7-FANS PRIVACY POLICY

(Version: August 2017)

The Dairy Farm Company, Limited 牛奶有限公司 trading as 7-Eleven ("7-Eleven" or "we" and "us" and "our" shall be construed accordingly) owns and operates 7-Eleven in Hong Kong and Macau. We recognise the importance of your privacy and maintaining the confidentiality of your personal information. This Privacy Policy applies to all products and services provided by us including but not limited to the app or such other program or software named as 7-Fans ("7-Fans") and sets out how we may collect, use and disclose your personal information. We pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) ("Ordinance") in Hong Kong. In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.

A. COLLECTION OF PERSONAL DATA
A.1 Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our products and/or services and to operate your 7-Fans account ("7-Fans Account"). A.2 We may ask you to provide personal information when you use 7-Fans and your 7-Fans Account, including when you register as a 7-Fans member. The personal data that we may ask you to supply includes without limitation to name, day and month of birth, age group, gender, phone number, email address, mailing address, occupation, payment account details and where applicable, your Octopus card number (collectively "Personal Data"). A.3 Please note that it is mandatory for you to provide certain categories of Personal Data (as specified at the time of collection). In the event that you do not provide any Personal Data marked as required, we may not be able to provide you with our products and/or services (including registering you as 7-Fans member).
B. USE AND DISCLOSURE OF PERSONAL DATA
B.1 If you provide any Personal Data to us, you authorise us to collect, retain and use Personal Data about you for the following purposes:
a. operating, processing, maintaining and/or managing your 7-Fans Account; b. processing, verifying and/or making refunds of money into the e-wallet function of your 7-Fans Account (where applicable); c. verifying your identity; d. providing you with rewards, birthday promotions, vouchers or services under 7-Fans or lucky draws; e. providing you with customer services and responding to your queries, feedback or claims; f. performing research or statistical analysis in order to improve our products and services and for marketing and promotional purposes; g. providing Marketing Materials in accordance with B.4 below; h. in connection with establishing, maintaining and/or running any subsidiary or ancilliary clubs/programs under 7-Fans (whether or not such clubs/programs may bear the words “7-Fans” in their name, and for the avoidance of doubt, 7-Fans shall include such clubs/programs); and i. making such disclosures as may be required for any of the above purposes or as required by law or in respect of any feedback or claims made by you.
B.2 You further agree that we may disclose and transfer (whether in Hong Kong or abroad) your Personal Data to third party service providers engaged by us to provide (a) data entry services, (b) customer database management services, (c) customer contact services (and service providers may contact you regarding promotions, product rewards, vouchers, redemptions and customer services), (d) services in relation to processing, verifying and refunding money into the e-wallet function of your 7-Fans Account (where applicable), and (e) secure data disposal services ("Third Party Service Providers"). The Third Party Service Providers are under a duty of confidentiality to us and are only permitted to use your Personal Data in connection with the purposes specified in B.1 above, but not for their own purposes (including direct marketing). B.3 When necessary we may also disclose and transfer (whether in Hong Kong or abroad) your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations for purposes specified in B.1(h) above. B.4 We may only use your name, phone number and email address with your consent or with your indication of no objection to provide marketing materials to you relating to 7-Fans and/or your 7-Fans Account and goods/services which may be redeemed under 7-Fans and/or your 7-Fans Account, including goods and services provided by (a) 7-Eleven; (b) other business units owned and operated by The Dairy Farm Company, Limited 牛奶有限公司 (including Wellcome, Market Place by Jasons, Jasons Food & Living, ThreeSixty, Oliver's The Delicatessen, Mannings, Mannings Plus, Mannings Baby, GNC and IKEA); and (c) 7-Eleven’s partners. Such goods and services for each of the foregoing shall include the following classes: retail, cosmetics and beauty, health, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, betting (lucky draw), dining, travel, transportation, banking, electronics, home, household, textile, tele-communication, food and beverage, grocery, office and business supplies, technology, outdoor, furniture, lighting, décor, media (including digital), e-commerce platform and facilitator (including online trading, payment and auctions), bill payment, gift card, prepayment card, subscription card, vending machine, ticketing, logistic hub (collection and pick up point), online games and publications ("Marketing Materials"). B.5 We may share aggregate data that does not allow you to be identified with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt to our products and services. B.6 Any Personal Data supplied by you will be retained by us and will be accessible by our employees, the Third Party Service Providers and third parties referred to in B.3 above, for or in relation to any of the purposes stated in B.1 herein. B.7 We may permit individuals who are staff members of 7-Eleven or other business units owned and operated by The Dairy Farm Company, Limited 牛奶有限公司 (including those stated above) ("Staff Members") to use 7-Fans (including but not limited to registering as a 7-Fans member and using the various functions provided by 7-Fans) but such Staff Members must at all times comply with all applicable codes of conduct and/or other relevant company policies of us and/or their relevant employer(s) when using 7-Fans. Notwithstanding anything stated herein, in the event it is found that a Staff Member misuses 7-Fans in his/her capacity as a Staff Member (including but not limited to using any confidential or other similar insider information to obtain an unfair advantage from any promotions or offers offered by 7-Fans), we may disclose or transfer the Personal Data provided by such Staff Member to his/her employer(s) for investigation and/or disciplinary purposes.
C. CONFIDENTIALITY
C.1 Personal Data held by us relating to the members or to visitors to 7-Fans will be kept confidential in accordance with this Privacy Policy. C.2 Any questions, comments, suggestions or information other than Personal Data sent or posted via 7-Fans by visitors will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development, manufacture and marketing of products and services and to meet customer needs.
D. SAFETY OF PERSONAL DATA
D.1 All reasonable efforts are made to ensure that any Personal Data held by us is stored in a secure and safe place, and accessed only by our authorised employees or authorised Third Party Service Providers. D.2 You should be aware that no system is impenetrable and no information provided over apps or the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over 7-Fans or the internet.
E. LINKS
7-Fans may contain links to other apps, websites and/or webpages which are operated by third parties. We have no control over the content of the linked apps, websites and/or webpages or the way in which the operators of those apps, websites and/or webpages deal with your Personal Data. You should review the privacy policy for those third party apps, website and/or webpages to understand the ways in which your Personal Data may be used by those third parties.
F. RIGHT TO ACCESS/CORRECT PERSONAL DATA
F.1 Under the Ordinance, you have the right of access to Personal Data held by us about you and to request correction of your Personal Data. F.2 If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data, you may send your request in writing to the following address:

