Privacy Policy

Last updated: August 6, 2024

Date of effective: August 6, 2024

About Delvaux Design Coordination & Finance S.A. and this Privacy Policy

Delvaux Design Coordination & Finance S.A., an affiliate of Richemont Group, has its registered offices at Boulevard Louis Schmidt 7, 1040 Brussels, Belgium. Its affiliate in China, Richemont Commercial Company Limited (with registered office in 701-708 Tower 3 Kerry Center, Jing’an, No. 1228 Yan’an Zhong Lu, Shanghai, China, postcode 200041) (hereinafter “we”, “us” and “our”) is responsible for personal information protection and other relevant matters in the Mainland China. In this Privacy Policy, we use the term Delvaux to refer to the head office of Delvaux Design Coordination & Finance S.A. at the registered address above, Delvaux affiliates and our boutiques.

Please take a moment to read the following policy that explains how we collect, store, use, transfer, provide, disclose and delete (collectively “processing”) the personal information that you provide to Delvaux through Delvaux’s websites, mobile applications and Delvaux stores in other digital platforms, including Tmall PFS and WeChat Official Accounts and mini-programs (together referred to as the “Platforms”), when you visit a Delvaux boutique, contact the Delvaux concierge by telephone or email, or when you interact with Delvaux over social media platforms (including WeChat and Tmall), you may be required to provide us with this information. This Privacy Policy also explains how Delvaux collects information through the use of Cookies and related technologies when you use our Platforms.

Before using Delvaux services, please read and fully understand the following policy. We process your personal information in accordance with this Privacy Policy in order to provide services to you. If you do not agree with the content of this Privacy Policy, Delvaux services may not be used or the full range of our services may be affected as a result.

Where Delvaux offers our products for sale online or by phone through the Delvaux Client Relations Center, you must read the applicable Conditions of Sale, which will govern the terms and conditions of any such purchases made in these ways.

From time to time we may update this Privacy Policy. When we do, we will notify you by publishing the changes on this Platform. We will also inform you by other means such as sending you notification e-mails and/or push notifications and/or pop-up windows prior to making any material changes, which may affect your rights and interests in this Privacy Policy, data security, or may involve with changes in the category of information we process, the purpose or methods of our processing, the parties to whom we share, transfer or disclose the information, our contact information, and how you exercise your rights.

Personal information means information that is recorded electronically or otherwise and relates to identified or identifiable natural person, not including anonymized information. Sensitive personal information means information that, if leaked, illegally disclosed or abused, may lead to causing harm to dignity of a natural person, bodily harm or property damage to a natural person. Sensitive personal information may include but not limited to biometric characteristics, religious belief, special identity, medical and health information, financial and account information and tracking information as well as personal information of minor under 14 years old.

We may collect your personal information in the following scenarios when providing Delvaux’s products and/or services, including sensitive personal information, as detailed below. For sensitive personal information we may collect from you, we will draw your attention by way of underline and bold. If the personal information provided by you is not yours but another individual’s, you should ensure that you have obtained that other individual’s authorisation. If there is any scenario not listed in this Privacy Policy, but your personal information will be collected, we will separately provide explanation on the applicable data collection and use rules. Any matters not provided in such rules will be governed by this Privacy Policy

• To access certain areas of Delvaux’s Platforms, you will need to register with us on Delvaux’s Platforms. During the registration process you will be asked to submit basic personal information about yourself (including information such as your name, date of birth and mobile number and other information that you may voluntarily provide to us, such as gender, age and nationality ). We may also collect the digital identification information (including system account number and IP address, account nickname, email address, relevant password and password protection questions). By entering your details in the fields requested and registering with us, you authorise Delvaux to provide you with the services you select. When you use the "Forgot Password" function of the Delvaux platform, you may need to submit your personal information again, including mobile phone number, verification code and new password;

• In order to have a full understanding of our clients, we may also collect and store data about your behaviour, interests, preferences (such as products, topics, and channel and frequency of communication), wish lists, hobbies, client interactions and marketing campaign activities, opinions, customer reviews, demographic data, habits, wedding anniversary, celebration events, purchasing reviews and feedback as well as your general purchasing tendencies.

