CURATING THE WORLD’S FINEST SENSATIONS

Duty Zero by cdf Membership Private Information Collection Statement (“PICS”)

This PICS contains important information about the privacy of Duty Zero by cdf Members (“Members”) and communications sent by CDF-LAGARDERE COMPANY LIMITED (“CDFL” or “Duty Zero by cdf”). By using your Duty Zero by cdf card (“Card”), you agree to the terms of this PICS, as amended from time to time.

  1. Your privacy

    The Duty Zero by cdf Membership Program (“Program”) is a loyalty program which gives Members the opportunity to receive benefits such as Shopping Point redemptions, special promotions, and updates about the latest products, promotions and membership administration. An important part of this is Duty Zero by cdf’s ability to communicate with Members. This PICS explains how Duty Zero by cdf collects, uses, discloses and otherwise handles the personal data of Members, and how we communicate with Members.

    We are committed to protecting your privacy. We value the trust that you place in us by providing to us your personal data and we are committed to taking all reasonable precautions to protect your personal data from misuse and keeping it secure by complying with all applicable data protection laws and regulations in Hong Kong, as amended from time to time. This PICS is available at dutyzero.com.hk.

  2. What we collect
    1. Collection of personal data through your submission

      Personal data consist of information in respect of an individual who is identified or reasonably identifiable. Submission of personal data can be obligatory or voluntary. For the obligatory submission, you must provide such personal data to us if you want us to provide the service for which you are applying. For the voluntary submission, it is entirely up to you to decide whether you want to provide such information to us or not.

      Obligatory submission includes:

      • when you join the Program, your name, address or email address, telephone numbers, date of birth, gender and any other information you provide on the Application Form, whether in hardcopy, online, or via other platforms recognised by Duty Zero by cdf. Further, each Member is assigned a Card and a Membership number, which are used for identification purposes by Duty Zero by cdf
      • when you shop with Duty Zero by cdf or a CDFL Affiliate using your Card, your Membership number and transactional information (including when and where you shopped, how you paid and what you purchased)
      • when you shop with a third party using your Card, your Membership number and transactional information (including when and where you shopped)
      • if you enter a Duty Zero by cdf promotion, the information you provide when submitting your entry, whether in hardcopy, online, or via other platforms recognized by Duty Zero by cdf
      • if you send us an enquiry or provide us with feedback, including your name, contact details, details of your enquiry or feedback and information about any response we provide, whether in hardcopy, online, via other platforms recognized by Duty Zero by cdf

      If you do not provide us with the information requested on the Application Form, or agree to our subsequent collection of your personal data as outlined in this PICS, we may not be able to enroll you as a Member and/or continue to provide relevant services.

      Voluntary submission includes:

      • when you shop with a third party using your Card, your Membership number and transactional information (including when and where you shopped)
      • after you shop the Shopping Points you earned and any rewards you have received

      Members can transact with Duty Zero by cdf anonymously, by paying cash in-store for purchases and not presenting their Card. However, if you do not provide us with your Membership details, you will not earn Shopping Points. You can also view the Duty Zero by cdf website without having to identify yourself, but if you would like to make specific enquiries about your Membership, we may not be able to assist you without identifying yourself.

    2. Collection of personal data through cookies

      Information is automatically collected through your use of the Duty Zero by cdf website and may be collected through your use of other platforms recognised by Duty Zero by cdf, through cookies. Cookies are small text files that websites or apps may place on your computer or device. Most often, cookies are used to recognize repeat users of websites and remember user preferences. We may collect this information both anonymously and in relation to user accounts. Cookies are also used to allow the website to track usage behavior and aggregate data to allow Duty Zero by cdf to customize a user\'s experience on their websites.

      For example, when you visit the Duty Zero by cdf website, we may use cookies to record information including your server address, the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used. The information is used and disclosed by Duty Zero by cdf for purposes including statistical analysis and to assist Duty Zero by cdf to improve the functionality and usability of the Duty Zero by cdf website. We also may work with advertising partners that use cookies, pixel tags and other tracking technologies to serve advertisements on behalf of their retail clients, including Duty Zero by cdf, across the Internet, including to you after you have visited our site. You may decline our cookies if your browser permits, although doing so may interfere with your use of the Duty Zero by cdf website.

      Similarly, when you use other platforms recognised by Duty Zero by cdf, Duty Zero by cdf may periodically collect and use technical data and related information (including technical information about your mobile device and system preferences), to facilitate the technical support and other services related to such platform.

    3. Collection of sensitive information

      Duty Zero by cdf only collects sensitive information where it is reasonably necessary for our functions or activities and either you have consented, or we are required or authorized by law to do so.

  3. Why we collect personal data
    1. Main purposes

      The main purposes for which we collect, hold, use and disclose personal data about Members are set out below:

      • to enroll Members in the Program
      • to administer Memberships, including issuing Cards and administering your account
      • to provide you with Shopping Points
      • to contact and communicate to Members information about Program Benefits, including but not limited to:
        • Shopping Point redemptions, birthday offer, special promotions, and updates about the latest products, promotions and membership administration
        • offers from Duty Zero by cdf, its Affiliates and third parties
      • performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes. This may include matching information we collect against other information held by third parties. (We may also use and disclose de-identified data about Members for these purposes)
      • protecting the security of our stores, staff, customers, suppliers and merchandise (including theft and fraud prevention)
      • answering queries and resolving complaints
      • general planning and administration purposes

      We may also collect, hold, use and disclose personal data for other purposes explained at the time of collection or which are required or authorized by or under law, and for which you have provided consent.

