Privacy Policy Statement

1. Pledge
Sky Connection Limited and Anway Limited which manages and operates Free Duty (“Sky Connection”, “Anway”, “Free Duty” ,“we”, “us”, or “our”) recognizes and understands that customers, website visitors, and mobile application users are concerned about the privacy of personal data. Free Duty pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).

This Privacy Policy Statement outlines Free Duty’s practices and the choices you have concerning the collection and use of your personal data. This Privacy Policy Statement should be read together with the applicable Terms and Conditions of the relevant service, website, and/or mobile application provided by Free Duty (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Privacy Policy Statement and the Terms and Conditions concerning matters relating to personal data, this Privacy Policy Statement shall prevail. This Privacy Policy Statement should be also read together with the applicable personal information collection statement of the relevant service, website, and/or mobile application provided by Free Duty (the “PICS”), provided that, in the event of any inconsistency between this Privacy Policy Statement and the PICS concerning matters relating to personal data, the PICS shall prevail.

2. Collection of Information
You may be invited to provide to Free Duty your personal data on Free Duty’s relevant website(s) or mobile application(s), or through other media on a voluntary basis for different purposes at different times. If you are under the age of eighteen (18), you should obtain consent from your parent or guardian before you provide Free Duty with your personal data.

3. Log Files
When you visit Free Duty’s website(s) and/or use Free Duty’s mobile application(s), the servers of Free Duty will collect only data relating to your visits to/use of such website(s) and/or use such mobile application(s), including but not limited to your IP address, domain name, browser type and access time (“Log Files”) but will not collect your personal data. However, if you register on our website and log in to your account, we may combine your Log Files with other personal data we collect from you, in which case such Log Files shall be considered your personal data for the purposes of, and will be used in accordance with, this Privacy Policy Statement and the PICS.

4. Use of Cookies and Other Tracking Mechanisms
When you browse the website(s) of Free Duty and/or use the mobile application(s) of Free Duty, cookies will be stored in your computers, mobile phones or other devices for internal navigation and programming only. We may use cookies and other tracking mechanisms described below to track information about your use of Free Duty’s website(s) and/or mobile application(s) (“Tracking Data”). We may combine this Tracking Data with other personal data we collect from you, in which case such Tracking Data shall be considered your personal data for the purpose of, and will be used in accordance with, this Privacy Policy Statement and the PICS.

Cookies are alphanumeric identifiers that we transfer to your computers, mobile phones or other devices through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate Free Duty’s website(s) and/or mobile application(s), while others are used to enable a faster log-in process, or to allow us to store and track information about your interests and preferences at Free Duty’s website(s) and/or Free Duty’s mobile application(s).

We may also engage third parties to track and analyse non-personally identifiable data from the website(s) or mobile application(s). We use the data collected by such third parties to help us administer and improve the quality of Free Duty’s website(s) or mobile application(s) and to analyse usage of the same. This is unrelated to and separate from your personal data. Such third parties may combine the non-personally identifiable data that we provide about you with other information that they have collected. You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functionality of the website(s) and/or mobile application(s) (where applicable) of Free Duty.

If you interact with Free Duty on social media platforms (for example if you “Like” Free Duty’s Facebook page), Free Duty can interact with you and send you messages via these platforms. Free Duty will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your personal data. We are not responsible for what third parties post on our social media accounts.

5. Kinds of Information Collected
For the different purposes in the course of conducting Free Duty’s business, you may be required to provide to Free Duty your personal data, which may include your name, gender, age (or age range), month of birth, contact details, e-mail address, mailing/residential/correspondence address, contact number, membership number, marital status, family status, educational level, occupation, username and password, Log Files, Tracking Data, interests and favourite activities, transaction information (including your characteristics and transaction behavior), social media account information, etc. Details of personal data to be collected will also be set out in the relevant PICS provided to you on or before collection of such personal data.

6. Purposes and Uses of Personal Data Collected
Free Duty will use your personal data for specific purposes identified in the PICS provided to you on or before your personal data is collected. This includes sharing your personal data with, and your personal data being used by, third parties as set out in the PICS for those purposes.

7. Accuracy of Information
You may be requested to provide to Free Duty certain personal data for specific services. If you fail to provide accurate or update information as requested for each specific service, the provision of such services by Free Duty may be affected.

8. Retention of Information
Free Duty will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are to be used. If you are a subscriber of Free Duty services, your personal data will be retained for a reasonable period after termination of your subscription for verification and audit purposes. The above is subject to any legal, statutory, regulatory or accounting requirements.

9. Third Party Merchants
Free Duty may have on-line stores or some services and/or products which are hosted in the website(s) and/or mobile application(s) of Free Duty but are operated by third party merchants. If you provide your personal data to the third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that your personal data is beyond the control of Free Duty and thus is outside the scope of protection afforded by Free Duty.

10. Third Party Websites and/or Mobile Applications
The website(s) and/or mobile application(s) of Free Duty may from time to time contain linkages to other third party websites and/or mobile applications. These other third party websites and/or mobile applications are independent from the website(s) or mobile application(s) of Free Duty. Free Duty has no control or management over the contents of such other websites, mobile applications or their privacy policies or compliance with law. You should be fully aware that the provisions of such links do not constitute an endorsement, approval, or any form of association by or with Free Duty. Free Duty has no control over your personal data submitted by you, if any, to other websites and/or mobile applications. This Privacy Policy Statement only applies to the website(s) and/or mobile application(s) of Free Duty. You should read the respective privacy policies of other websites or mobile applications.