• When you purchase products online, through boutiques or by phone, Delvaux collects information such as your purchase details (including the merchandise and price, the time when the order is placed, the order code and status), relevant payment information (including time, amount and method of payment, payment account number, ID information and other payment information) and delivery information (including recipient’s name, address and telephone number), to process your order, deliver products and services, process payments and issue invoices, and update your purchase status and records;

• When you contact us by telephone or emails (for example, if you contact Delvaux to enquire about one of our products or services, including product maintenance services), or when you visit a Delvaux boutique to enquire about one of Delvaux’s products or services or to request other information, in order to match out existing records and provide personalised services for you, we will collect your personal information (including your name and your telephone number). When you contact Delvaux by telephone, your phone calls with us may be recorded for the purposes of security, evidence, training, quality control, analysis and development;

• If you follow us or choose to interact with Delvaux on or via a social media platform or other third-party service providers (including Tmall and WeChat), we will collect the information you have provided to us through that platform or third-party service providers (including your profile photo, nick name, area and other information authorised on the prompt page, and the information obtained by that platform or third-party service providers after processing your behavioral data including your browsing records and purchase history on that platform);

• When you use live chat function on Delvaux’s Platforms to contact us, we will collect the chat history with us (including your preferences) to facilitate our response to your enquiries and to improve Delvaux’s customer services;

• When you use Delvaux’s visual chat function on our Platforms to contact us, the chat history with us (including your preference) maybe recorded for training, quality monitoring, analytical and development purposes. We will also collect the chat content to you with customised services and to improve our customer services;

• In our retail boutiques, corporate premises or other areas, we collect data using CCTV or other video surveillance technology;

• Some of our technology products, including connected mirrors, augmented reality technologies or photo booths, collect photographs or video recordings from you. This data may also allow us to take measurements from you required for our products and/or services. We may also take photographs or make video or voice recordings of you at one of our events;

• When we carry out surveys and market research, we will collect your response data;

• Except for third party platforms (including Tmall and WeChat, described in the section headed “Information Collection by Third Parties”), we collect certain information automatically about visitors to Delvaux’s Platforms (including browsing records) via Cookies and other relevant technology (e.g. SDK and Pixels), described in the section headed "Cookies and other information that we automatically collect", below; and

We will collect information about your location (including your precise location) to the extent that Delvaux provides any location services, described in the section headed “Location information” below. Furthermore, in order to implement relevant business function or provide you with more convenient products and/or services, we will request relevant permission depending on specific use case scenarios (including Camera, save, microphone, Bluetooth, contact list). The permission is not granted by default setting. Only when you trigger relevant business function we will request your permission by a pop-up box. You can choose to close part or all of relevant permissions in the setting on the Platform. This may result in non-implementation of relevant business function or inability to reach the expected effect. However, it does not affect your normal use of other products and/or service functions Providing us with personal information laid out above is voluntary, but Delvaux may not be able to provide the products and/or services you requested (including processing your order and sending you the required order acknowledgement and shipping confirmation notice or repair progress notice) if you do not provide us with certain information necessary for basic functions relating to products and/or services. For personal information that you have chosen to fill or provide, not providing such information will not affect your use of the basic business function for our products and/ or services, however, Delvaux may not be able to provide specific function or any benefits that can only be provided with such information.

We may also collect your sensitive personal information with your consent where there is specific purpose: such as your financial information (including transaction and consumption records and bank account), individual identification information and other information (including communication records, tracking, browsing history and precise geographical location.

We will use the information we collect from you for the following purposes:

• Manage and fulfil purchase and repair orders, facilitate delivery, refund, provide after-sales services, online appointment, online queue up, extended product warranty, product exchange, sales note, and service satisfaction survey;

• Manage your accounts, and Delvaux’s accounts and records;

• Verify you are 14 years old or above;

• Deal with your enquiries and requests;

• Send service-related communications, including announcements and administrative messages such as order confirmation;

• Organise and run events, boutique appointments and membership communities, including registering you as a member, attendee or speaker, or reporting or logging a health and safety incident that you may have suffered or assisted with. We may also take photographs or make video or voice recordings of you at one of our events for promotional purposes.