    2. Direct marketing and research

      By providing your address, email address and telephone numbers to Duty Zero by cdf, you consent to Duty Zero by cdf contacting you for the purposes set out above. We may send this information in a variety of ways, including by mail, email, social media, SMS, MMS, and telephone. You can opt out of being contacted by the ways listed under Clause 8.

    3. Email and mobile communication

      If you provide us with an email address or phone number, you consent to electronic communication such as notices or reminders being sent to you via that email address or phone number. Your email address must be unique, and for your security we recommend it is only accessible by you.

  4. Who we may share your personal data with

    We may share the personal data of Members with third parties where appropriate for the purposes set out above, including:

    • CDFL’s Affiliates
    • third parties which provides Benefits to Members
    • Duty Zero by cdf\'s contracted service providers, including but not limited to: delivery and shipping providers, overseas and local agents, information technology service providers, venues and event organizers, marketing and communications agencies, research and statistical analysis providers, call centers, hard copy and electronic mail houses, manufacturers and suppliers, and external business advisers (such as recruitment advisors, auditors and lawyers)
    • Regulatory, investigative or government bodies to comply with laws.

    We may ask one of these third parties to contact you directly for a specific purpose, and provide us with information collected from you in the course of providing the relevant products or services.

  5. Cross border disclosure of personal data

    We may disclose personal data to recipients which is located in other countries and/or regions, for example, Mainland China, depending on the services those recipients provide to Duty Zero by cdf.

  6. Data quality and security
    1. General

      We hold personal data in a number of ways, including in printed documents, electronic databases and email contact lists. Printed documents may be held at Duty Zero by cdf’s head office, or archived in boxes and stored in secure offsite facilities. We take reasonable steps to:

      • ensure that the personal data that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
      • protect the personal data that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
      • destroy or permanently de-identify personal data that is no longer needed for purposes permitted by laws.
    2. Security

      The steps we take to secure personal data include website protection measures, security restrictions on access to Duty Zero by cdf\'s computer systems, controlled access to Duty Zero by cdf\'s premises, policies on document storage and security, personnel security and training and workplace policies.

      While we endeavor to protect the personal data of the Members, we cannot guarantee the security of information you disclose online: you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact Duty Zero by cdf as set out in Clause 8. You can also help protect your personal data by keeping your account details confidential. If you become aware of any security breach, please let us know as soon as possible.

    3. Third party websites

      Duty Zero by cdf is not responsible for the privacy or security practices of third party websites, which are not covered by this PICS. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal data to them.

  7. Access and correction
    1. Members can update or correct their contact information by sending an email to Duty Zero by cdf pursuant to Clause 8.

      Members will take all the responsibilities for any result caused by incorrect or unclear information submitted to Duty Zero by cdf.

    2. Pursuant to the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region (“Ordinance”), you have the right to ask us if we hold any personal data about you and if so, to request a copy of some or all of your personal data. If you would like to make such a request, please submit the "Data Access Request Form" (the prescribed form (form:OPS003) can be downloaded from the following link http://www.pcpd.org.hk/english/publications/files/Dforme.pdf), along with appropriate proof of identity (a copy of the applicant\'s Hong Kong Identity Card or Passport) to our Duty Zero by cdf Customer Service Team by the ways listed under Clause 8. We may charge you a fee at a level permitted by the Ordinance for this service. We will allow your data access request unless we consider that there is a sound reason under the Ordinance or other relevant law to reject the request.

  8. Opting out of being contacted, complaints or questions

    If you would like to opt out of being contacted for purposes listed under Clause 3.1, if you would like to make a personal data access request under Clause 7.2, if you wish to lodge a complaint in relation to an alleged breach of the laws related to privacy, or if you have any further queries, please email our Duty Zero by cdf Customer Service Team by customerservice@dutyzero.com.hk.

    All complaints received by the Duty Zero by cdf Customer Service Team will be dealt with fairly and in a timely manner considering all the circumstances of the complaint.

    In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.

  9. Amendments to this PICS

    Duty Zero by cdf may revise this PICS from time to time by posting the amended terms on Duty Zero by cdf website dutyzero.com.hk. All amended terms automatically take effect immediately upon posting. Your continued use of membership after an updated Privacy Policy is posted signifies that you accept all its revisions.

    If you do not agree with any amendments to this PICS, you have the right to terminate your participation in the Program in accordance with clause 11 of the Duty Zero by cdf Membership Program Terms.

  10. Interpretation

    Capitalized terms used in this PICS have the meaning given in the Duty Zero by cdf Membership Program Terms.

    This PICS is written in both English and Chinese (traditional Chinese and simplified Chinese). In case of discrepancies between the English and Chinese, the English version shall apply and prevail.