ALLU Hong Kong Limited (hereinafter referred to as the “Company”) processes personal data in the course of its business operations. In the course of its business operations, the Company acknowledges its responsibilities under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and is committed to protecting the privacy, confidentiality, and security of personal data. In addition, when the Company collects personal information, it will provide a Personal Information Collection Statement (“PICS”) by appropriate means before or at the time of collection, as required by the PDPO.

1. Definitions

   The Company shall define “personal data” as: any data—

   1. 1. relating directly or indirectly to a living individual.
      2. from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
      3. in a form in which access to or processing of the data is practicable

2. Types of personal information

   The Company shall handle the following personal information.

   1. Customer information

      Name, date of birth, gender, address, phone number, email address, company name, or other contact information; etc.

   2. Inquiry information on goods and services

      Name, date of birth, gender, address, phone number, email address, company name, or other contact information; etc.

   3. Information on applicant for recruitment (i.e. job candidates)

      Name, date of birth, gender, address, phone number, email address, resume, qualifications, interview notes, and recruitment assessments, etc.

   4. Information on employees who are or formerly were on the Company's payroll

      Name, date of birth, gender, address, telephone number, email address, recruitment assessment, merit rating, employment records, payroll records, and related labor information, etc.

3. Purpose of use of personal information

   The Company shall use personal information within the scope necessary for its business operations, including but not limited to customer service, transactions, recruitment and employment administration, compliance, and business management. If the Company uses personal information for any purpose other than the following purposes of use, the Company shall specify the relevant purpose of use on a case-by-case basis and obtain the necessary consent in advance where required by law:

   1. To handle customer inquiries, provide after-sales services, or carry out procedures related to transactions;
   2. To provide guidance, including direct marketing materials, regarding the services, goods, or various plans and programs offered by the Company, its group companies, or other companies affiliated with the Company (please see Item 4 below for further details);
   3. To provide guidance related to the Company’s business activities, including but not limited to questionnaires, campaigns, and customer engagement, etc.;
   4. To assess whether to enter into a transaction, manage the transaction after it begins, and conduct credit management or claims management;
   5. For evaluating goods or services, or identifying customers;
   6. To prevent fraud, misuse, or unfair transactions;
   7. For marketing research or analysis;
   8. For the preparation of statistical data for management analysis and the use of the results of that analysis;
   9. To ensure proper handling and maintenance, or to improve the quality of service provided by operators or staff when interacting with customers by phone or in person;
   10. To evaluate job applications and make hiring decisions;
   11. For personnel administration, payroll, benefits, business communication, and other employment-related matters; and
   12. For the management of former employees’ records and contact information when necessary for legal, regulatory, or legitimate business purposes, etc.

4. Use of personal information for direct marketing purposes

   The Company intends to use customers’ personal information for direct marketing purposes only where permitted under the PDPO and, where required, after obtaining the customer’s prescribed consent or confirmation of no objection. Before using personal data for direct marketing, the Company will inform the customer of the types of personal data to be used, the categories of marketing topics, and whether the marketing is conducted by the Company or by a third party.

   In particular, we may use certain types of your personal information—such as your name and address—to contact you via various communication methods, such as email, regarding our auction-related goods, services, and campaigns. If you no longer wish for us to use your personal information for marketing purposes, please contact the Personal Information Executive Office (see Item 10 below).

   In addition, if the Company intends to provide your personal information to its group company, Valuence Japan Inc., or any other third party, the Company will obtain your express consent separately and will disclose the relevant categories of recipients and categories of marketing subjects. If you no longer wish for us to provide your personal information to third parties for marketing purposes, please contact the Personal Information Executive Office (see Item 10 below).

5. Acquisition, use and provision of personal information

   The Company will endeavor to collect personal information only to the extent necessary for the relevant purpose of use, and will take reasonable steps to ensure that the data is accurate and up to date where appropriate. The Company will not collect personal information in an unfair or unlawful manner. In addition, the Company will not use, disclose, or provide personal information to a third party beyond the scope notified to the data subject or otherwise permitted under the PDPO. The Company may transfer personal information to its group company, Valuence Japan Inc., for the purposes set forth in Items 3 and 4 above.

6. Security control measures of personal information

   The Company shall implement reasonable and practicable security measures to protect personal information against unauthorized or accidental access, processing, erasure, loss, use, or disclosure. Such measures may include access controls, password protection, encryption where appropriate, staff training, confidentiality obligations, and secure storage and disposal procedures. The Company shall also review and improve its security measures from time to time in light of technological and operational developments.

7. Entrustment of personal information

   The Company may entrust all or part of the handling of personal information to third-party contractors or service providers for the purposes of carrying out the uses described in this Policy. In such cases, the Company shall select contractors that meet the Company’s personal information protection standards and shall impose appropriate contractual or other restrictions to ensure that the contractors process the personal information only in accordance with the Company’s instructions and maintain confidentiality and security measures. The Company may conduct periodic reviews or audits of such contractors as appropriate.

8. Continuous improvement of the personal information management system

   The Company will review this Policy from time to time, develop internal rules and regulations, provide training to employees, and conduct appropriate internal audits in response to technological advancements, legal requirements, and social changes, in order to continuously improve the proper handling of personal information.

9. Request for disclosure of personal information, etc.

   A data subject may request access to and correction of personal information held by the Company, subject to the PDPO and any applicable exemptions. The data subject may also request that the Company notify him or her of the types of personal data held and the Company’s personal data practices, where applicable under the PDPO. Requests should be made in writing to the person or office specified in Item 10 below, and the Company may require verification of identity and may charge a fee permitted by law for processing certain requests.

10. Inquiries about personal information

    < Personal Information Protection Manager, Personal Information Executive Office, ALLU Hong Kong Limited. >

    Address.

    Unit A110, 16/F, Tower 5, The Gateway Harbour City, Kowloon, Hong Kong

    Tel: +852 3921 5280

    Email address. alluhk.pp@allu.inc