ALLU Hong Kong Limited of 16/F, Tower 5, The Gateway, Harbour City, Kowloon, Hong Kong (the “Company”, “we”, “our”, “us”) is committed to protecting the privacy of the personal data (“Personal Data”) of employees, customers and other individuals entering our store (“you”) that we hold from our use of closed-circuit television (“CCTV”) systems.

To ensure that you can make informed decisions about providing your Personal Data to us, we outline in this privacy policy (“Policy”) our practices and the choices you have concerning our collection and handling of your Personal Data.

Please read this Policy carefully to understand our policies and practices regarding Personal Data and how we will handle it. By accessing and entering our store, you acknowledge that you have read this Policy, understand it and agree to it. If you do not agree to this Policy, please do not enter or remain in our store and immediately leave the vicinities of our store.

This Policy may be updated from time to time in our sole discretion and without prior notice. Any updates to this Policy will be posted on our website, and all changes shall be effective immediately when we post them. The latest version of this Policy shall supersede all earlier versions. Your entrance to our store after we make any updates is deemed to be acceptance of those updates. It is your responsibility to routinely review the most recent version of this Policy and remain informed about any changes to them.

1. Purpose of collection and use:

   The Company has placed its stores under CCTV video and audio surveillance for one or more of the following specific and legitimate purposes:

   1. 1. to ensure the safety and security of our employees, customers and other individuals who enter the store;
      2. to ensure the safety and security of our property, assets and merchandise from theft, damage or loss;
      3. to prevent, deter, and assist in the investigation of crime, fraud, and other unlawful or dishonest activities;
      4. to verify the accuracy of customer transaction details by cross-referencing recordings with internal documents as part of our fraud detection and prevention procedures;
      5. to handle your enquiries, requests and/or complaints to/against us;
      6. to detect and resolve issues with the CCTV systems and/or recordings;
      7. to conduct investigations, research and/or analysis with regards to incidents, activities and/or events occurred at our store; and/or
      8. any other incidental or associated purposes relating to the above, or any other purposes as specified to you when your Personal Data is being collected, or any other purposes which you may from time to time agree.

   We will not knowingly or intentionally use, share, or sell your Personal Data in ways which are unrelated to the above purposes without your prior express consent.

2. Personal Data we collect and how we collect it:

   Our CCTV systems collect the following types of Personal Data from you within their range:

   1. Video and image data: recordings of your physical appearance and movements within the store, in particular, publicly accessible areas where employees interact with customers and back-of-house areas used for merchandise storage;
   2. Audio data: recordings of conversations and other ambient sounds that occur within the vicinity of the cameras;
   3. Metadata: data associated with the CCTV recordings, which may include the date, time, and specific location of the CCTV.

3. Categories of data subjects:

   Employees, customers and other individuals entering the store are likely to be recorded on our CCTV video and audio by the surveillance system.

4. Recipients:

   To facilitate the purposes mentioned above, we may transfer, disclose, grant access to, or share your Personal Data with recipients located within or outside of Hong Kong, and your Personal Data may be transferred within or outside of Hong Kong. These recipients may include the following (collectively, the “Recipients”):

   1. Our parent company, Valuence Japan Inc., located outside of Hong Kong, who shall review the CCTV recordings as a data processor on the Company’s behalf in accordance with the Company’s instructions;
   2. The authorised personnel of the Company and Valuence Japan Inc. (in particular, by the personnel in charge of security and by the management personnel of the Company and/or Valuence Japan Inc.);
   3. Any authorised agent, contractor, or third-party service provider who provides administrative and maintenance services for the CCTV systems installed in the store;
   4. Any person under a duty of confidentiality to us and/or Valuence Japan Inc. (including auditors, legal advisors or other advisors);
   5. Our successors and assigns; and
   6. Any person, government, regulatory or law enforcement authority or administrative organisation.

5. Transfers outside Hong Kong:

   Video and audio surveillance footage from our CCTV system is stored in Hong Kong. The Company ensures that any Personal Data accessed from outside Hong Kong is protected by security standards and contractual obligations comparable to those required under the Personal Data (Privacy) Ordinance (Cap. 486).

6. ARetention period:

   Video and audio surveillance footage from our CCTV system is kept for the period necessary to fulfil the purposes described above unless a longer retention period is required by applicable law or necessary to protect the Company’s rights in the event of an incident, after which such video and audio surveillance footage will be securely destroyed.

   In the event of an incident relating to the security of people and property or a fraudulent activity, we may elect to remove the relevant video and audio surveillance footage from our CCTV system. Such footage shall then be stored on another medium for the time needed to complete the investigative procedures linked to this incident or activity and are only accessible to authorised individuals in this context.

7. Data Security

   The Company has implemented robust technical and organisational security measures to protect CCTV footage against unauthorised or accidental access, processing, use, loss or erasure. These measures include but are not limited to:

   1. Secure storage of recordings in locked, restricted access areas;
   2. Password protection for all systems used to access, view or store recordings;
   3. Maintaining a formal register of individuals authorized to access CCTV footage, ensuring proper documentation and control.

   Notwithstanding the above, you acknowledge and agree that complete confidentiality and security is not yet possible over the Internet.

8. Data subject rights:

   You are entitled to the following rights regarding your Personal Data held by us:

   1. Request access to your Personal Data;
   2. Request correction of your Personal Data;

   If you wish to exercise any of the rights listed above or if you have a question relating to the processing of your personal data, you can contact our Data Protection Officer:

   • by e-mail at the following address: alluhk.pp@allu.inc
   • by post at ALLU Hong Kong, Limited, 16/F, Tower 5, The Gateway, Harbour City, Kowloon, Hong Kong.

   We will endeavour to use appropriate technical means to ensure that you can access and correct your Personal Data. In accessing and/or correcting your Personal Data, we may ask you to authenticate your identity in order to protect the safety of your Personal Data. To the extent permitted by relevant laws and regulations, we reserve the right to refuse unreasonable requests (for example, requests which infringe the privacy of others). To the extent permitted by relevant laws and regulations, we reserve the right to charge a reasonable fee for the cost of processing any request set out above.