• Run competitions, prize draws, and other promotions, and we need to collect information from you to administer such promotions.

• Identify and predict through algorithm models the products, services or other information that may be interest to you based on your information (such as your purchase history, favourite products records, browsing records, search records, interaction records (including comments/sharing/likes), device information, gender, age and residing cities and areas) and push notice via automated decision making about the products, services, event invitation, personal benefits and other information, or present you with tailored product recommendations on Delvaux’s Platforms (if such function is available in such Platforms). When we use your personal information for automated decision making, we will ensure transparency in decision making, fair and unbiased results, and ensure that your transaction terms (including price) are not subject to unreasonably differential treatment;

• Where we have your authorisation, use the contact details you provided to us and send you marketing communications (including e-mails, SMS, MMS, instant messaging and social media audience matching) relating to Delvaux and other third party partners and that Delvaux think may be of interest to you (please see the “Your choices” section below for further information about how you can control these updates);

• Conduct market research, analysis and demographic studies (including customer survey), together with anonymized personal information, to analyse, profile and monitor purchase preference so that we can continuously improve our offerings and the products and/or services Delvaux provides to its customers;

• Undertake anti-money laundering or international sanctions compliance, credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platform and services secure or as otherwise required to respond to a legitimate request from a third party (for example, a regulatory or police authority or financial institution);

• Understand how Delvaux’s Platforms are used so that we can continuously improve Delvaux’s Platforms and services and other offerings;

• Conduct indirect and/or direct user profiling for the purposes of improving the services Delvaux provides to our customers and, where we are permitted to do so in accordance with applicable laws or we have obtained your consent to do so, send you marketing information on Delvaux’s products and services which may be of interest to you (please see the “Your choices” section below for further information about how you can control these updates);

• Unless you explicitly refuse, we may reasonably collect and process the personal information publicly disclosed by you or otherwise in accordance with laws, in order for us to better understand Delvaux’s clients and increase our service quality;

• Prevent and detect crime, assist law enforcement agencies in the apprehension, investigation and prosecution of offenders, ensuring the safety of our staff, visitors and property and, occasionally, to monitor in-store activity or WiFi browsing;

• Use new retail technologies to provide you with enhanced in-store and online experiences, including virtual try-ons, augmented reality and product configurators. For example, we may use images or videos of your hand to generate and send you a photograph or a video clip showing product(s) on your hand;

• We will share or transfer your personal information in the occasions and by means as described in the section headed “Entrustment, sharing and transferring your information” below; and

• We will seek your approval in advance when we collect or use your personal information for other purposes not specified in this Privacy Policy.

Exception to the consent requirement: under the Personal Information Protection Law, we do not need to obtain your prior consent before processing your information under any of the following circumstances:

• the processing is necessary for the conclusion or performance of a contract to which you are a contracting party;
• the processing is necessary to fulfil statutory functions or statutory obligations;
• the processing is necessary to respond to public health emergencies or protect the life, health or property safety of natural persons under emergency circumstances;
• personal information is processed within a reasonable scope to conduct news reporting, public opinion-based supervision, or other activities in the public interest;
• the personal information that has been disclosed by you yourself
• or other personal information that has been legally disclosed is processed within a reasonable scope in accordance with the Personal Information Protection Law; or
• under any other circumstance as provided by any law or administrative regulation.

Like most platforms, we log IP addresses and uses Cookies and similar technologies that allow us to recognise you, to achieve better security and fraud prevention purposes, and to customise your experience, and provide us with information about the way our visitors access our Platforms.

