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Privacy Policy

About Delvaux and this Privacy Policy

Last updated: November 2022

Delvaux has its registered offices at Boulevard Louis Schmidt 7 – 1040 Brussel (Belgium). In this Privacy Policy, we use the term Delvaux (and "we", "us" and "our") to refer to the head office of Delvaux at the registered address above, our 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 us through our online stores in digital platforms, such as T-mall flagship store, WeChat Official Accounts and mini-program), (together referred to as the “Platforms”), when you visit a Delvaux boutique, contact Delvaux reception by telephone or email, or when you interact with us over social media platforms or third party service provider platforms (including T-mall and WeChat), you may be required to provide us with this information. This Privacy Policy also explains how we collect information through the use of cookies and relevant technologies when you use our Platforms.

Before using our 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, our services may not be used or the full range of our services may be affected as a result.

Where we offer 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 this way.

Updates to this Privacy Policy

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 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, etc.

Information you provide to us and how we use it

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 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.

a. What information we collect

We will collect your personal information (including sensitive personal information) in the following scenarios in which Delvaux products and/or services are provided. For sensitive personal information that may be involved, we shall remind you by using boldface and underlining. If the personal information you provide is not your personal information, you should ensure that you have obtained the authorization and consent of the person. If we need to collect your personal information in scenarios not listed in this policy, we shall separately explain to you the personal information collection and use rules applicable to such scenarios. For matters not clearly stated in such personal information collection and use rules, the provisions of this Privacy Policy applies.

  • To access certain areas of our Platform, you will need to register with us on our Platform. During the registration process you may be asked to submit some basic personal information (including your name, date of birth and mobile phone number, and other information you may voluntarily provide to us, such as gender, age, nationality, marital status, favourites, wishlist information, hobbies and preferences). We may also collect your online identity information, including system account, IP address, account nickname, email address, relevant password, password protection questions etc.) By entering your details in the fields requested and registering your account, you enable Delvaux to provide you with the services you select.
  • When you purchase products online, from boutiques or by phone, we may collect your details related to such purchase (including the product and price of the purchase, time of order, order reference number and status) and relevant payment information details (including payment time, amount and manner, payment accountID card information and other payment information) and delivery information(including the recipient's name, address, and phone number) in order to process your orders, invoice, delivery of products and services, process the payment and update your purchase status and records etc.
  • When you contact us by phone or email (For example, you asked us about a product or service, including product maintenance services etc.) or when you visit Delvauxboutique inquiring about certain product or services or request other information, we collect your personal information (including your name and phone number etc.) so that we can check the existing records to provide you with personalized services. When you contact us by telephone, please note that phone calls will on occasion be recorded for security, collection of evidence, training, quality control, analysis and development purposes
  • If you choose to interact with Delvaux via a social media platform or other third party services (including T-mall and WeChat etc.), follow Delvaux or otherwise interact with Delvaux, we will collect the personal information (including profile picture, nickname, area and other information authorised on the prompt page) you have provided to us through that platform;
  • When you use the online customer service consulting service on our platform to contact Delvaux, we will collect your consulting content (including your preferences), so that we can respond to your consulting needs more quickly and improve our service quality;;
  • When you interact with Delvaux using our platform's video chat function, your video calls with us are sometimes recorded for training, quality control, analysis, and development purposes. We also collect chat content (including your preferences) in order to provide you with customized services and to improve the quality of our services;
  • Through third-party digital platforms (including T-mall and WeChat, etc.), we collect certain information (including web browsing history) about visitors to our Platform through relevant technologies (such as SDK and Pixels). For details, please refer to the section headed "Other information that we automatically collect "; and
  • When we provide location services (see the following "Location Services" section for details), we will collect your location information (including your precise location information) accordingly. In addition, in order to provide relevant business functions or provide you with more convenient products and/or services, we will ask for the corresponding necessary permissions (such as camera, storage, microphone, Bluetooth, contacts, etc.) based on the specific use scenarios. These authorizations are not enabled by default. Only when you trigger relevant business functions will we ask for relevant authorizations in a pop-up window. You can choose to close some or all authorizations in the platform settings, which may cause failure of performance of the corresponding business functions or failure to achieve the desired results. However, it does not affect your normal use of other functions of the product and/or service.

You can voluntarily choose whether to provide us with the personal information listed above, but if you do not provide certain information, which is necessary for the basic functions of products and/or services, we may not be able to provide you with the products and/or services you request (including processing your order, sending order confirmation notice and dispatch confirmation notice, maintenance notice, etc.). For the optional personal information you have chosen to provide, failure to provide such information will not affect the basic functions of your use of products and/or services; However, in this case, we may not be able to provide you with some specific functions or rights that rely on such information.

