PRIVACY POLICY

Valuence International Limited. (hereinafter referred to as the “Company”) handles a great deal of personal information in the conduct of our business. Upon execution of the business, we understand that we have the important responsibility of recognizing the importance of personal information deeply and striving for the protection thereof. The Company shall provide the following policy on protection thereof for that purpose, and strive to protect personal information. In addition, when the Company acquires personal information, the Company will disclose a Personal Information Collection Statement (“PICS”) by the proper means before the acquisition of such personal information.

1. Definitions

   The Company shall define the following information by which an individual may be distinguished as personal information:
   any data-

   1. relating directly or indirectly to a living individual;
   2. from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
   3. in a form in which access to or processing of the data is practicable

2. Types of personal information

   The Company shall handle the following personal information:

   1. Customer information

      Name, date of birth, sex, address, telephone No., email address, company name, etc.

   2. Inquiry information on goods and services

      Name, date of birth, sex, address, telephone No., email address, company name, etc.

   3. Information on applicant for recruitment (i.e. job candidates)

      Name, date of birth, sex, address, telephone No., email address, assessment for recruitment, etc.

   4. Information on employees who are or formerly were on the Company’s payroll

      Name, date of birth, sex, address, telephone No., email address, assessment for recruitment, merit rating, labor information, etc.

3. Purpose of use of personal information

   The Company shall use the personal information of customers within the scope necessary for execution of the auction related business. If the Company uses personal information for any purpose other than the following purposes of use, the Company shall specify the purpose of use on each occasion, and obtain the consent of the customer in advance:

   1. For handling of inquiries from customers, or implementation of after-sale services, or various procedures relevant to transactions,
   2. For provision of guidance including direct marketing materials with respect to services, goods or a variety of plans and programs of the Company, Group companies of the Company, or other companies affiliated with the Company (please see Item 4 below for further details),
   3. For provision of guidance relevant to business activities of the Company, including questionnaires, or campaigns, etc.,
   4. For judgments on the possibility of transactions, management of transactional status after start of the relevant transaction, credit management or claims management,
   5. For assessment of goods, or identification of customers,
   6. For prevention of unfair transactions,
   7. For marketing research or analysis,
   8. For preparation of statistical numbers for management analysis, and use of the results of analysis,
   9. For accurate handling and maintenance or improvements of quality of operators or staffers when dealing with customers by phone or directly,
   10. For judgments on recruitment of personnel that the Company needs,
   11. For personnel management affairs and business liaison, and
   12. For personnel management affairs for retired employees as provided in the laws and regulations, and contact when necessary for social gatherings, etc.

4. Use of personal information for direct marketing purposes

   The Company intends to use customers’ personal information for direct marketing purposes and your consent is required before we do so. In particular, we may use your types of personal information, e.g. name and address to contact you by methods of communication, e.g. email about our auction-related goods, services and campaigns. If you no longer want us to use your personal information for marketing purposes, please contact the Personal Information Executive Office (see Item 10 below).

   In addition, the Company intends to disclose your types of personal information, e.g. name and address to its group company Valuence Japan Inc. who provides the same type of goods and services as set out above to enable them to market their goods and services to you. Your consent is required before we do so. If you no longer want us to provide your personal information to Valuence International Limited. for marketing purposes, please contact the Personal Information Executive Office (see Item 10 below).

5. Acquisition, use and provision of personal information

   The Company will strive to acquire personal information within the scope necessary for achievement of the set purpose of use, and use this while maintaining accurate and current content. The Company will not acquire personal information that might infringe the rights and interests of individuals. In addition, the Company will not use, or disclose or provide to a third party personal information beyond the scope to which the customer has agreed. Please note that the Company may transfer your personal information to its group company Valuence Japan Inc. for the purposes set out in Item 3 above.

6. Security control measures of personal information

   The Company shall always develop and enhance security measures including information security measures that the Company has been implementing, to ensure accuracy and security of personal information, striving to prevent or correct leaks, destruction or damage, etc. of personal information, as well as to prevent unauthorized access to personal information.

7. Entrustment of personal information

   The Company may entrust all or part of the handling of personal information of customers for achievement of the purpose of use. In such instance, the Company shall entrust by choosing contractors that satisfy the personal information protection standards of the Company, and check on contractors even after entrustment through regular-basis investigations, etc.

8. Continuous improvement of the personal information management system

   The Company will reconsider this Policy, develop internal rules and regulations, provide education to employees and carry out proper internal audits, in response to information technology development and social changes, thus taking continuous basis improvement measures for proper handling of personal information.

9. Request for disclosure of personal information, etc.

   When the Company receives a request from a customer for notification, disclosure of purpose of use, correction, addition, deletion, suspension of use or erasure of contents, or suspension of provision to a third party of personal information of the customer, the Company will respect the rights of the customer to the personal information and handle the issue in good faith. The Company will also establish an inquiry section to handle disclosure requests, etc. for personal information. Please note in advance that if a customer requests disclosure or notification of the purpose of use, the Company may request a commission as a handling cost.

10. Inquiries about personal information

    Personal Information Protection Manager
    Personal Information Executive Office, Valuence International Limited.
    Address: Unit A110 & B123, 16/F, Tower 5, The Gateway Harbour City, Kowloon, Hong Kong
    Tel: +(852) 3921 5280
    Email address: info@alluhk.com