Please note that, like most mini-programs, Delvaux’s stores in certain third party platforms, public accounts and mini-program (such as WeChat) may use Cookies or other similar technology to automatically collect your IP address and other relevant information and the information provided by such third party platforms (including OpenID and UnionID). We will also collect the information from you with your prior authorisation (including your profile photo, nickname). This information may be used to identify you when you visit our mini-program again and combine with other information about you. Furthermore, we will collect the information when you visit our mini-program, including browsing records, preferences, search records and interaction records (such as which pages you have visited and dwell time), in order for you to use Delvaux’s mini-program and relevant functions more smoothly and for us to analyse, profile and monitor purchase preference so that we can continuously improve our offerings and the products and/or services Delvaux provides to its customers.

You can find out more about how we use cookies and related technologies below.

What are Cookies?

Cookies are text files, containing small amounts of information, which are downloaded to your computer or mobile device when you visit a website or mobile application. They are used to recognise your computer as you move between pages on a website, or when you return to a website or mobile application you have visited previously. Cookies are widely used in order to make platforms work, or to work more efficiently, as well as to provide information to the owners of the platform.

We use Cookies to enhance the online experience of our visitors (for example, by remembering your language and/or product preferences) and to better understand how Delvaux’s Platform is used. Cookies will tell us, for example, whether you have visited Delvaux’s Platform before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests.

There are two broad categories of Cookies:

• First party Cookies, served directly by Delvaux to your computer or mobile device. They are used only by Delvax to recognise your computer or mobile device when it revisits Delvaux’s Platform.

• Third party Cookies, which are served by a third party service provider on Delvaux’s Platform, and can be used by the service provider to recognise your computer or mobile device when it visits other platforms. Third party Cookies are most commonly used for platform analytics or advertising purposes.

Cookies can remain on your computer or mobile device for different periods of time. we use both 'session Cookies' and ‘permanent Cookies’. Session Cookies exist only while your browser is open and are deleted automatically once you close your browser. Permanent Cookies survive after your browser is closed, and can be used to recognise your computer or mobile device when you open your browser and browse the internet again.

What Cookies do we use?

The Platform serves only the following types of Cookies to your computer or mobile device:

How to control or delete Cookies

We use non-essential Cookies on the basis of your consent. You have the right to withdraw that consent and refuse the use of Cookies at any time and we have explained how you can exercise this right below. However, please note that if you choose to refuse Cookies you may not be able to use the full functionality of Delvaux’s Platform.

You can set your Cookies preferences by changing your browser settings so that Cookies from this Platform cannot be placed on your computer or mobile device. In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility).

IP addresses

Our Platforms will collect information about your computer or mobile device, including where available your IP address, operating system, log-in times and browser type. We will also automatically collect the information about how you use our Platforms, including your searches and pages you have visited. We use this information to better understand how visitors use our Platform and for internal reporting purposes. We will anonymize and share this information, which cannot identify you, with advertisers, sponsors or other businesses.

Wi-Fi usage

Where Wi-Fi is available at Delvaux’s stores or events, if you register for our free Wi-Fi service at the stores or events, we will collect certain information about your device, including MAC or IP address, connection date and time and the location(s) at which you connected to our Wi-Fi service, for the purpose of providing the Wi-Fi service to you. When you connect to our Wi-Fi service you may be directed to Delvaux’s Platforms and we may collect and process information using “Cookies”. You may refuse to such collection by not connecting to our Wi-Fi routers in Delvaux’s stores or events.

We collect and use information about the device you are using to connect to Delvaux’s online services, including services on Delvaux’s site, application or any interactive content. This information typically includes the type of device you are using, your internet browser, your location or the application running on your device. When you enter into a boutique or attend an event, we may also use technologies that connect to the functionality on your device (typically your mobile phone) such as Bluetooth and GPS and collect information based on Wi-Fi and other in-store technologies. You can view the status of the above permission item by item in the device system, and you can decide whether to turn on or off at any time. Please note that by granting a permission means that you authorise us to collect and use relevant personal information to provide you relevant services. If you cancel the permission by turning off the function, it means that you withdraw the authorisation, we would not be able to continue to collect and use the relevant personal information, nor would we be able to provide you with the corresponding services. However, your decision to turn off permissions does not affect the effectiveness of previous personal information processing activities based on your authorisation. Please note that information you voluntarily share or even publicly share while using Delvaux’s services may involve personal information or even sensitive personal information about yourself or others. Please be careful about any such sharing of information when using Delvaux’s services.

