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Privacy Policy

  1. INTRODUCTION

Noble Elegance Holding Ltd. and its affiliates (“FINE”, “our”, “us”, or “we”) respect the privacy rights of our customers and others whose personal data we process. We have adopted this Privacy Policy (“Policy”) to govern how we collect, store, use, process and disclose the information that you give us online through fine.global or any mobile app we may make available (together, our "Site") or via a third party website, or in one of our stores

 

This Policy is subject to all applicable data protection laws and regulations.

By accessing or using our Site, or placing orders for or purchasing our products, you agree that we will process your Personal Data in the manner described in this Policy. 

We may revise this Policy from time to time on notice to you by posting the amended terms on our Site.

By continuing to access or use our Site, make requests to reserve products, or place orders for or purchase our products after an updated Policy is posted, you are agreeing to the revised Policy. 

Our Site may contain links to third-party sites. FINE does not control these third-party sites or the companies or individuals who maintain them. We are not responsible for the actions of these third parties, or for any of your Personal Data that you provide to them after you leave our Site. 

This Policy was written in English. To the extent any translated version of this Policy we make available conflicts with the English version, the English version controls.

2.YOUR PERSONAL DATA

We may collect the following information relating to you:

Personal Data” means any information that relates to you from which it is practicable to ascertain your identity. Subject to applicable law, this may include the following:

  • information you provide
    • to us online or in-store, which may include the following:
      • Name prefix (e.g., Mr., Ms.) and full name;
      • Primary and secondary telephone numbers;
      • Email address; 
      • Physical address; and
      • Country of residence;
    • information we collect as you browse the Site, such as Location Data, Log Data, page views and links to third-party sites you access through the Site;
    • information we collect when you purchase our products, including details of the products you have purchased, payment instructions, your preferred location of product delivery or pick-up, and other transaction details;
    • other information you provide to us through the Site or when you interact with our customer service representatives, in-store personnel and other personnel, such as your feedback, reviews, opinions or complaints about the Site, or our products and services; and
      • if you are a job applicant, information you provide us with as part of your job application and as part of any subsequent interview process, such as your professional references, and information about your education and job background.
      information we collect as you browse the Site, such as Location Data, Log Data, page views and links to third-party sites you access through the Site

     "Location Data" means information regarding your location when you access the Site, including the IP address of the device or Internet service you use to access our Site, the location of your device when you access the Site, and your activity status.

    "Log Data" means technical information that we automatically collect when you use or access the Site, whether through cookies or otherwise as set out in Section V, including any unique identifier associated with your device, your browser settings and other information.

    3. PURPOSE

    We may use your Personal Data for any of the following purposes:

    • to process your payment instructions when you purchase our products;
    • to provide you with location-based services through the Site, such as personalized content;
    • for customer service;
    • for the detection and prevention of crime including fraud, intellectual property infringement, misuse of our Site or other violations of applicable law;
    • to keep records as may be required of FINE under applicable laws and regulations (whether in your jurisdiction of residence or elsewhere);
    • for archival and backup purposes in connection with the ordering and sale of our products;
    • to offer you marketing materials and advertising as set out in Section VII;
    • to better understand how you access and use the Site in order to improve and personalize the presentation of the Site to you;
    • to conduct research, statistical analysis and behavioural analysis in relation to our Site and our products;
    • to allow you to participate in surveys and other activities about our products;
    • to administer and protect our business and Site, including troubleshooting, system maintenance, support, reporting and hosting of data.
    • if you are a job applicant, to process your application as set out in Section VI; and
    • for other purposes directly related to any of the foregoing.

    Where we need to collect Personal Data by applicable law, or under the terms of a contract we entered into with you, and you fail to provide that Personal Data requested by us, we may not be able to provide you the requested service or complete your transaction.

    4. LOCATION OF COLLECTION AND STORAGE

    You consent to the processing and storage of your Personal Data in locations other than the location from which you access the Site.

    5. COOKIES AND SIMILAR TECHNOLOGIES

    We automatically analyze trends and monitor usage statistics of our Site by tracking the pages viewed on our Site, the previous and following sites visited, the browser used and the computer’s IP address. You may browse our Site without telling us who you are or revealing your Personal Data. However, some of the functionality made available through the Site, in particular, any request to reserve our products, will not be available unless you provide us with Personal Data.  