In addition to the above personal information, we may also collect sensitive personal information from you for specific purposes with your consent, including your personal financial information (including transaction records, payment accounts, etc.), personal identity information and other information (including communication records, whereabouts, web browsing history and precise location information, etc.).

b. How we will use your personal information

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

  • Manage and fulfill purchase and repair orders, facilitate delivery, refund, provide after-sales services, online appointment, online queueing, the extension of product warranty, exchange, proof of sale, and satisfaction survey;
  • Manage your account and our internal accounts and records;
  • Verify that you are 14 years old or older;
  • Deal with your enquiries and requests;
  • Send service-related communications, including announcements and administrative messages such as order confirmation;
  • Based on your information (such as your purchase history, favorite records, browsing records, search records, comments/sharing/likes and other interactive records, device information, gender, age, residing cities and areas), we can predict your preference characteristics through an algorithm model, identify the goods, services or other information you may be interested in, and push you the products, services Information such as activity invitation and personal benefit, or show you the products you may be interested in on our platform. When we use your personal information to make automated decisions, we ensure that transparency in decision-making, fair and unbiased results, and will not give you unreasonable differential treatment on transaction terms such as transaction price;
  • 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 us and other third-party partners and that we 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 study (including customer questionnaires) and to analyze, describe and monitor purchasing preferences in combination with anonymized personal information, so that we can continuously improve the services we provide to our customers;
  • Undertake credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platform and services secure;
  • Understand how our Platform is used so that we can continuously improve our Platform and services and other offerings;
  • Conduct direct and/or indirect user profiling for the purposes of improving the services we provide 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 our 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 expressly refuse, we may collect and process your self-disclosed or other legally disclosed personal information within a reasonable scope in order to better understand our customers and improve service quality;
  • We will share or transfer your personal information in the manner and in occasions are described in the "Entrustment, Sharing, transferring and disclose your information" section below; and
  • When we use your personal information for other purposes not specified in this Privacy Policy, we will obtain your prior consent

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 fulfill 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.

Cookies and other information that we automatically collect

Like most platforms, Delvaux logs 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, our stores in certain third-party platforms (such as T-mall and WeChat), public accounts and mini-program may use Cookie or other similar technology to automatically collect your IP address and personal information we are authorized to obtain directly from such third-party platforms, such as the type of device you are using, the operating system and other settings. We will also collect the information from you with your prior authorisation (such as your profile photo, nickname, mini-program openID and UnionID). This information may be used to identify you as a user who has visited our mini-program when you visit our mini-program again and combine with the information on your use of the mini-program and other information about you. Furthermore, we will collect the information when you visit our mini-program, such as which pages you have visited and dwell time, in order for you to use our mini-program and relevant functions more smoothly.

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

What is a cookie?

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 our Platform is used. Cookies will tell us, for example, whether you have visited our 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 Delvaux to recognise your computer or mobile device when it revisits our Platform.
  • Third party cookies, which are served by a third-party service provider on our 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. Delvaux uses 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 does Delvaux use?

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

Type of Cookie Purpose
Management of pre-contractual relations with potential customers (prospects). The retention period is 3 years from the last action/reaction on the part of the person concerned.
Cookies necessary for essential purposes These cookies are essential to provide you with services available through this Platform and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Functional Cookies These cookies are set as required to provide a specific feature or service that you have accessed to or requested. These cookies serve a variety of purposes related to the presentation, performance and functionality of this Platform. Their overall purpose, however, is to enhance visitors’ experience and enjoyment of this Platform. For example, some of these cookies enable us to display our Platform in the proper format and language, product or other platform preferences. They also allow us to authenticate and verify your transactions, and to preserve the contents of your online shopping bag when shopping with us online.
Performance Cookies These cookies are used to collect information about how visitors use and interact with our Platform. The information gathered does not identify any individual visitor and is aggregated. It includes the number of visitors to our Platform, the platforms that referred them to our Platform and the pages that they visited on our Platform. We use this information to help run our Platform more efficiently, to gather broad demographic information and to monitor the level of activity on our Platform.
Advertising Cookies When you visit our Platform or click on advertisements or promotional areas on the Platform these cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help to evaluate the effectiveness of advertising and promotion. They are usually placed by advertising networks with our permission. They remember that you have visited a platform and this information is shared with other organisations such as advertisers.
Social Cookies These cookies enable users to share pages and content through third party social media and other platforms. The companies that serve these cookies may also use your information to serve targeted advertising on other platforms.

