Our Pledge

We pledge to meet fully, and where possible exceed, in complying with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong). In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.

The typesof personal data we collect may include but not limited to:

• your title, name, gender, telephone number, email address, home, mailing, billing, delivery address or other contact information, your day and month of birth, your payment or credit card information, username and password, and other personal data you voluntarily provide to us; and
• IP address, real-time geographic location data, browser settings, browsing records, referring websites, and other internet log on information of your computer, mobile, or other electronic/communication devices.

How We Collect Personal Data
We may obtain personal information about you in a number of ways, such as:

• when you shop at our online or physical stores;
• when you participate in our events or promotions;
• when you apply for or use our membership card or participate in any of our loyalty or promotion programs;
• when you register an account with us;
• when you participate in any surveys or marketing campaigns;
• when you login to visit our websites, use our mobile applications or view any of our social media pages;
• when you use the wifi service at our stores or events;
• when you contact us whether in person, by phone, by email or via any social media platforms, to make enquires or provide information;
• when verifying your identity; and
• when you subscribe to our marketing or promotional materials.

You are not required to provide the personal informationthat we request, but we may not be able to provide you with our products,services or benefits or you may not be able to login to our platforms or use certainfeatures without such information. You have the right to request access to thepersonal information we have about you, and to request us to make correctionof, update or delete the information. If you live in the EU, you have certainadditional rights to your personal information. Please refer to “Your Rights asa Data Subject” in paragraph 11 below.

Purposes of Collection
Your personal data may be used for one or more of the following purposes(“Purposes”):

• communicating with you;
• verifying your identity and any accounts you have with us;
• administering any loyalty or other marketing, promotional or corporate programs that we are involved in, including providing you with the benefits that you are entitled;
• processing your orders for products and services you place with us (such as maintaining your shopping cart, attending to billing, payments, refunds and delivery arrangements);
• handling and responding to your inquiries, suggestions or complaints;
• conducting customer surveys or organizing events for customers;
• providing you with customer service;
• conducting analysis to help us better understand our customers and to improve our services and products;
• customising the information displayed on our shopping websites/apps and social networking/media platforms to create better customers experience;
• designing targeted promotional offers;
• conducting advertising activities, including targeted advertising;
• conducting direct marketing activities;
• fulfilling our obligation to maintain records of processing activities;
• meeting legal, regulatory or compliance requirements, dealing with enquires from law enforcement or regulatory bodies or for the purpose of obtaining legal advice; and
• any other purposes directly related to any of the above purposes.

We only collect personal data we actually need for ordirectly related to our specific Purposes. If we intend to use the personalinformation for purposes other than the above, we will seek your consent priorto using your personal data.

Direct Marketing
We intend to use your personal information for direct marketing which willinclude the marketing and promotion of all products and services offered by theThe Hanli International Corporation Limited. We will not provide your personalinformation to third parties for use in their direct marketing activities. Youmay withdraw your consent for us to use your personal information in our directmarketing activities by indicating your preference where appropriate or requestus to change your preference (without any fees), at any time by contacting ourrepresentative listed in the “Contact Us” section below. For direct marketingsent by emails, you may also unsubscribe with the link provided at the bottomof our emails. For customers in Hong Kong and Singapore, we will not use yourpersonal information for the purpose of direct marketing without your consent.We will use your personal information such as name, mobile phone number, emailaddress and/or residential address to inform you of our new beauty productsand/or latest promotional and marketing events. For customers in Singapore andMalaysia, we are able to use your personal data to the extent it is requiredfor the provision of products or services to you. You consent to the processingof your personal data in accordance with this Privacy Policy. Should youprovide your consent for the use of your personal data for advertising or directmarketing purposes, we will continue to send you such advertising and directmarketing materials until you withdraw your consent. For customers in the EU,we rely on our legitimate interests as the legal basis to send you directmarketing materials unless you object to our use of your personal informationin directly marketing. You have the right to opt-out of our direct marketingactivities at any time. You can do this by:

• contacting our representative listed in the “Contact Us” section below; or
• in the case of emails, by clicking the unsubscribe link at the bottom of the emails. Your withdrawal will be properly documented and withdrawal will not affect the lawfulness of processing before the withdrawal.

How We Will Use Your Personal Data
We will process (including without limitation collect, store, hold, use,transfer and disclose) the information you provide in a manner compatible withthe required laws and regulations. We will endeavour to keep your informationsecured, accurate and up to date, and not keep it for longer than is necessary.