In order to facilitate the account verification, the online payment and booking delivery service, or to withdraw map data, we may incorporate third party’s services within this Platform, and such third party may directly collect from you some data out of our control. We will mark such services/functions as “provided by third party”, and also require such a third party to obtain your consent and to respond to your requests in accordance with applicable laws.

The Platforms use third parties such as network advertisers and ad exchanges to serve you ads on third party platforms after you leave Delvaux’s Platforms, and we use third party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Platforms and viewing of ads and of the content. Network advertisers are third parties that display advertisements, which are based on your visits to the Platforms and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services that you might be interested in.

Third party tracking technologies are not controlled by us, even if they are associated with Delvaux’s Platforms or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

You have choices in respect of the delivery of ads. You can opt-out of receiving certain types of behavioural ads by visiting the third party websites described in the section headed “How to control or delete cookies” above. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.

• Entrustment: we will disclose your personal information to our third party service providers entrusted by us to process personal information necessary for the purposes of providing online, offline and other payment services, handling credit checks and fraud prevention, and any other services required in order for us to use your information for the purposes specified in the section entitled “Information you provide us and how we use it” (including delivery companies, logistics companies and trading partners, marketing service providers, advertising providers, communication service providers (such as emails, SMS, multi-media communication and social media) and technology service providers. We will use reasonable efforts (e.g., through contractual arrangements and regular reviews of security impact assessments) to ensure that our entrusted third parties have adequate data security measures in place to protect your personal information and only process the information for the entrustment purposes and processing methods.
• Asset/ business merger or acquisition: in a merger or acquisition, purchase or transfer or similar transaction of all or substantially all of our assets and business, if your personal information is to be transferred, we will require the new company or organisation that is to hold your personal information to continue to be subject to the terms of this Privacy Policy, or obtain your new consent.
• Public disclosure: We will not publicly disclose your personal information. If we need to publicly disclose your personal information, we will notify you the purpose, types of personal information to be disclosed and possibly sensitive personal information involved and obtain your separate consent;
• Legal requirements, obligations or requested by government or enforcement authorities: To fulfil our statutory duties and obligations, we will disclose your personal information in accordance with applicable regulation and requirement. We may also disclose your personal information to enforcement agency, court, regulator, government authority or other third parties if we believe it is necessary to comply with the legal requirements or to protect our legal rights or those of third parties. In which case, we are not obliged to seek your prior consent;
• Sharing with authorised dealers: Where you interact with our authorised dealer network, we may ask for your consent to share your information with an authorised dealer from time to time for the purposes of:
• providing you with services you have requested;
• improving your customer journey and experience within boutiques when interacting with our products and services and/or our authorised dealers;
• ensuring that the information we hold about you is accurate and up to date, including registering purchases, warranty extensions and other transactions as well as recording your marketing preferences; and
• management of client and vendor relationships to improve co-operation with our authorised dealers and provide you with bespoke client experiences with us.

In circumstances where an authorised dealer may require access to the information we hold about you, we will seek your permission to share your information with an authorised dealer prior to granting such access. Where you grant permission to share your information with an authorised dealer, we will maintain industry leading measures to ensure the continued security of your information. Where your information is shared with an authorised dealer, both Delvaux and the relevant authorised dealer may simultaneously be acting as an independent data controller and/or data processor in respect of your information, depending upon how we or our authorised dealer are interacting with you; and

• Exception to the consent requirement: under the Personal Information Protection Law, we do not need to obtain your prior consent before sharing, transferring and publicly disclosing your information under any of the following circumstances:
  • the processing is necessary for the conclusion or performance of a contract to which you are a contracting party;
  • the processing is necessary to fulfil statutory functions or statutory obligations;
  • the processing is necessary to respond to public health emergencies or protect the life, health or property safety of natural persons under emergency circumstances;
  • personal information is processed within a reasonable scope to conduct news reporting, public opinion-based supervision, or other activities in the public interest;
  • the personal information that has been disclosed by you yourself or other personal information that has been legally disclosed is processed within a reasonable scope in accordance with the Personal Information Protection Law; or
  • under any other circumstance as provided by any law or administrative regulation.

