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Thank you for reading this privacy policy (“Privacy Policy”) of SOoft. For the purposes of this Privacy Policy, SOoft comprises The Pink Technology Limited and its subsidiaries (collectively, we or us). Respecting and protecting our customers’ privacy and personal data is important to us. This Privacy Policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.

In this Privacy Policy, we use the following terms from applicable laws, which we’ve defined below for your ease of reference:

• ‘Data controller’: refers to any organisation or individual that independently determines the purpose and method of processing personal data.
• ‘Data processor': refers to any organisation or individual that processes personal data on behalf of and under the instruction of another organisation or individual.
• ‘Process/processing of data’: refers to the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal data.

What information do we collect?

We collect and process personal data about you when you:

• visit and/or register on any website owned and operated by us (collectively our “Site”), including www.sooft.co.uk;
• place an order with us as a guest or as a registered user on our Site;
• use a third-party service offered by service providers such as analytics companies, advertising networks and cooperatives, demographic companies, and any other third-party service providers that we choose to collaborate or work with, and we obtain your personal data from those third parties;
• provide us with your personal data via: our physical stores, Wi-Fi, mobile devices, social media platforms/networks or telephone enquiries or your application for or use of our services or loyalty programmes (such as our Privilege Cards or private sales);
  

In this Privacy Policy, your “personal data” means: your name, email address, telephone number, mailing address, IP address, credit/debit card and other payment information, gender, date of birth, age, interests, geographical location, Site usage (including browsing activities), shopping and purchasing activities, your physiological data in images captured by our analytics cameras (which data is anonymised and aggregated before any analytics use), and any other personal data you provide to us.

How do we use this information, and what is the legal basis for this use?

We process personal data for the following purposes:

1. To conduct our business and pursue legitimate interests -- in particular, to:

• Provide our services to you, including: responding to any questions you may have of us; providing you with recommendations on products in our stores or on our Site; maintaining your shopping cart on our Site; assessing your applications with us for any of our services or loyalty programmes; providing our Privilege Card to you; fulfilling any orders you may make with us (including verification and security checks of your details, performing appropriate anti-fraud checks such as credit / identity checks, processing of your payments, and shipping to you the products that you have ordered from us); personalising our services to you and enhancing your experience in using our services;
• Monitor the use of our Site and our services (both online and offline), and use your information to help us monitor, improve and protect our products, content, services (both online and offline) and our Site;
• Analyse trends, usage, browsing and shopping behaviour with us (whether on an individualised or anonymised and aggregated basis), which helps us better understand how you and our collective customer base access and use our Site, stores and services, for the purposes of:improving our services;
  > responding to customer needs and preferences;
  > measuring the effectiveness of our marketing campaigns;
  > conducting marketing activities targeted at potential customers (on an anonymised and aggregated basis only); and
  > crowdsourcing data analytics and hackathon activities (on an aggregated and anonymised basis only).

2. When you give us consent (if required):

• To allow you to register for and participate in our events and promotions, including verifying your identity at those events and promotions; and
• To provide you with direct marketing communications in relation to products, services, events, offers or promotions under the categories stated below, provided by: (i) us or our related companies (including our affiliate and subsidiary companies), (ii) business partners, and/or (iii) other third-party providers.
• These marketing communications may:
  > be in various forms, including advertisements, newsletters and special events notifications
  > be delivered by various methods, such as email, SMS, MMS, WhatsApp, WeChat messages and notifications, smartphone app push notifications, Social Media notifications and direct messaging, including but not limited to, platforms such as Instagram, Facebook, Messenger, YouTube, X (formerly known as Twitter), Weibo, XiaoHongShu, Douyin, in-app messaging and postal mail; and
  > promote or offer products or services (including special events and promotions) in the following categories: dining, food and beverage, sports, music, film, clothing and accessories, jewellery, luggage and bags, cosmetics, personal health and hygiene, electronics, home furnishings and other homeware, automobiles, transport and travel, hotels, financial services, loyalty and reward programmes, media services, television and other entertainment services and products, social networking services, payment services, on-line advertising services, other e-commerce, information and communications services, concierge services, and other products and services related to any of the above that we think may be relevant to you based on information you have provided to us (for instance, via your participation in our surveys).

3. For purposes that are required by law, such as in response to lawful requests by government or law enforcement authorities conducting an investigation.

4. Prohibit users from spreading false information, counteract Internet rumors to maintain information security.

Withdrawing consent or otherwise objecting to direct marketing

Whenever we are required to obtain your consent to the processing of your personal data under applicable law, you will always be able to withdraw any consent you provide to us. We will then stop using your personal data for the purpose in respect of which you have withdrawn your consent, but we may still use, process, store and transfer your personal data for other purposes if applicable law allows us to do so.