Our Legal Basis for Processing Personal Data for Customers in the EU
There are a number of different ways that we are lawfully able to process yourpersonal data. We have set these out below:
Where using your data is in our legitimate interests
We are allowed to use your personal data where it is in our interests to do so,and those interests are not outweighed by any potential prejudice to you.
We believe that our use of your personal data is within a number of ourlegitimate interests, including but not limited to:

• conducting business by providing services to you, including verifying your identity and any accounts you have with us; administering any loyalty or other marketing activities, processing your orders for products and maintaining your shopping cart, attending to billing, payments, refunds and delivery arrangements; handling and responding to your inquiries, suggestions or complaints; conducting analysis and for other Purposes, providing you with direct marketing communication as you can reasonably expect at the time and in the context of collection of your personal information that processing for direct marketing purpose may take place;
• to help us satisfy our legal obligations (for example, in relation to prevention of money laundering and anti-terrorism);
• to help us understand our customers better and provide better, more relevant services to them;
• to ensure that our service runs smoothly;
• to help us keep our systems secure and prevent unauthorised access or cyber-attacks; and
• to drive commercial value for the benefit of our shareholders.
• We do not think that any of the activities set out in this Privacy Policy will prejudice you in any way. However, you do have the right to object to our processing your personal data on this basis.
• Where you give us your consent to use your personal data
• We are allowed to use your data where you have specifically consented. In order for your consent to be valid:
• It has to be given freely, without us putting you under any type of pressure;
• You have to know what you are consenting to – so we will make sure we give you enough information;
• You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you do not know exactly what you are agreeing to; and
• You need to take positive and affirmative action in giving us your consent – we are likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

You have the right to withdraw your consent at any time.We have set out details regarding how you can go about this in the “Contact Us”section below.
Where using your personal data is necessary for us to carry out our obligationsunder our contract with you. We are allowed to use your personal data when itis necessary to do so for the performance of our contract with you. Forexample, we need to collect your credit card and bank account details in orderto be able to process your payments. Where processing is necessary for us tocarry out our legal obligations As well as our obligations to you under anycontract, we also have other legal obligations that we need to comply with andwe are allowed to use your personal data when we need to in order to complywith those other legal obligations.

The provision of such personal data is voluntary.

Cookies

We use cookies in order to improve your shopping experience when you visit Thehanli.com. Cookies are small pieces of information that your web browser stores on your computer when you visit a website. Our cookies let us personalize your visits to Thehanli.com and recognize you when you return. Information collected from these cookies may be used for the purposes laid out above in this privacy policy.

Most browsers automatically accept cookies. You can disable cookies on your computer by indicating this in the preferences or options menus in your browser. If you disable cookies, you will not be able to shop at Thehanli.com but will still be able to visit selected areas of the site.

What Information We Share and How We Share Them
We may disclose or transfer your personal data to companies within the TheHanli or to any third party service providers or business partners, whetherwithin or outside your jurisdiction, as necessary on a need-to-know basis tofulfil any of the Purposes. For transfer of personal data outside yourjurisdiction, we will adopt contractual or other appropriate measures to safeguardyour personal data, to provide a standard of protection at least comparable tothat standard under the data protection laws in your jurisdiction, and to usethem only to fulfil the above Purposes on our behalf or otherwise in accordancewith any other cross-border data transfer mechanisms under the data protectionlaws of your jurisdiction. We may also disclose or transfer your personal datato any other party when we believe such disclosure or transfer is required forlegal or regulatory reasons or where it is necessary to protect our interests(as permitted by law), for example, to our insurers in cases of potentialclaims. We also reserve the right to transfer your personal information with usin the event we are involved in any merger, acquisition or corporatereorganization (as permitted by law).

Your Rights as a Data Subject
You have the right to request a copy of the information that we hold about youand to correct the personal data that we hold about you that is inaccurate orincomplete. We will seek to deal with your request without undue delay, and inany event within the applicable time period under the data protection laws inyour jurisdiction (subject to any extensions to which we are lawfullyentitled). In the event that we refuse your requests to have access to orcorrection of your personal information, we will provide you with a reason asto why.
For customers in Singapore, you have the right to withdraw your consent for thecollection, use or disclosure of your personal data at any time by writing tous using one of the channels set out in the “Contact Us” section below. Uponthe receipt of such withdrawal of consent, we will cease to collect, use anddisclose your personal data unless otherwise permitted by law. However, suchwithdrawal of consent is likely to affect our ability to continue to provideproducts and services to you. You also have certain personal data rights,including to access what personal information we have about you, makecorrections, update or require that we cease to use and disclose, or undercertain circumstances and subject to restrictions and exemptions, delete thepersonal information that we have collected about you. For customers inMalaysia, you may exercise your statutory rights including to: (i) opt-out ofdirect marketing; or (ii) withdraw your consent to our processing of yourpersonal data, by contacting us via the contact details listed in the “ContactUs” Section below. If you are residents in the EU, at any point while we are inpossession of or processing your personal data, you also have the followingrights under the General Data Protection Regulation (GDPR):

(i) Right to object

• You have the right to object to us processing your personal data for one of the following reasons: (i) where it is within our legitimate interest; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and/or (iv) for scientific, historical, research, or statistical purposes.
• The "legitimate interests" category above is the one most likely to apply in relation to our relationship, and if your objection relates to us processing your personal data because we deem it necessary for our legitimate interests, we will act on your objection by ceasing the activity in question unless we:
• have compelling legitimate grounds for processing which overrides your interests; or
• are processing your data for the establishment, exercise or defence of a legal claim.

