Privacy Policy Statement: HONG KONG S.A.R.

I. Introduction

Your privacy is important to us. The purpose of this Privacy Policy Statement is to inform you how Origin Brands (HK) Limited (“ROAM”/ “we”) protects your privacy in accordance with Hong Kong S.A.R’s Personal Data (Privacy) Ordinance (“PDPO”). 

We pledge to meet fully the requirements of the PDPO alongside the associated regulations and guidelines as may from time to time be issued by the Privacy Commissioner for Personal Data of Hong Kong S.A.R.  If any part of this Policy conflicts with the PDPO and/or other applicable legislation, the law(s) shall prevail. 

This Privacy Policy Statement and ROAM’s Personal Information Collection Statement should be read, and are intended to operate, together.

II. Personal Data Collection

1. “Personal Data”: means any data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable. The definition of Personal Data excludes any anonymized data or data that cannot identify you in any way.

2. Personal data may be collected from you in one or more of the following ways:

a. when you visit and use our website (“Website”), information about you may be collected via the use of Cookies;

b. through your own submissions, including via the Website e.g. using the Contact Us page, creating a member account or signing up to our eNewsletter;

c. through your ongoing business relationship with ROAM; and

d. from other sources including our associated companies.

3. If you provide us with any Personal Data relating to a third party, (e.g. information of employees and/or authorised representatives), by submitting such information, you represent and warrant that you have a lawful basis for providing their Personal Data to us, and have obtained any applicable approvals, permits and/or consent. 

4. The provision of your Personal Data by you is voluntary. Please note, however that, if you choose to withhold your Personal Data, then depending on the circumstances, it may not be possible for us to provide our services and products to you or any entity you represent.

III. Type, Use and Disclosure of Personal Data

1. Personal Data collected or stored may include identification information (name, title), contact details (postal or e-mail address and telephone number), financial details, preferences (language settings), and other information collected by Cookies.

2. Any Personal Data we collect or store shall be used only for those purposes specified at the time of collection, as set out in the Personal Information Collection Statement, or as otherwise permitted or required by law.

3. Your Personal Data which we collect or store shall not be disclosed except with your
consent, as required or permitted by law, or in accordance with the Personal Information Collection Statement.

4. You may withdraw your consent to the use of your Personal Data at any time by notifying us of your decision via the Contact Details set out herein. Please note that upon such withdrawal of consent it may not be possible for us to provide our services and products to you or any entity you represent.

IV. Cookies

 1. “Cookies” are text files which hold small pieces of data regarding your browsing activities.  They are sent from a website to the device you use to access the website
and are stored in your device.  When you visit and use the Website, information about you may be collected via the use of Cookies. Such information may include the pages of our Website which you visit. 

 2. Cookies are used to ensure that we give you the best experience on our Website, including remembering your preferences and for maintaining your logged-in identity so you do not have to log in your account each time you visit.  We also use Cookies to monitor our Website’s performance, to compile user statistics, and further to
tailor effective advertising relevant to your interests.   They may also be used for other purposes as stipulated in the Personal Information Collection Statement.

 3. Some Cookies are generated by ROAM (“First-party Cookies”) and some are generated by third parties (“Third-party Cookies”).  We are unable to control Third-party Cookies,
but you can choose to disable them through your internet browser settings.

 4. For user statistics and traffic analytics of our Website, the data collected will be anonymised, i.e. they cannot be used to identify you as an individual.

 5. We recognise that not everyone is comfortable with the use of Cookies, and as such you can chose to disable Cookies at any time by changing the settings in your internet browser. If you choose to disable Cookies, then some functions of the Website may no longer be fully operational.

V. Direct Marketing

 From time to time we would like to share information with you regarding our projects, services and products.  We will only send you such marketing materials when we have received your express consent, for example when you tick the consent box when signing up to our eNewsletter. More information in this regard can be found in the Personal Information Collection Statement.

VI. eNewsletter

 Our eNewsletter is designed to keep you up to date on our collection, promotions and other ROAM or fashion related news.  When you subscribe to our eNewsletter we will collect and process your personal data in order to manage your subscription, which may include sending you customised information on our products by e-mail. Such collection and processes shall be undertaken in accordance with this Privacy Policy and the Personal Information Collection Statement. You can unsubscribe from our eNewsletter at any time without cost by clicking the “unsubscribe” button in our eNewsletter or sending an email
request to us at cs@roamcollection.com.

VII. Retention of Personal Data

 We will only retain your Personal Data for as long as it is necessary to fulfil the purpose for which it is collected, or as may be required or permitted by law. Thereafter commercially reasonable and technically feasible measures shall be taken to irrecoverable or irreproducible delete or anonymised your Personal Data. Further details with regards to how long your Personal Data will be retained for any specific purpose can be obtained via the Contact Details herein.

VIII. Access to and Correction of Your Data

You have the right to enquire as to whether we hold any of your Personal Data and request a copy of the same. If any of the held Personal Data is incomplete or incorrect you have
the right to require us to amend the same, and we shall refrain from using the relevant Personal Data until the amendments are made. Personal Data access and correction requests should be addressed to the Contact Details set out herein. Under the PDPO we are entitled to charge a reasonable fee to process such access and correction requests.

IX. Security

1. We take the security and protection of your personal data very seriously. As such, we:

a. store your Personal Data on secure servers with appropriate security arrangements, such as encrypted cloud drive, to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal of your Personal Data;

b. shall, as far as reasonably possible, restrict the disclosure of your Personal Data to those
employees directly involved in the purposes detailed herein; and

c. have provided employee training on Personal Data handling and the provisions of the PDPO.

2. We cannot, however, guarantee that no unauthorised use, disclosure interception
of, or access to, your Personal Data, accidental or intentional, will occur. To the extent permitted by law ROAM disclaims any and all liability for any direct or indirect loss, damage or other consequences you or any third person may suffer as a result of such unauthorised use, disclosure, interception or
access. 

X. Third Party Sites

1. The Website may contain links and references to external websites, including plugins to social media sites such as Facebook, Instagram and Linkedin, and equally external websites may contain links or references to the Website or ROAM (“External Websites”).

2. We have no control over and are not responsible for the privacy practices of the External Websites. You should therefore check the applicable terms, conditions and policies of the External Websites to determine how they will handle your personal data or other information collected from you.

 XI. Contact Details

All correspondence regarding your Personal Date should be addressed to our Group
Legal Counsel by email at group.legal@epichk.com, or by telephone at Tel: +852 3512 0800, or
by post at 6/F, EGL Tower, 83 Hung To Road, Kwun Tong, Hong Kong S.A.R. Please
indicate in the subject header the nature of your correspondence.

XII. Changes to Privacy Policy Statement

This Privacy Policy Statement may be amended, supplemented or otherwise modified (“Changes”) by ROAM at its discretion and without prior notice. These Changes will be
effective immediately upon publication on the Website. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest privacy policies.

XIII. Miscellaneous

1. This Privacy Policy Statement has been prepared in English. In the event that this Privacy Policy Statement is translated into any other language the English language version shall prevail.

2. If any provision, or part thereof, within this Privacy Policy Statement is found or deemed to be illegal, invalid or unenforceable, they shall be treated as having been deleted from this Privacy Policy Statement, and such illegality, invalidity or unenforceability shall in no way affect any remaining provision, or part thereof.

Updated by ROAM in March 2023

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