You can withdraw your consent by:

• amending your preferences in the logged-in area of our Site; and/or
• contacting our Data Privacy Officer at info@sooft.co.uk; and/or
• in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.

Who will we share this data with, where and when?

We may share your personal data with the related companies of LCJG Limited and its subsidiaries located within or outside Hong Kong for the purposes set out in the section “How do we use this information, and what is the legal basis for this use?” above.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes set out in the section “How do we use this information and what is the legal basis for this use?” above, when mandated by law and in compliance with Hong Kong’s Personal Data (Privacy) Ordinance (the “Ordinance”) or other applicable laws.

Personal data will also be shared with those third party service providers located within or outside Hong Kong who we need to process it on our behalf for the purposes identified in this Privacy Policy. Amongst others, we use the following third-party providers:

• Courier and other goods delivery services;
• Email, SMS, MMS, WhatsApp, WeChat, Instagram, Facebook, Messenger, YouTube, X (formerly known as Twitter), Weibo, XiaoHongShu, Douyin, other social media notifications and direct messaging platforms and other digital notification services;
• Telecom companies (e.g. for providing in-store Wi-Fi services);
• Data storage and cloud service providers (e.g. for storing personal data and hosting applications that process personal data for the purposes identified in this Privacy Policy);
• Google, Facebook and other advertising networks (for the matching of your personal data with their database in order to send you our direct marketing materials through, e.g., your Google and/or Facebook account(s));
• Marketing (including digital marketing) and website analytic agencies for display of advertising materials on our Site and other websites that you may visit, as well as analysis of your online behaviour and usage of our Site – we note that these agencies use cookies; please refer to our separate Cookies Policy (https://www.lanecrawford.com.hk/info/help/cookies-policy/) for details;
• credit reference and fraud-prevention agencies (e.g. for performing appropriate anti-fraud checks, such as credit / identity checks); and
• Data analytics and hackathon service providers and agencies (for the purposes stated in the section “How do we use this information, and what is the legal basis for this use?” above), to whom we will only send anonymised data and then only for the purposes in the section “How do we use this information, and what is the legal basis for this use” above.
  

We may also sell your personal data to third parties for their own purposes where permitted by applicable laws.

If our business or any part of it is put up for sale, sold or integrated with another business, personal data may be disclosed to our advisers and any prospective purchaser and their advisers and will be passed to the ultimate new owners of the business.

What rights do I have?

Where permitted by law, you have the right to ask us for a copy of your personal data; to correct, delete or stop any active processing of your personal data, to obtain from us, in a structured, machine-readable format, the personal data you’ve previously provided to us, and to ask us to share this data with another data controller.
In some circumstances, your rights to object to our processing of your personal data may be limited -- for example, where fulfilling your objection request would reveal personal data about another person, where it would infringe our rights or the rights of a third party or if you ask us to delete information which we either are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions in these respects are provided under applicable laws. We will inform you of any exemptions we rely upon when responding to any objection request you make.
To exercise any of these rights, or to obtain other information (such as a copy of a legitimate interests assessment), you can get in touch with us – or our Data Privacy Officer – using the contact details set out in the section “How do I get in touch with you” below.

Who is the data controller?

The data controllers are The Pink Technology Limited and its subsidiaries; contact details for them can be found in the section “How do I get in touch with you” below.

How long will my data be kept?

• Personal data collected during your registration on our Site: we process this personal data for as long as (i) you are an active user of our Site and (ii) it is required for our business and/or legitimate interests or by law or regulation.
• Personal data processed for marketing purposes or with your consent:, we process the personal data for this purpose until you ask us to stop and for a short period after this to allow us to implement your request. We also keep a record of the fact that you have asked us not to send you direct marketing or not to process your data, so that we can respect your request in the future.
• Personal data collected by analytics cameras: we will not keep any images captured by our analytics cameras for longer than is necessary to achieve the purposes for which they are collected, and such images will be anonymised and aggregated before any use of them for the purposes stated in the section “How do we use this information, and what is the legal basis for this use?” above.
  

This Privacy Policy has been prepared in English and Chinese. If there is any discrepancy between the English and Chinese versions of it, the English version of it will prevail.

We may change the Privacy Policy in order to comply with the evolving regulatory environment or, provided that the Privacy Policy continues to comply with applicable law, the needs of our business. Subject to any applicable legal requirements to provide additional notice, any changes to this Privacy Policy will be communicated through our Site and our mobile applications. We will obtain your consent to such changes where required to do so by applicable laws.