(ii) Right to withdraw consent

• Where we have obtained your consent to process your personal data for certain activities (for example, for automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to, unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of the same.
• (iii) Right to submit a data subject access request (DSAR)
• You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you for more information about your request. We may refuse your request where we are legally permitted to do so, and we will inform you of the reasons for our refusal. If we provide you with access to the information we hold about you, we will charge you if your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible.
• (iv) Right to erasure
• You have the right to request that we "erase" your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
• the data is no longer necessary for the purpose for which we originally collected and/or processed them;
• where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
• the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
• it is necessary for the data to be erased in order for us to comply with our obligations as a data controller under EU or Member State law; or
• if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
• We would only be entitled to refuse to comply with your request for erasure for one of the following reasons:
• to exercise the right of freedom of expression and information;
• to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
• for public health reasons in the public interest;
• for archival, research or statistical purposes; or
• to exercise or defend a legal claim.
• When complying with a valid request for the erasure of data, we will take all reasonably practicable steps to delete the relevant data.
• (v) Right to restrict processing
• You have the right to request that we restrict our processing of your personal data in certain circumstances*1. Upon acceptance of your request, we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances (as listed in *1) is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will notify you before lifting any restriction on processing your personal data.
• *1:The circumstances in which you are entitled to request that we restrict the processing of your personal data are: (a) where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified; (b) where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data; (c) where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and (d) where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

(vi) Right to rectification

• You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you, including by means of providing a supplementary statement. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

(vii) Right of data portability

• The right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
• You have the right to transfer your personal data between data controllers which means that you are able to transfer the details we hold on you to another employer or a third party. We will provide you with your data in a commonly used machine-readable format to allow you to effect such transfer. Alternatively, we may directly transfer the data for you.

(viii) Right to lodge a complaint with asupervisory authority

• You also have the right to lodge a complaint with your local supervisory authority.

If you would like to exercise any of these rights, orwithdraw your consent to the processing of your personal data (where consent isour legal basis for processing your personal data), details of how to contactus can be found in the “Contact Us” section of this Privacy Policy. Please notethat we may keep a record of your communications to help us resolve any issueswhich you raise.
If you consider that our processing of your personal information infringes dataprotection laws, you have a legal right to lodge a complaint with a supervisoryauthority responsible for data protection in your habitual residence or to ourrepresentative whose contact details may be found at the “Contact Us” sectionbelow.

Retention of Personal Data
We will periodically review the personal data we hold. We will retain yourpersonal data for as long as it is necessary to fulfil the Purposes for whichthe personal data is to be used, and delete any of your personal data that wehave stored as soon as reasonably practicable, subject to, or where otherwiserequired or permitted by law.
While we will endeavour to permanently erase your personal data once it reachesthe end of its retention period, some of your personal data may still existwithin our systems, for example if it is waiting to be overwritten. For ourpurposes, this data has been put beyond use, meaning that, while it stillexists in the electronic ether, our employees will not have any access to it oruse it again.

Protection of Information
In order to protect your personal data against accidental, unlawful orunauthorized access, we will implement appropriate measures to protect theconfidentiality and security of the personal data that we collect and process.

Websites of Third Parties
This Privacy Policy only applies to us, but not to any other third parties(including any websites maintained by them). When you click on links and/or adbanners that take you to either third parties’ websites or websites ofcompanies associated with us, you will be subject to the privacy policies ofthose parties. Whilst we support the protections of privacy on the internet, wedo not accept responsibility for any actions taken by third parties outside ourweb domain.

Children’s Privacy
We do not intend to transact through our website or mobile application directlywith anyone we know to be under the age of 16. If you are under the age of 16,you should use our website or mobile application only with the involvement of aparent or guardian and should not submit any personal data to us.

Changes to Privacy Policy
We may change this Privacy Policy from time to time by posting the updatedversion of the Privacy Policy on our website and other mobile platforms. Weencourage you to visit frequently to stay informed of our most updated version.

Member Information

Thehanli.com members enjoy many privileges, including newsletters, participation in special Thehanli.com offers and promotions and streamline shopping. Over time we will be expanding membership benefits to include personalized services on the site and possibly free product samples and other special benefits. When you join Thehanli.com, we need to know your name, email and mailing addresses, and we request that you complete the profile survey in order to allow us to serve you better.

Ordering Information

When you place an order with Thehanli.com you will be asked to provide details such as credit card number and shipping address. This allows us to process and fulfill your order and to notify you of your order status.

Further Information

Contact Us

If you have any questions regarding this Privacy Policy or would like to exercise your rights to request access to or the correction of the data,
For online shopping and retail store customers in Hong Kong, please contact our Customer Service Representative

• by e-mail: contact@thehanli.com; or
• by mail: The Hanli Intl Corp Ltd. 16A CKK Commercial Ctr 289 Hennessy Road Wan Chai, Hong Kong