PRIVACY POLICY

(JANUARY 2020)

MUNDIAL is committed to protecting your personal information. It’s your information, and we respect that. Our Privacy Policy gives you detailed information on when and why we collect your personal information, how we use it and how we keep it secure. This Policy also sets out your right to request that we delete, update, transfer or provide you with access to your personal information. This Policy should be read alongside our Terms of Use. Please also note that this Privacy Policy only applies to personal information obtained by us – not information collected from your interactions with third parties.

How we collect your personal information

Generally, we collect your information when you decide to interact with us. This could include purchasing online, over the phone or in person when you sign up to receive emails from us. We also look at how customers use our website, so that we can offer the best possible experience.

Information we obtain directly from you

Here are some examples of information we collect about you when you interact with us (as detailed in point 3):

• Title
• Name and Surname
• Email address
• Date of Birth
• Contact phone number(s)
• Purchase information
• Interactions with us e.g. contacting our Customer Service, visitors logs
• Payment details
• Delivery address(s)
• Billing address
• Attendance at events
• Preferred store, categories and brands
• Appointment booking and information given during appointments
• Alterations and repair requests
• For some specific services, such as Safe Deposit box, we will also be required to collect the following information from you:
• Photograph
• Official documentation providing proof of identification (photographic identification) and related information provided on the official documentation, including, where relevant, a passport number and driving licence number
• Automatically populated IP address*
• Information from cookies**

*When visiting our website we may collect an automatically populated IP address. An IP address is a unique number which allows a computer, group of computers or other internet connected device (such as your mobile or tablet) to browse the internet. We may also record the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version.

Information we obtain independently from you:

Your information may be shared with us by independent organisations, for example other organisations that MUNDIAL has worked with. These independent organisations will only do so when there is a lawful basis to do so. You should check their Privacy Policy when you provide your information to them, to understand fully how they will process and safeguard your data. These independent organisations may include:

Third Party Organisations

We may combine information you have given to us with additional information made available from / shared with us by external sources. This will only be done when we both have a lawful basis to do so.

Information updates

From time to time we may screen our database against recognised data files, such as the National Change of Address file, to help us keep our database up to date.

Social Media

Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you may give us permission to access information from those accounts or services.

Information available publicly

We may include information found in places such as Companies House and information that has been published in, for example, articles/ newspapers / online.

Ensuring your personal information is only used where lawful

In order for our use of your personal information to comply with applicable data protection law, that use by us needs to fall under at least one of the specific lawful reasons that are set out in applicable data protection law. Examples of these lawful reasons include our use of your personal information being necessary for the purchase of goods or services, or for compliance with a legal obligation.

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, we will have a lawful reason to use your personal information in such a way to ensure that we provide the very best products to you and our other customers.

Why we collect your personal information and how we use it

At MUNDIAL, we like to get to know our customers – after all, this is how we find new ways to provide you with an extraordinary experience. We use information about you in a number of ways, including providing the services that you have requested, offering you a personalised experience and informing you about special events or exciting MUNDIAL news. We might also use the information we have to contact you about any information we might need to process your orders, returns or queries.

Examples of how we use your data are as follows:

To carry out our business and to provide a service or carry out a contract with you.

• Fulfilment of, and delivery of, products and services you have ordered. We may share your personal information with our delivery partners and third party concessions.
• Process payments. MUNDIAL does not store any payment card numbers once the transaction has been completed. We share your personal information with credit card companies and other payment providers and acquirers. These third parties will be responsible for the handling of your personal data for these purposes and their privacy policies will set out how they do this. An example of this is IPGPAY Limited, who provide payment processing services for MUNDIAL. They are a Data Controller of your transactional data in order to process the payment. IPGPAY Limited's privacy statement, which can be found on their corporate website, sets out how they use and handle your personal information.
• Contact you with important information relating to your booking or purchase, or use and administration of any of our Services, such as confirming your order, letting you know about returns and refunds and any information in relation to that Service. We may share your information with our communication partners for this purpose.

Where we have your consent:

• Send you marketing updates via email about all the latest news, events and offers at MUNDIAL. You can unsubscribe at any time by clicking the unsubscribe link in any email. We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.
• Use your details to show you advertising on such Social Media platforms, such as Facebook and Instagram, or via other third party advertising that may appear on other websites you use. Online advertising channels we may use are: digital display, video on demand, search engine marketing, paid social - these are all on third party sites or platforms.
• We tailor emails and online advertising to the things you love, so they’re relevant to your location, what you have shown an interest in and the things you buy from us.