We may share with third parties the aggregated or anonymized information or data that cannot directly identify your identity.

All of your personal information specified in the section headed “Information you provide to us and how we use it” above, including the sensitive personal information, we collect and generate in Mainland China, shall be stored in Mainland China. If, in exceptional circumstances and based on our business needs, we need to transfer certain data to our overseas data receiver located in Switzerland, Richemont International SA (please see below the address and contact number) and Richemont Group’s affiliates, for processing, we will only make such transfer after we obtain your separate consent and meet all the applicable requirements on cross border data transfer under the laws and regulations (such as, if required, passing the security assessment by the Cyberspace Administration of China, filing successfully with the cyberspace administration at the provincial level, or obtaining corresponding certification). For our Group affiliates, please visit https://www.richemont.com/en/h.... The transferred information will be retained at the overseas data receiver until the earlier of the achievement of such purpose for such transfer, and the cancelation of your account. We will supervise the overseas data receiver’s processing of personal information to ensure that the processing meets the standards for protection of personal information under the Personal Information Protection Law and is only carried out within the authorised scope.

Overseas Data Receiver:

Richemont International SA
50 chemin de la Chênaie
CP 30, 1293 Bellevue
Geneva
Switzerland
Tel: +41 (0) 22 721 3500

We want you to feel confident about using Delvaux’s Platform, and we are committed to protecting the personal information we collect. We have passed the multiple level security certification of the Public Security Ministry, obtained ISO27001 information security relevant system certification and established a good coordination and communication channel with the third party assessment institute so that any type of security threat can be defended and managed in time to provide all protection to your personal information. We take all reasonable measures so as to ensure that only the information necessary, appropriate and relevant to the purposes laid out in this Privacy Policy is collected, used and shared. We limit access to personal information about you to employees who reasonably need access to it, to provide products or services to you or in order to do their jobs. We will stop using or delete your personal information upon your request, or anonymize your personal information. We have appropriate technical, encrypted, anonymous and organisational physical, electronic, and procedural safeguards (e.g., TLS, SSL) to protect the personal information that you provide to us against unauthorised or unlawful processing, damage to the data integrity, and against accidental loss, damage or destruction. We have established a designated management system, process and organization to ensure information security. However, where we ask you to choose a password in order to access certain parts of Delvaux’s Platform, you are responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else. Please be aware and understand that the Internet environment is not 100% safe. We strongly suggest you help us to protect your account by using safe methods and complicated password. We may convert your personal information into statistical, aggregate or other de-identified information so that you cannot be identified and such personal information will be used for research and analysis. We ensure data security during the transfer, storage and backup process of personal information, and regularly conduct security audit.

If unfortunately, any data leakage or distortion happens, we will stick to the applicable laws and take all reasonable countermeasures and remedial measures in our emergency plan to minimize the effect on your lawful interests, including informing you of such accident and the corresponding advices to you.

Access and correction: Unless applicable law prohibits or limits you to do so, you have the right to ask for access to any personal information that we hold about you in our records, or to correct or help you correct any inaccuracies and to update any out-of-date information. You can use the user interaction function in our Platforms (if applicable), or the method described in the section headed “Contact Us” in this Privacy Policy to contact us for requesting access or correct your personal information.

Copy: You have the right to request a copy of your personal information. If you would like to obtain a copy of your information we collected, you can use the user interaction function in our Platforms (if applicable) or the method described in the section headed “Contact Us” in this Privacy Policy to contact us for requesting a copy of your personal information