11. Service Providers
Free Duty may provide your personal data to the people and/or companies providing services (whether within or outside Hong Kong) to Free Duty in connection with the specific purposes set out in the PICS and paragraph 6 above (the " Free Duty Service Providers"). In these cases, the Free Duty Service Providers are required to use your personal data consistent with the agreements Free Duty enters into with them as well as this Privacy Policy Statement and the PICS.

12. Security of Information
The physical records of your personal data will be stored in secured places (whether within or outside Hong Kong) with restricted access by us or those who we share your personal data with in accordance with this Privacy Policy Statement and the PICS. The electronic records of your personal data will be stored in the servers of Free Duty and/or relevant Free Duty Service Providers as our data processors (whether within or outside Hong Kong) located in secured places and protected by adequate IT security measures (e.g. encryption for transmission of sensitive data through the internet in appropriate cases), or we will procure by contract or use our reasonable endeavours to ensure that those who we share your personal data with (whether within or outside Hong Kong) in accordance with this Privacy Policy Statement and the PICS do the same. Only authorized personnel of Free Duty (who have been trained to handle your personal data properly and bound by a duty of confidentiality) will have access to these records and servers on a "need-to-know" and "need-to-use" basis, or we will procure by contract or use our reasonable endeavours to ensure that those who we share your personal data with (whether within or outside Hong Kong) in accordance with this Privacy Policy Statement and the PICS do the same.

Your personal data may be stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with third parties with physical locations and/or servers located within or outside Hong Kong, in each case in accordance with the PICS. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the place or country in which it is stored, and we will procure by contract or use our reasonable endeavours to ensure that any third parties will do the same. Our cross-border transfer of your personal data will be conducted in accordance with the PICS and applicable laws for the protection of your personal data.

No data transmission over the internet or any other public network can be guaranteed to be completely secure, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorized access to your password. You are advised to sign out from your account when finished particularly when using a shared computer.

13. Exclusion
Free Duty may disclose your personal data as required by law, any government departments, regulatory authorities, enforcement agencies and courts of competent jurisdiction. Free Duty excludes all liability for disclosure of your personal data in this manner.

14. Use in Legal Proceedings etc.
If it becomes necessary for Free Duty to take action against you for recovering from you the debt you owe to Free Duty, you agree that your personal data can be used by Free Duty in identifying and taking legal action against you.

15. Access and Correction of Information and Withdrawal of Consent
You have the right to request in writing to the Personal Data Privacy Officer of Free Duty to:

a. check whether a/the relevant Free Duty company(ies) hold any of your personal data;
b. access your personal data held by the relevant Free Duty company(ies) (if any);
c. require the relevant Free Duty company(ies) to correct your personal data that is inaccurate (if any); and
d. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;
e. withdraw your consent to the use of your personal data for direct marketing purposes (see below).

All such requests will be handled promptly in accordance with the requirements of the PDPO. Free Duty may charge you a reasonable fee for processing your personal data access request.

16. Direct Marketing
We cannot use or provide to third parties (whether intra-group and/or external parties) your personal data for direct marketing purposes without your consent. Subject to your consent, we may use or provide to third parties (whether intra-group and/or external parties) your personal data for direct marketing purposes in accordance with the PICS provided to you on or before collection of your personal data. You may withdraw your consent any time by writing to the Personal Data Privacy Officer of Free Duty at Units 817-823, 8/F, Trade Square, 681 Cheung Sha Wan Road, Cheung Sha Wan, Kowloon, Hong Kong or by email at privacy@freeduty.com.

17. Change of Privacy Policy Statement
This Privacy Policy Statement may from time to time be updated, revised and amended. Any update, revision or amendment will be effective immediately upon being posted on website(s) and/or mobile application(s) of Free Duty. Where legally required, we shall notify you and/or obtain your consent for specific material updates, revision or amendment. If you do not accept the updates, revision or amendment, and/or provide your consent, then we may not be able to provide goods or services to you. You are advised to check the website(s) and/or mobile application(s) of Free Duty for updates to this Privacy Policy Statement on a regular basis.

18. Change of Control
In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our affiliates or our affiliates’ businesses, Free Duty may need to transfer your personal data to the new entity in accordance with the PICS. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.

19. Enquiries
If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by the relevant Free Duty company(ies) for direct marketing purposes, please contact the Personal Data Privacy Officer of Free Duty at:

Units 817-823, 8/F, Trade Square, 681 Cheung Sha Wan Road, Cheung Sha Wan, Kowloon, Hong Kong
Attention: Personal Data Privacy Officer
(Marked Confidential, and with the name of the relevant Free Duty company(ies))
or by email at privacy@freeduty.com.

20. Inconsistency or Conflict
If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.

21. PRC Addendum
If you are:

(i) an individual located in Mainland China who visits Free Duty’s relevant website(s) or uses relevant mobile application(s) of Free Duty, or otherwise uses Free Duty’s products and/or services by phone or any other means from Mainland China; and/or
(ii) an individual holding a Mainland China passport and/or resident identity card who visits the physical stores of Free Duty in Hong Kong or otherwise use Free Duty’s products and/or services by phone or any other means in Hong Kong,

your personal data will be processed by Free Duty in accordance with the “People’s Republic of China Addendum” in addition to this Privacy Policy Statement and the PICS, as well as the applicable data protection laws and regulations in Mainland China which, for the current purposes, excludes Hong Kong, the Macau Special Administrative Region of the People’s Republic of China and Taiwan.