    We use “cookies” (small pieces of information sent to and stored on your computer) on certain pages of our Site to help analyze our web page traffic, customize our services, measure promotional effectiveness and maintain Internet security. We use cookies to help identify you and maintain your signed-in status. We offer certain features that are available only through the use of cookies. You are always free to decline our cookies or modify cookie settings if your browser permits, although doing so may interfere with your use of our Site, in particular, your ability to request a reservation of our products through the Site.

    FINE also works with advertising partners that use cookies, pixel tags and other tracking technologies to serve advertisements on behalf of their retail clients, including FINE, across the Internet, including to you after you have visited our Site. These advertising partners engage in remarketing, online behavioral advertising and ad delivery and reporting. These advertising partners may collect anonymous information about your browser as it makes visits to websites across the Internet (including our Site) and your interaction with our advertising and e-mail communications. This anonymous information may also be used to tailor advertising for you and others elsewhere on the Internet. FINE will have access to the information collected by these advertising partners and can then use it in combination with Personal Data provided by you to FINE to enhance your experience on our Site.

    DIRECT MARKETING

    With your consent, we may use your contact details forming part of your Personal Data for the purpose of sending you direct marketing that offers or advertises our products. With your consent, we may contact you by mail, telephone, social media, SMS, text/picture/video message, fax and email.

    These communications may include:

    • communicating to you regarding new product launches and other promotional activities;
    • communicating to you regarding our promotional events including where applicable, member exclusive events, store openings and workshops;
    • communicating in and out of store services, promotions and events;
    • FINE membership programs, birthday offers, sampling, digital campaigns, roadshows, and in-store promotion updates;
    • communicating joint promotions or events with third parties (such as shopping malls, department stores, banks, websites, charities or non-profit organizations); and

    We will honor your request for us to not use your Personal Data for such direct marketing purposes noted above.  If you wish to make such a request, please: (i) notify our Data Protection Officer at the address set out in Section XIII; (ii) follow the relevant instructions on our marketing communications; or (iii) follow the instructions as set out in certain service-specific guidance.

    Please note that we will not share your Personal Data with advertisers unless you have given us your consent to do so.

    6. DISCLOSURE

    Other than as permitted under this Policy or as otherwise consented to by you, we will not share or transfer your Personal Data to any other third parties for their processing for any purposes.

    We may share or transfer your Personal Data as follows:

    • within the FINE Group worldwide;
    • with agents, contractors, third party service providers (such as those providing administrative, telecommunications, computer and other services to us in connection with the managing, processing and storage of your Personal Data);
    • if we or any member of the FINE Group is acquired or decides to sell or reorganize any relevant part of our business, to any actual or proposed acquirer, assignee, transferee or successor who agrees to assume our obligations to you under this Policy; or
    • (i) in order to comply with applicable laws or regulations (whether of your jurisdiction or elsewhere); (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations.

     7. INTERNATIONAL TRANSFERS

    FINE is a global company, hence your Personal Data may be collected in, transferred to or accessed by FINE, our affiliates, suppliers and/or agents located in jurisdiction outside of your jurisdiction of residence. Please be aware that the privacy protection and legal requirements, including the rights of authorities to access your Personal Data, in some country may not be equivalent to those in your jurisdiction of residence. However, we will perform security assessment for the international transfers of Personal Data to the extent required by applicable law and take reasonable actions to protect your privacy, such as obtaining your consent or de-identify your Personal Data.

    8. SECURITY

    We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of your Personal Data.  The safety and security of your Personal Data also depends on you, so you should keep your log-on credentials and passwords secure and confidential. 

    9. YOUR RIGHT TO ACCESS AND CORRECTION

    Subject to applicable law, you may have the right to request access to, correct and/or delete Personal Data we hold about you. Where required by law, we will facilitate your exercise of your rights.

    If you wish to exercise your rights under this Section XI, you may direct such request to our Data Protection Officer using the contact details in Section XIII. Please note that, to the extent permitted under application law, we may charge you a reasonable fee for providing such access.

    10. AGE RESTRICTIONS

    FINE recognizes a special obligation to protect Personal Data of young children. Therefore, children under 13 years of age (or such other age as may be determined by applicable law) should not use our Site. 

    11. DATA PRIVACY OFFICER

    If you would like to make any inquiries about your Personal Data or request that we cease use of your Personal Data for the above purposes, please contact our Data Protection Officer at:

    Noble Elegance Holdings Ltd

    Data Protection Officer

    2003 Tower 5, China Hong Kong City, 33 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong, SAR China

    or via email at fine@fine.global

    Tel: +852 6333 2597

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