PRIVACY POLICY

Sugarfina, Inc., including our group or affiliated companies ("Sugarfina" or "we" or "us") realizes the importance of privacy when you visit our website located at sugarfina.com.hk (“Website”) and will keep your personal data confidential and secure by complying with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (“PDPO”). We will ensure compliance by our staff and follow this Privacy Policy as specified below or as amended from time to time by us. Nothing in this Privacy Policy will limit your rights under the PDPO.

1. Collecting Personal Data
Sugarfina may collect some of your personal data when you join any activity organized by us and our partners or affiliates. The provision of your personal data to Sugarfina is necessary for us to provide services to you. In the event that you do not provide such information to us, we may not be able to provide any service to you. For the purpose of this Privacy Policy, "affiliates" shall include any entity directly or indirectly held by any direct or indirect shareholder of Sugarfina.

Separately, we use "cookies" or other technology (collectively “cookies”) to collect and store information about your internet connection when you visit our Website. Cookies or other technology help us to provide customized services and information. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. You are free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Website.

2. Use of Personal Data
Sugarfina uses your information to deliver our products and/or services to you, administer your account, conduct general customer affairs, conduct research and analysis, communicate with you from time to time so that you can obtain newsletters (such as customer benefits, details of activities, etc.) and marketing information, activities, products and services in relation to food and beverage and other Sugarfina merchandizes. In respect of the uses stated herein, your personal data, including your name, telephone number and electronic mail address, may be provided by us to third party data processors or services providers (including, without limitation, logistics companies, data companies, telecommunication companies and information technology companies) engaged by us for the above purposes.

3. Retention of Personal Data
Sugarfina will keep all your personal data confidential and secure at all times. The information shall only be maintained by Sugarfina for the period of time necessary to fulfill the purpose of use of such data (including any purpose directly related).

4. Direct marketing
Sugarfina intends to use your personal data for direct marketing purposes. You will need to give your consent (including representation of no objection) before any processing takes place. Please note the following:

4.1. Sugarfina may use data from time to time collected and kept by us, including your name, telephone number and electronic mail address, for direct marketing purposes;

4.2. Services, products and market subject to be used for direct marketing: information, activities, products and services in relation to food and beverages, other Sugarfina merchandise, and courses and activities organized by us and our partners or affiliates.

4.3. In order to conduct the above direct marketing, Sugarfina may engage third party data processors or services providers (including, without limitation, logistics companies, data companies, telecommunication companies and information technology companies) to complete the tasks;

4.4. Sugarfina may transmit or disclose any of your personal data to companies (including our group or affiliated companies and our business partners (including our franchisee Upper East Corporation Limited and its subsidiaries and affiliates) that provide administrative, telecommunication, computer, payment, insurance, professional, support or other services to us (such as credit card processors or other payment services providers, mailing houses or website hosts) and that help us market our products and services (such as email vendors) for direct marketing purposes. When you give your consent (including no objection) in relation to the above use to us when provide the personal data, you represent that you have consented to our use of your personal data for the above purposes. In case you do not wish Sugarfina to so use personal data at any time, you may contact us to withdraw your consent or to change your mode of consent.

5. Right to request access to correction of personal data

5.1. You have the right to request access to and correction of your personal data held by us about you in accordance with the provisions of the PDPO. If you have any enquires regarding personal data, or requests for access to personal data or correction of personal data, you may contact us.

5.2 In accordance with the terms of PDPO, Sugarfina has the right to charge a reasonable fee for the processing of your data access request.

6. Disclosure of personal data
We may disclose your personal data if requested by authorities, courts or tribunals under applicable law or regulation.

7. Revisions to this Privacy Policy
We may review this Privacy Policy from time to time and may update and amend the same. Any amendment, update or revision to this Privacy Policy shall be effective upon posting of the same in our website.

8. Governing law
The Privacy Policy shall be governed and construed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China. Any disputes arising in connection with the Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Hong Kong Special Administrative Region of the People’s Republic of China.