Personal Data Officer
7-Eleven
3/F Devon House,
Taikoo Place,
979 King's Road, Quarry Bay
Hong Kong

Email: uhavesay@7-eleven.com.hk
F.3 In accordance with the Ordinance, we reserve the right to charge you a reasonable fee for the processing of any data access request.
G. AMENDMENTS
We may amend or update this Privacy Policy from time to time without prior notice and your Personal Data collected shall be governed by our latest Privacy Policy, which shall be available in 7-Fans.
H. THIRD PARTIES RIGHTS
Notwithstanding the Contracts (Rights of Third Parties) Ordinance and/or any comparable law in any jurisdiction, this Privacy Policy is personal to and is made solely for the benefit of the parties to it and shall not create or give any rights to or purport to confer any benefits on any third parties whatsoever. The application of the Contracts (Rights of Third Parties) Ordinance and/or any comparable law in any jurisdiction giving to or conferring on third parties the right to enforce any term of this Privacy Policy is expressly excluded and no terms of this Privacy Policy are, or are intended to be, enforceable by any person not being a party to it. Notwithstanding the foregoing in this paragraph, third party rights under this Privacy Policy shall be enforceable by Dairy Farm International Holdings Limited (“DFIHL”) and/or an entity which, as at the time of enforcement, is a direct or indirect wholly-owned subsidiary of DFIHL in accordance with the Contracts (Rights of Third Parties) Ordinance and/or any comparable law in any jurisdiction. The rights of the parties to terminate, rescind, or agree any amendment, waiver, variation or settlement under or relating to this Privacy Policy, or any term of this Privacy Policy, are not subject to the consent of any third party (including DFIHL and/or any of the wholly-owned subsidiaries at all times). The term “subsidiary” shall have the same meanings as in section 15 of the Companies Ordinance (Chapter 622) as amended from time to time.
©2017 The Dairy Farm Company, Limited 牛奶有限公司 trading as 7-Eleven. All rights reserved.