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 our 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 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.

Use of Wi-Fi Network

If you register our free Wi Fi service in our boutiques or events, we will collect some information about your device, including MAC address or IP address, connection date and time, and the location where you connect to our Wi Fi service, so as to provide you with Wi Fi service. When you connect to our Wi Fi service, you may be directed to our platform, and we may use "Cookies" to collect and process information. You can also refuse such collection without connecting to our boutiques or events Wi Fi routers.

Location information

We collect and use information about the device you are using to connect to our online services, including services on our site, application or any interactive content. This information typically includes the type of device you are using, your internet browser, your approximate 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 granting permission means that you authorise us to collect and use relevant personal information to provide you the services you request. 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 our 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 our services.

Information collection by third parties

a. Third parties for Software Development Kit (“SDK”) or Application Programming Interface(“API”) (as listed in Exhibit 1)

In order to facilitate account verification, online payment and booking delivery services or extract map data, we may incorporate third party’s relevant 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.

b. Third parties for advertising (as listed in Exhibit 1)

The Platforms use third parties such as network advertisers and ad exchanges to serve you ads on third party platforms after you leave our 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 our 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 our Platforms or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others, the use of the information that such third parties collect or the purpose 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, sharing, transferring and disclose your information

We do not share or transfer personal information about you with other people, organizations or non-affiliated companies except under the following circumstances:

  • 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 service 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 explicit 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 regulations and requirements. 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; 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 fulfill 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.

Cross-border transfers

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 and, upon your consent, may be, based on business needs, transferred to and processed by our headquarters and our affiliated group companies in places outside of Mainland China including Hong Kong SAR, Switzerland and European Union in accordance with applicable laws or in any country or region where one or more of our affiliated group companies or entrusted service providers are located or maintain facilities. For the addresses and contact details of our headquarters and affiliated group companies located outside of Mainland China, please see below. For our Group affiliates, please visit https://www.richemont.com/en/h.... The transferred information will be retained at each transferee until the earlier of the achievement of such purpose for such transferee, and the cancelation of your account. Prior to such cross-border transfers, we will (1) conduct a security assessment in accordance with the requirements of the State; or (2) be certified by a specialized institution in accordance with the provisions of the State Cyberspace Administration in respect of the protection of personal information; or (3) conclude written agreements with the overseas transferee specifying rights and obligations and supervise the overseas transferee’s processing of personal information to ensure that the overseas transferees’ processing meets the standards for protection of personal information under the Personal Information Protection Law and they only process the data within the authorised scope. While other countries/regions may not have the same standards of data protection as those within your home country, we will ensure that overseas recipients protect the personal information we transfer at the level not less than that provided in this Privacy Policy.

Headquarter:

Delvaux Design Coordination and Finance SA
Boulevard Louis Schmidt 7 – 1040 Bruxelles
Belgique

Richemont Group Headquarter:

Compagnie Financière Richemont SA
50 chemin de la Chênaie
CP 30, 1293 Bellevue
Geneva
Switzerland

Tel: +41 (0) 22 721 3500

Protecting your information

We want you to feel confident about using our 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 our 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 a 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.

Your choices

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 our Platform, or our Platform no longer serves you. You can use the user interaction function in our 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 remind you that 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 our Platforms may accordingly turn inactive for you, and our processing prior to your revocation will remain unaffected. You may withdraw your consent to processing of your personal information by us via requesting data deletion or shutting down permission or authorisation etc. 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 will only keep your information as long as necessary to serve the purposes laid out above or by applicable laws. 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. Should you wish to cancel your account or otherwise unsubscribe from one of our 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. Your personal information will be deleted or destroyed in a manner that cannot be restored or reproduced.

Minor

In commercial activities, we assume that you have the appropriate capacity for civil conduct. We understand the importance of safeguarding the personal data 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 our services or provide information to us with the consent of your parents or other guardians.

Contact us

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 a 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: clientserviceCN@delvaux.com.

Exhibit 1 List of third parties

SDK name Types of Personal Information Provided to the Third Party Purpose / Use Name of Recipients Privacy Policy Link of Data Recipient
WeChat Device IP Account Log in Tencent https://open.weixin.qq.com/cgi-bin/frame?t=news/protocol_developer_tmpl
Amap Location information, device identifier, Networking information Map navigation, specific region limited activity scope AutoNavi Holding Ltd. https://lbs.amap.com/home/privacy/