Where we have justifiable reason (legitimate interest):

• We share your personal information with any applicable third party hosting the event and ticketing companies.
• Respond to customer service enquiries raised in the store, online, social media or on the phone.
• Send an abandoned basket email via third party suppliers.
• Invite you to provide feedback about our products and services in the form of online, email, or in-store surveys. We use this information to help us improve the quality of service provided; to monitor the quality of our products and services and to assist with the selection of future product and service lines. We use a third party service provider to assist us with customer surveys and feedback requests.
• Conduct postal marketing. We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.
• Analyse aggregated customer information with other interactions customers have with MUNDIAL in order to continually improve the products and services we offer through our stores; website and app. We do this using third parties.
• For classifying our audience into groups or segments, using shopping habits information regarding your personal or professional interests, demographics, experiences with our products and contact preferences. These segments help us to understand our audience better.
• Use of our in-store Wi-Fi; automatic re-connection when you return into the store. A MAC address to monitor Sites traffic and volume.
• Anonymous track usage statistics on our Sites. By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn what pages to target our adverts so that they’re more relevant to you.
• Measure and understand how our customers respond to our Sites and to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective.
• To help us run the test version of our website that we use internally to pilot new features and ensure the smooth running of our web services.
• To keep our database accurate and relevant, we may do this for example, using National Change of Address.
• The use of CCTV recording equipment in and around our premises for monitoring and security purposes. We may share where necessary CCTV footage to the Police. This is very strictly controlled.
• Detect and reduce fraud and credit risk.

The Privacy and Electronic Communications Regulations (PECR)

Where we have collected your contact details in store in the process of a sale (or negotiations of a sale) of a product or service, MUNDIAL will have PECR compliant permission to send you marketing updates via email. We will only send you marketing updates about MUNDIAL’s products and services.

You will be able to say no to receiving these emails when we first collect your contact details and you will be able to unsubscribe in every subsequent communication from us.

Sharing your information

We use third party platforms to manage and deliver customer relationship management (CRM); email marketing campaigns; online advertising; customer analytics; events; booking of appointments; ulfilment of orders; delivery; returns; refunds; IT services; etc. In providing the services, your personal information will, where applicable, be used by the service provider on our behalf.

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal information. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal information and their compliance with our data security standards and international transfer restrictions.

Business Administration and Legal Compliance

In certain circumstances, we share and/or are obliged to share your personal information for business administration and legal compliance purposes with third parties outside the MUNDIAL Group.

We may use your personal information in connection with a business transition (such as a merger, acquisition by another company, or a sale of all of or portion of our assets), to enforce our legal rights and/or to protect the rights of third parties and it is in our legitimate interest to do so. In such instances it will be necessary to share your personal information with external professional advisors such as lawyers and accountants, or insurers or financial institutions.

We may use your personal information for legal compliance purposes and to enforce our legal rights. In such instances it will be necessary to share your personal information with external parties such as administrative authorities (HMRC), the Financial Conduct Authority, police and public prosecutors or to comply with a court order or power of attorney. We will also need to do this to undertake customer checks to know our customers and verify their identity. We will use your information to conduct online searches with Thomson Reuters World-Check, to assist us with meeting our legal requirements. We may also be required to share your information to report any suspicious and/or criminal activity including fraud, sanctions and anti-money laundering. It is our legal obligation to do so.

How can I unsubscribe from marketing communications?

We would be sad to say goodbye, but if at any point you do not wish to hear from us there are a number of ways you can unsubscribe.

These are as follows:

• You can click onto the "unsubscribe" link in any communication that we send to you by email which will automatically unsubscribe you from that type of communication. Each "unsubscribe" link only relates to that specific type of communication (e.g. general marketing communications, specific marketing communications or survey communications). This means that unsubscribing from general marketing communications will not automatically unsubscribe you from specific marketing or our survey communications (or vice versa). Please also note that you may continue to receive communications which are already en route to you for a short period of time while your relevant unsubscribe request is being processed.
• In relation to the App, you can manage your preferences and select to opt out from one or all of the different push notifications by disabling them in your phone settings.
• Alternatively, you can contact our customer services by calling one of our telephone numbers mentinoned in here, Monday to Friday: 9am-6pm or by using our online form.

Please note that in relation to our in-store CRM system, you can ask a team member in any one of our stores to record your preferences (e.g. you can specify that you are happy for us to send you e-receipts, but that you would prefer not to be included on our marketing mailing list, or vice versa). However, should you wish for your marketing preference to be updated or changed, then you will need to contact our customer services using the contact details above.

