ALLU Hong Kong Limited. (hereinafter referred to as the “Company”) handles personal data in the conduct of its business. Upon execution of the business, the Company recognizes 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, sex, address, telephone number, email address, company name, or other contact details; etc.

   2. Inquiry information on goods and services

      Name, date of birth, sex, address, telephone number, email address, company name, or other contact details; etc.

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

      Name, date of birth, sex, address, telephone number, email address, CV, qualifications, interview notes and assessment for recruitment, etc.

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

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

3. Purpose of use of personal information

   The Company shall use the 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 each occasion, and obtain the necessary consent of in advance where required by law:

   1. For handling of inquiries from customers, or providing after-sale services, or carrying out procedures relevant to transactions;
   2. For provision of guidance including direct marketing materials with respect to services, goods or a variety of plans and programs of the Company, its group companies, or other companies affiliated with the Company (please see Item 4 below for further details) ;
   3. For provision of guidance relevant to business activities of the Company, including but not limited to questionnaires, campaigns, and customer engagement etc.;
   4. For assessing whether to enter into a transaction, managing the transaction after commencement, and carrying out credit management or claims management;
   5. For assessing goods or services, or identifying customers;
   6. For preventing fraud, misuse or unfair transactions;
   7. For marketing research or analysis;
   8. For preparation of statistical numbers for management analysis, and use of the results of analysis;
   9. For accurate handling and maintenance or improvements of quality of operators or staffs when dealing with customers by phone or directly;
   10. For assessing recruitment applications and making recruitment decisions;
   11. For personnel administration, payroll, benefits, business communication and other employment-related matters; and
   12. For administration of former employees’ records and contacts where 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 no objection. Before using personal data for direct marketing, the Company will inform the customer of the kinds of personal data to be used, the classes of marketing subjects, and whether the marketing is by the Company or by a third party.

   In particular, we may use your types of personal information, e.g. name and address, to contact you by methods of communication, e.g. email about our auction-related goods, services and campaigns. If you no longer want 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 classes of transferees and classes of marketing subjects. If you no longer want 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 strive to acquire personal information only to the extend 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 acquire personal information in a manner that is unfair or unlawful. 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 out in Items 3 and 4 above.

6. Security control measures of personal information

   The Company shall implement reasonable and practicable security measures to safeguard 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 instance, the Company shall select contractors that satisfy the personal information protection standards of the Company, and shall impose appropriate contractual or other restrictions so that the contractors process the personal information only on the Company’s instructions and maintain confidentiality and security protections. The Company may conduct periodic reviews or audits of such contractors where 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 education to employees and carry out proper internal audits, in response to technological development, legal requirements and social changes, so as to improve the proper handling of personal information on an ongoing basis.

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 the Company to notify him or her of the kind 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