Introduction

Welcome to the LanNoe’s privacy policy.

LanNoe respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can browse through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

[IMPORTANT INFORMATION AND WHO WE ARE] [THE DATA WE COLLECT ABOUT YOU] [HOW IS YOUR PERSONAL DATA COLLECTED?] [HOW WE USE YOUR PERSONAL DATA] [DISCLOSURES OF YOUR PERSONAL DATA] [INTERNATIONAL TRANSFERS] [DATA SECURITY] [DATA RETENTION] [YOUR LEGAL RIGHTS] [GLOSSARY] Important information and who we are Purpose and Declaration of this privacy policy

This privacy policy aims to give you information on how LanNoe collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in other activities that are held by LanNoe.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Hong Kong law shall apply to this privacy policy unless the judiciary finds laws in other jurisdiction are more suitable.

Controller

LanNoe HONG KONG LIMITED and its global affiliates are the controllers and responsible for your personal data (also referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy).

We have appointed Mao Jianxin who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email address: support@lannoe.com

Postal address: [Shenzhen, Guangdong.]

[Telephone number: [8618664949449]

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on September 3, 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information  includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, identification number, date of birth and gender. Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, wifi, and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.   Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

Location Data includes GPS-based location information from your use of this website. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any  Sensitive Personal information about you (this includesracial or origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health information, information about sex life or sexual orientation, etc.). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: purchase our products or services; create an account on our website; subscribe to our membership or newsletter; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as the following:

Technical Data from the following parties:

analytics providers [such as Google based outside the EU];

advertising networks; and

search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests or those of a third party (such as Fraud prevention; IT security; Use of client or employee data) and your interests and fundamental rights do not override those interests. We promise that the data usage is proportionate and fair to the user. When we need to comply with administrative or judicial authorities’ requires based on our legal obligations Where in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.  

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

A cookie is a text file stored by a web server on a computer or mobile device, and the content of a cookie can be retrieved and read only by the server that created the cookie. Cookies are unique to the browser or mobile application you are using. The text in a cookie often consists of identifiers, site names, and some numbers and characters.

Sometimes, we store cookies on computers or mobile devices for the purpose of improving user experience, including the following scenarios:

• Ensure the normal operation of the official website page. These cookies are necessary for you to browse and use the functions of official website page. Without these cookies, you may not be able to use and access the official website page normally. For example, these cookies can record the information you have entered. When you visit next time, you do not need to enter it again.

• Analyze the usage of official website pages to measure and improve the performance of the pages. This kind of cookies will collect information about your behavior when you visit the official website, such as the pages you frequently visit and whether you receive error notification. Through this information, we can improve the structure, navigation and content of the official website to provide you with a better access experience.

If you have any questions about our use of cookies or other similar technologies, you can also contact us through the contact information.

We will not use cookies for purposes other than those described above.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

The Company is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. However,we may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Our products and services are delivered through resources and servers located in different places, to offer our products and services, we may need to transfer your personal data among several countries. Authorised LanNoe personnel and third parties acting on our behalf may access, use and process personal data collected from you in a country/region that is different from the country/region where you entered the personal data, which may have less stringent data protection laws. When we transfer your personal data to other countries/regions, we will protect that the personal data as described in this statement or as otherwise disclosed to you at the time the data is collected (e.g. via privacy notice or supplementary statement of specific product or service).

LanNoe has implemented global privacy practices for processing personal data protected under various data protection laws. LanNoe transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data protection laws, including standards and conditions related to security and processing.

With respect to personal data coming from the EU or the UK, we comply with applicable legal requirements providing adequate safeguards for the transfer of personal data to countries outside of the European Economic Area (“EEA”) or  the UK. We use a variety of legal mechanisms, such as standard contractual clauses to implement the cross-border transfer of your personal data; or implement security measures like anonymisation on the data before the cross border data transfer.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. please contact na.support@popmart.com for the following purposes:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
• No fee usually required
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
• What we may need from you
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• Time limit to respond
• We try to respond to all legitimate requests within 45 calendar days. Occasionally it could take us longer than  45 days (within 90 days) if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
• Request the Closure of Your Account and the Deletion of Your Personal Information
• You can submit a request for us to permanently close your LanNoe account and delete your personal information by contacting support@popmart.com.
• Note: Once your account has been closed, all of the products and services accessed through your account will no longer be available to you, across any LanNoe sites globally.
• A confirmation notification will be sent to the email address associated to your account or via text message after the account is successfully closed.
• Note: Once your account is closed, it is no longer accessible by you or anyone else, and it cannot be restored. If you decide later that you want to start ordering from us again, or if you would like to use website features that require an account, you’ll need to create a new account.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the LanNoe Group acting as joint controllers or processors (and provide [IT and system administration services and undertake leadership reporting]).

External Third Parties

Examples of external third parties are:

Service providers; Professional advisers; Taxation authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.