Hong Kong R&C Privacy Policy Version 1.1. Date 13.08.2018

HONG KONG RESERVE & COLLECT WEBSITE

Privacy Policy

1. Introduction

The website under the domain “www.shopdutyfree.com” (hereinafter the "Website" or "Reserve & Collect") is owned and operated by The Nuance Group (HK) Ltd, a Dufry group company (hereinafter "Dufry", "we", "our", and "us"), with registered address at Suite 601-604, One Citygate 20, Tat Tung Road, Tung Chung, Lantau, Honk Kong, China with Company Registration number 0581846, registered in Hong Kong, and with contact email address: legal@dufry.com, and is the data user for the personal data processed in accordance with this privacy policy (the “Privacy Policy”).

This Privacy Policy governs the way we treat all the personal information you provide or that we have obtained from you, including through the Website. This data will be processed in accordance with the privacy, data protection and e-commerce laws applicable at the relevant time.

2. Using your personal information

When you choose to use the Website, we may ask you to provide some personal information, for example, when you register on the Website, when you subscribe to one of the services offered on the Website or when you place a pre-order. The personal information requested and processed includes, but is not limited to, your name, address, email address, telephone number, year of birth, etc.

The provision of your personal information is voluntary. However, if you do not provide us with your information we may not be able to fulfil your request. Your personal information allows us to give you access to all parts of the Website and to provide all the services that you have requested. This also allows us to contact you should it be necessary after you have used the Website. We will also use and analyze the information that we receive so that we can administer, support, enhance and further our services and/or our Website.

We intend to use your personal data for marketing purposes and your consent is required in order for us to do so. With your consent, we will use / transfer your name and contact information for the purpose of sending sales information (including the electronic newsletter) or notify you of special offers or promotions on related products, activities and services provided by DUFRY, by post, email, SMS, or any other equivalent means of electronic communication. We may also share your name and contact information with other companies in the Dufry group (who offer the same kinds of products and services) and third party companies with which DUFRY has trade agreements (who offer travel, station and accommodation-related products and services) to enable them to send their sales information (including the electronic newsletter) to you.

We may also use your personal information to ask you to participate in customer surveys or to provide information about our services and/or the Application. If you provided your consent but subsequently do not wish to receive marketing communications from us, please inform us by sending an email to privacy@dufry.com or follow the instructions that will be provided in each communication.

3. Disclosure of personal information

We may transfer or disclose your personal information within our corporate group, and outside our corporate group to third party service providers including (but not limited to) providers of hosted IT solutions, mail houses and call centres for the purposes of those third parties providing services in connection with the provision of services related to the Application. We may also transfer or disclose your personal information in connection with a joint venture or the proposed sale or as a result of the actual sale of all or part of the assets of, or shares in, the company.

DUFRY will not trade, rent or sell your personal information. DUFRY does disclose or otherwise transfer your personal information, except as otherwise set out herein. Personal information will be used by DUFRY only for the purposes of providing services and performing its various obligations. However, DUFRY may need to disclose and share personal information with government authorities or regulators when it is necessary to comply with a court order, any on-going judicial proceeding, or other legal, statutory or regulatory process served on DUFRY or to exercise the legal rights or defend against legal claims, criminal investigations, judicial matters or in prevention, investigation, detection, prosecution of criminal activities or matters related to national security.

4. Where do we store your personal data?

DUFRY informs you that the personal information you have provided will be included in a file owned by it, the purpose of which is to manage the business relationship with you, in accordance with the provisions of the data protection laws of Hong Kong and the EU General Data Protection Regulations to the extent applicable. We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded on paper files that we store securely.

5. Do we disclose personal information to overseas recipients?

We disclose your personal information to recipients which are located outside Hong Kong. Those recipients are likely to be Dufry group entities located in Switzerland. You will be responsible for providing accurate information to ensure the authenticity of the data entered when completing a form.

6. Security and retention of personal information

We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain benefits of the Website, you are responsible for safeguarding it and keeping it confidential and you undertake not to allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of using the Internet and will not hold us responsible for any breach of security unless we have been negligent and only within the limits set out in the Terms and Conditions of this Website. We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or directly related purposes.

7. Rights over your personal information

At any time, you may exercise your rights of access and rectification as well as withdraw your consent for use and/or transfer of your data for direct marketing. To do this, you can write to Dufry AG, Brunngässlein 12 Basel, 4052, Switzerland, to the attention of the Global Data Protection Co-ordinator, or send an email to privacy@dufry.com stating your name and telephone number. Finally, we inform you that DUFRY will keep your personal information strictly confidential at all times and comply with the mandatory duty of confidentiality, adopting for that purpose the technical and organisational measures necessary to ensure the safety of your personal information and prevent its alteration, loss, or unauthorized processing or access, given the state of technology, the nature of the data stored and the risks to which they are exposed.

8. Changes to our privacy policy

We may make changes to our privacy policy from time to time. We will publish in this Application any changes we make to our privacy policy in the future and/or take any other action required under applicable law.

9. Links to third party applications and/or websites

This privacy policy only applies to this Website and does not apply to other third party websites and/or websites that may be accessed via this Website.

Our Website may contain links to and from websites and/or the websites of our network of partners, advertisers and affiliates. These are only provided for information purposes. If you follow a link to any of these websites, please remember that they have their own privacy policies and that we do not accept any responsibility arising under their policies.

You should therefore carefully read the privacy policies of each of these third parties.

10. Complaints

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out above.

Dufry 2018

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