Gilman Group

1. General
1.1. This statement provides information onthe policies of GilmanGroup Limited (member of Dah Chong Hong Group Limited) in respect of anybusiness and website of the Company (collectively "Businesses") underthe Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong (“Ordinance”).
1.2. Terms used in this statement shall, unlessotherwise specified, be construed in accordance with the Ordinance.

2. Purpose of collection of personal data
2.1. The provision of any personal data byyou or on your behalf to the Businesses shall be voluntary and shall be deemedto authorize our Company to collect,retain, update and use your personal data for the purpose of clause 2.2 below.
2.2. The personal data provided by you oron your behalf to the Businesses fromtime to time as well as all other personal data related to you collected andheld by our Company will be used for the following purposes:
(1) Processing your application formembership of the loyalty programmes of the Businesses including but notlimited to Gilman.More;
(2) Operating daily for provision of goods,facilities and services to you;
(3) Providing additional goods, facilitiesand services to you as they may arise from time to time;
(4) Collecting outstanding amount payableby customers;
(5) Updating and verifying your identityand other information in accordance with relevant laws;
(6) Marketing and direct marketingpurposes, including the service or products of selected business partners, andissuing any advertising and/or marketing materials to you;
(7) Conducting statistics and marketresearch for the purpose of providing products or services to you;
(8) Performing statistical analysis of yourhabit and behaviour in order to design suitable products and services to you;
(9) Comparing the personal data provided byyou with your other information possessed from time to time by any other memberof Gilman Group Limited for verification purposes;
(10) Making such disclosures as may berequired for any of the above purposes or by law;
(11) Achieving any other lawful purposesrelating to any of the aforesaid purposes; and
(12) Enforcing any legal or other rightsthat our Company may have against you in respect of the Businesses.
2.3. In the event that in our Company'sopinion, the personal data provided by you is insufficient or our Company isnot satisfied that such data is true and accurate, our Company reserves theright to refuse to withhold process of your application or provision of anyservice to you unless and until the personal data required by our Company isprovided.
2.4. For the purposes stipulated in clause2.2 above, any employee of our Company shall be entitled to inspect thepersonal data provided by you.

3. Use of personal data
Our Company will ensure the confidentialityof collected personal data but may provide such information to the followingparties (including parties within as well as outside the Hong Kong SpecialAdministrative Region (“Hong Kong”)) for the purpose of implementing the“purpose of collection of personal data” mentioned above:
(a) Any agent, contractor or third partyservice provider who provides administrative, telecommunications, computer, orother services to the Businesses;
(b) Any agent authorized by the Businessesfrom time to time to process personal data of our customer;
(c) Any business partner selected by theBusinesses;
(d) Any other members of the Dah Chong Hong Holdings Limitedand Gilman Group Limited, within as well as outside Hong Kong;
(e) Auditors, consultants or legaladviser(s) of our Company , within as well as outside Hong Kong;
(f) Any other person under a duty ofconfidentiality to our Company; and
(g) Any of the actual or proposed assigneesor transferees of the Businesses.

4. Duty of confidentiality
4.1. Our Company shall exercise reasonable endeavorsto ensure that the personal data provided by you shall be kept confidential andbe placed in secure locations. OurCompany shall further exercise reasonable endeavors to ensure the integrity,prudence and competence of the persons who have access to such data.
4.2. In compliance with any law in HongKong, our Company may disclose the personal data provided by you togovernmental authorities or other regulatory bodies or persons.

5. Special provisions for personal dataheld by our Company on the internet
5.1. By assessing the Businesses throughour Company's website (“Site”), you shall be deemed to agree to the terms andconditions in this statement.
5.2. All reasonable efforts are made toensure that any personal data held by our Company from time to time through theSite is stored in secure and safe storage.
5.3.Our Company may use “cookies” on the Site so as to:
(a) enable tighter security;
(b) enable you to complete the application process;
(c) personalize the Site for you;
(d) improve our service and understand our visitor behaviour; and
(e)build online profile for you.
5.4. You may disallow “cookies” at any time on your webbrowser. If you disable cookies, you acknowledged that you may not able to usesame of the functionality of our website.