Deletion and account cancellation: You have the right to request the erasure of your personal information we collected, if our processing violates any applicable law or against your consent, or if you wish to cancel the registration or no longer use Delvaux’s Platform, or Delvaux’s Platform no longer serves you. you can use the user interaction function in Delvaux’s Platforms (if any), or the methods described in the section headed “Contact Us” in this Privacy Policy to contact us for requesting deletion of your personal information. We would like to note some information is indispensable to some functions on this Platform, if such information is deleted, the corresponding functions will turn inactive. You can also request cancelation of your account by the same channel. After you cancel your registration with us on the Platform, we will delete your personal information or anonymize it as required by the applicable laws. However, we may retain other information collected through this Platform, including transactions information such as payment records, logistics and express delivery, return, replacement and after-sales services, risk assessment reports and handling records, which may contain your personal information, within certain period of time after you cancel your registration, in order to comply with our obligations as prescribed under the applicable laws and regulations. Please note that your request to cancel your registration with us in one of our Platforms does not affect your registration with us in other Platforms, unless you request to cancel all your registration with us in all our Platforms.

Withdraw consent and refuse personalised recommendation: You have the right to object to or withdraw your authorisation to us processing your personal information. However, the corresponding functions at Delvaux’s Platforms may accordingly turn inactive for you, and our processing prior to your revocation will remain unaffected. In certain situations, you may withdraw your consent to processing of your personal information by us via requesting data deletion or shutting down permission or authorisation. In particular, you can ask us to stop sending you direct marketing communications at any time (however please note that we may continue to send you service-related (i.e. non-marketing) communications, such as e-mail updates on your order status), or to shut down some customized promotion information and product/service display. If you wish to exercise any of these rights, please write to us at the email address listed below in the section headed “Contact Us” or via the user interaction function in our Platforms (if any). You may unsubscribe from e-mail marketing communications at any time by e-mailing the address below in the section headed “Contact Us” or clicking on the ‘unsubscribe’ link in any Delvaux marketing e-mails. We will respond to your requests within a reasonable time period, no later than 15 days thereafter. Once you withdraw your authorisation, we will no longer process your personal information. Your decision to withdraw your authorisation will not affect any of our previous processing of personal information based on your authorisation.

Retention: We retain your personal information in accordance with the applicable legal data retention requirements and our internal policies. The retention of your information will vary according to the type of data and the purposes for processing them. Generally, we will only keep your information as long as necessary to serve the purposes laid out above, unless otherwise stipulated by applicable laws and administrative regulations. We will delete or anonymize your personal information upon expiry of the applicable retention period. Should you wish to cancel your account or otherwise unsubscribe from one of Delvaux’s Platforms, unless applicable legislation requires a different retention period, we will delete or anonymize your information and have the overseas transferees delete or anonymize the same within a reasonable period (subject to applicable law requirements) upon receipt of your request. We may need to retain certain personal information even once a customer account has been closed or deleted to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you to receiving Delvaux updates for the purpose of ensuring we do not continue to contact you further.

In commercial activities, we assume that you have the appropriate capacity for civil conduct. We understand the importance of safeguarding the personal information of minors. The Platforms are not directed at any minor who we know to be under the age of 14, nor do we collect any personal information from any minor who we know to be under the age of 14. We may collect your birthday information to verify your age. If you are under the age of 14, you should not use the Platform and should not submit any personal information to us. In case we find that you are under the age of 14 but you submit your personal information to us, we will terminate services to you (including account cancelation) and delete such personal information as soon as possible. If you are above the age of 14 but under the age of 18, we may request that your parents or other guardians read this Privacy Policy carefully and you may only use Delvaux’s services or provide information to us with the consent of your parents or other guardians.

If you have any questions or comments about this Privacy Policy, or privacy matters generally, please contact us at the address provided below. You can also use this address if you wish to request access to your personal information, or to unsubscribe from any further e-mail marketing communications. We may first ask you to prove your identity and then handle your request within reasonable period of no longer than 15 days.

Unless you make unreasonably repetitive or unreasonably burdensome requests, our responses to your requests will not charge you in any way, and, we may reject your request if it violates confidentiality of business secrets, abuses your rights, involves malice, or conflicts with social welfare, public security, other persons’ legitimate interests, or our obligations under applicable law.

If you have any questions about this Privacy Policy or the manner in which your information may be processed, please contact us at:

Richemont Commercial Company Limited

Delvaux

Tel: +86 21 3106 3421

Email address: clientservicecn@delvaux.com