The Website and App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that they have their own privacy policies and MUNDIAL does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal details to these websites.

Our use of cookies and similar technologies

Our website, app and emails contain certain cookies, pixels, records and other technologies of which you should be aware.

Third Party Links and services

Our website, app and emails contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.

• Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
• We encourage you to become familiar with the privacy practices of every website you visit, or third party service provider that you deal with, and to contact them if you have any questions about their respective privacy policies and practices.
• This Privacy Policy applies solely to personal information collected by us through our Sites or Services (or Third Party providers performing our Services on our behalf) and does not apply to these third party websites and third party service providers.

Joint Controllers

In certain, very limited circumstances, we are jointly responsible for determining the collection and/or use of your personal information with third party organisations (this is known as being a “joint controller”).

This is the case with our affiliate marketing partners who we work with to help us measure the success of our relevant marketing campaigns.

The personal information (IP addresses and cookie IDs) that is collected through the use of Cookies on our Sites will be processed by each party as joint controllers in accordance with data protection laws. Our Cookie Policy provides more detail about the types of Cookies we use for the above purposes (including how you can manage the use of these Cookies). Please note that the personal information collected by the Cookies will be used by the affiliate marketing partner within their affiliate marketing model for their own purposes. They will be processing the personal information in their capacity as a data controller in their own right. We will no longer be deemed to be acting as a joint controller at that point. Please see the privacy policy of the relevant affiliate marketing partner for information as to how they will process and safeguard your personal information once it has been collected on our Sites.

As set out below (“How to access your information and your other rights”) you have certain rights with regards to your personal information collected on our Sites. Should you wish to submit a request in respect of this personal information, the request can be submitted either to us, MUNDIAL (as set out in this Privacy Policy) or to the relevant affiliate marketing partner (or to both of us). The party you submit a request to will be responsible for dealing with the request and responding to you.

Children

Customers need to be over 18 years old to create an account with us and to sign up to receive our newsletter. We do not knowingly collect Personal Data from children under the age of eighteen (18). If you are under the age of eighteen (18), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Sites and Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Services, please email our Data Protection Officer at info@mundial.com.hk and we will endeavour to delete that information from our databases.

Please note that customers need to be at least 18 years old to open (or be granted access to) a Safe Deposit box.

How long do we keep your personal information for?

We keep your personal information in line with our company retention policy and as required to comply with any legislation. We only retain information for as long as it is required.

Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We do not sell your personal information for any purpose.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access
• improper use or disclosure
• unauthorised modification
• unlawful destruction or accidental loss

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

• Your right of access

• If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to correct information

• If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it corrected. If we’ve shared your personal information with others, we’ll let them know about the changes where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to delete information

• You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict information

• You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability

• With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object

• You can ask us to stop processing your personal information, and we will do so, if we are:
• Relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• Processing your personal information for direct marketing.

• Your rights in relation to automated decision-making and profilling

• You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

• Your Right to withdraw consent

• If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required, to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

COOKIES

(JANUARY 2020)

Introduction

We use cookies and similar technologies (“Cookies”) on www.MUNDIAL.com.hk and the MUNDIAL mobile application (the “Sites”) for identification, analysis and advertising purposes. By using our Sites you consent to the storing and accessing of Cookies on your device.

This cookie policy (“Cookie Policy") is intended to inform you how we use Cookies to assist you in making informed decisions when using the Sites. Please take a moment to read and understand this Cookie Policy. This Cookie Policy should also be read in conjunction with our Privacy Policy and our Terms of Use.

Cookies are very small text documents or pieces of software code, which often include an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your PC or mobile device for permission to store this file on your computer or mobile device and access information from it. Information gathered through Cookies include the date and time of visits and how you are using the website or mobile application.

Cookies are used by us and our third party partners as part of our Sites. Details of the Cookies used on our Sites and any applicable third party partner are set out in the table below.

Our use of cookies generally requires your consent

When you first access our Sites you will be asked to consent to our use of the Cookies described in this Cookie Policy.

Our Sites also uses Cookies for which we do not require your consent. This Cookie Policy refers to these Cookies as “Strictly Necessary Cookies” and without them the services that you have asked for cannot be provided.

Blocking cookies

You can consent to, revoke or block the use of, specific Cookies by activating the relevant settings in your browser.

What happens when you do not consent to cookies and or you choose to block cookies that you have previously accepted?

In order to use some parts of our Sites you will need to consent to Cookies. If you choose to withhold consent, or subsequently block cookies, some aspects of our Sites may not work properly and you may not be able to access all or part of Sites.

For more information please Contact Us.