prior notice and your Personal Data collected shall be governed by our latest Policy. We will post the new Policy on the Application and websites. In case of discrepancies between the English and Chinese versions in respect of all or any part of this Policy, the English version shall prevail.
 
(Last updated: February 2020)

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