Annex A to the Addendum – Rules on processing minors’ personal data (hereinafter “Annex A”)

1. Application

This Annex A provides the rules of the activities of K11 Retail & Corporate Sales Company Limited in processing personal data of persons aged below eighteen (18) who are:-

1. located in Mainland China who visits the Website of K11 RCS, or otherwise uses K11 RCS’ products and/or services by phone or any other means from Mainland China; and/or
2. holding Mainland China passports and/or resident identity cards who visit the physical stores of K11 RCS in Hong Kong or otherwise use K11 RCS’ products and/or services by phone or any other means in Hong Kong.

(The aforesaid persons aged below eighteen (18) hereinafter referred to as “Minor”, “Minors” or “Minor(s)”.)

If you are a Minor, please read the RCS Privacy Policy Statement, PICS, the Addendum and this Annex A together with your parents or legal guardians and obtain their consent before providing any personal data to us.

If you are the parents or legal guardians who would like to provide any personal data of Minor(s) under your care, please ensure that you have carefully read, understood and agreed to the RCS Privacy Policy Statement, PICS, the Addendum and this Annex A before doing so.

In the event of any conflict or inconsistency concerning the processing of Minors’ personal data, they shall be resolved in the following order of precedence (from higher to lower): - (a) this Annex A; (b) the Addendum; (c) the PICS and (d) the RCS Privacy Policy Statement.

2. Personal data

Clause 2 of the Addendum applies, save and except that the “sensitive personal data” involved in this Annex A includes all Minors’ personal data.

3. How we collect and process Minors’ personal data

The following shall apply to how we collect and process Minors’ personal data:-

1. Minors’ personal data shall only be provided to us upon the consent of Minors’ parents or legal guardians. If the Minors’ parents or legal guardians subsequently withdraw the consent, they and the Minors shall immediately cease the provision of their personal data to us.
2. If Minors’ parents or legal guardians become aware that without their consent Minors under their care have provided personal data to us, please notify us to delete them by contacting our Personal Data Privacy Officer via the contact details set out in Clause 10 of the Addendum.
3. Minor’s personal data will be processed by us for the purposes as further specified below only (“Purposes for Minors”). In particular, in order for us to carry out the Purposes for Minors, the personal data set out below (either collected from you directly and/or entities that may have other business collaboration relating to the Purposes with us) may be required to be provided. If such information is not available or not accurate, we may not be able to perform the Purposes for Minors. For the avoidance of doubt, if/where applicable, we will indicate which kind of personal data is mandatory or optional for you to provide at the relevant time of data collection, e.g. when you register your membership account(s) with the relevant club(s)/loyalty programme(s) operated by us:-
Purposes
1. For daily operation and administration of your Website account, and to contact you in connection with your Website account
   • Name
   • Contact number
   • E-mail address
2. To deliver bespoke services and membership benefits to you
   • Name
   • Contact number
   • E-mail address
3. To process bookings, purchases, orders or requests made by you
   • Name
   • Contact number
   • E-mail address
   • Transaction Status
   • Transaction Receipt and Record
   • Mailing/correspondence address
   • Point record
   • Point balance(if possible)
4. To send you birthday messages and offers (if you have provided your date of birth) or event reminders
   • Name
   • Contact number
   • E-mail address
   • Member Join date
5. Identifying and verifying your identity and/or as a member
   • Name
   • User name and password
   • E-mail address
   • Point record
   • Point balance(if possible)
6. Registering you as a user of the Website (as the case may be)
   • Name
   • Contact number
   • E-mail address
   • Mailing/correspondence address
   • Point record
   • Point balance(if possible)
   • Member Join date
7. To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Website
   • Log Files
   • Tracking Data
   • Point record
   • Point balance(if possible)
8. Following registration as a user, accessing your account information (including, but not limited to, your name, membership number (if/where applicable), etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/ unsubscribing from direct marketing, etc.)
   • Log Files
   • Point record
   • Point balance(if possible)
9. Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour to provide other goods and/or services better tailored to your needs, and to assist us in selecting Marketing Subjects that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining
   • Name
   • Transaction information (including your characteristics and transaction behavior)
   • Mailing/ correspondence address
   • Log Files
   • Point record
   • Point balance(if possible)
10. For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future)
    • Name
    • Contact number
    • E-mail address
    • Point record
    • Point balance(if possible)
11. Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future)
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
12. Improving the Website, the Purposes, and our and our Affiliates’ and Marketing Partners’ Goods and Services
    • Tracking Data
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
13. Direct marketing and cross-marketing for the Marketing Subjects, subject to consent
    • E-mail address
    • Contact number
    • Mailing/correspondence address
    • Tracking Data
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
14. Data analytics, profiling, information management and database administration
    • Tracking Data
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
15. Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal subject to the applicable laws and regulations in the Mainland China
    • Name
    • Contact details
    • Mailing/ correspondence address
16. Collection or recovery of any debt owed by you to us or our Affiliates
    • Name
    • Contact details
    • Mailing/ correspondence address
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
17. The normal management, operation, and maintenance of the Website and the provision of the Goods and Services to you
    • Name
    • Contact details
    • Mailing/ correspondence address
    • User name and password
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
18. Storing your personal data (whether by a single or multiple Affiliates (including us) or our Marketing Partners) for the purpose of sharing such personal data with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above
    • Name
    • Contact details
    • Mailing/ correspondence address
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
19. Other purposes ancillary or related to the above
    • Name
    • Contact details
    • E-mail address
    • Contact number
    • Mailing/ correspondence address
    • Tracking Data
    • Transaction information (including your characteristics and transaction behavior)
    • Point record
    • Point balance(if possible)
4. In general, we process Minors’ personal data with their parents or legal guardians’ consent, and where appropriate, with separate consent from you for processing your personal data under specific circumstances required by the applicable data protection laws and regulations in Mainland China. Besides, disclosure of Minors’ personal data as above mentioned will be conducted in accordance with the applicable data protection laws and regulations in Mainland China.

4. Minors’ rights as the personal data subjects

Clause 4 of the Addendum applies to the extent that you as a Minor, or the parents or legal guardians of the Minor(s), may exercise the Minor(s)’ rights as provided therein.

5. Retention of personal data

Clause 5 of the Addendum applies only to the extent for the Purposes for Minors.

In addition, we strictly control the access to Minors’ personal data and only allow authorized personnel that are strictly necessary to process Minors’ personal data to access such data.

6. How we entrust others to process, share, transfer of Minors’ personal data

Clause 6 of the Addendum applies only to the extent for the Purposes for Minors.

7. How we store and transfer Minors’ personal data

Clause 7 of the Addendum applies only to the extent for the Purposes for Minors.

8. This clause is intentionally left blank

9. Miscellaneous

Clause 9 of the Addendum applies.

10. How to contact us

Clause 10 of the Addendum applies to the extent that you as a Minor or as the parents or legal guardians of the Minor(s) may contact us or exercise the Minor(s)’ rights over their personal data as provided therein.

11. Inconsistency or conflict

Clause 11 of the Addendum applies.