6. Your rights
6.1. In the event that you have objectionsto any use of the personal data in accordance with clause 2 or any provision ordisclosure of such data in accordance with clause 3 above, please inform ourCompany in writing. The address of ourCompany is stated in the relevant forms/contracts executed between you andus. Our Company shall cease the useand/or provision or disclosure of such data upon confirmation of your request.
6.2. Unless you request our Company todispose of all personal data provided by you, you acknowledge that we shallretain all such personal data and may continue to deliver to you marketinginformation even after cancellation or withdrawal of your application formembership of any of the clubs organized by the Businesses or your membershipin such clubs, expiry of the warranty period of any goods supplied or serviceprovided by the Businesses or completion of any sale of goods or provision ofservices by the Businesses (as the case may be).

7. Access and correction request
7.1. You have the right to request accessto and correction of your personal data in accordance with the Ordinance.
7.2. In the event that you intend tocorrect any personal data, please inform our Company in writing so that ourCompany shall be able to make the amendments accordingly.
7.3. Enquiries concerning the personal datacollected, including access and corrections, should be addressed to the addressstated in the relevant forms/contracts executed between you and our Company orany other address from time to time stipulated by the Businesses.
7.4. In accordance with the terms of theOrdinance, our Company has the right to charge a reasonable fee for theprocessing of any data access request. You agree to pay such fees.

8. Use of personal data in Direct Marketing
The Businesses intend to use a customer'spersonal data in direct marketing and may not so use the data unless ourCompany has received the customer's consent (which includes an indication of noobjection) to such intended use. In thisconnection, please note that: 8.1 the name, contact details, products andservices portfolio information, transaction pattern and behaviour, consumptionpreference, financial background and demographic data of the customer held bythe Businesses from time to time may be used by the Businesses in direct marketing;
8.2 The following classes of goods,facilities, services, and other marketing subjects may be marketed by the Businesses, namely:
(a) Member activities , member offers andservice
(b) Retail
(c) Pre-order and home delivery service
(d) Consumer products and services
(e) On-line service
8.3. the above goods, facilities, servicesand marketing subjects may be provided or solicited by the Businesses and/or:
(a) any subsidiary, affiliate or associatedcompany of Gilman Group Limited;
(b) any third party goods and/or servicesprovider;
(c) any third party reward, loyalty,co-branding or privileges programme provider; and
(d) any charitable organization;
8.4. in addition to marketing the abovegoods, facilities, services and other marketing subjects by itself, theBusinesses also intend to provide the above personal data to all or any of thepersons described in sub-paragraph (iii) above for use by them or it in marketingthose goods, facilities, services and other marketing subjects, and theBusinesses may not so provide the data unless our Company has received thecustomer's written consent (which includes an indication of no objection) tothe intended provision.
If the customer does not wish theBusinesses to use or provide to any other persons his personal data for use indirect marketing as described above, the customer may exercise his opt-outright by notifying our Company, in which event the Businesses must, withoutcharge to the customer, cease to use or provide to other persons the customer'spersonal data for use in direct marketing.
The customer may provide his consent to theBusinesses' using or providing to other person his personal data for use in directmarketing as described above by notifying the Data Protection Officer of theBusinesses, whose contact details are set out below, or through such otherchannel which the customer may be advised of when providing personal data tothe Businesses.

9. Data protection officer of theBusinesses
The person to whom requests for access todata or correction of data or for information regarding our Company's privacypolicies and practices and kinds of data held and for any other communicationshereinabove described are to be addressed is as follows:

The Data Protection Officer
[email protected]

10. Language
If there is any discrepancy between the Chinese and English versions, the English version shall prevail.