PRIVACY POLICY

Last modified on 1 September 2022

D F I Lucky Private Limited (“Company” or “We” or “Us” or “Our”) respect and commit to protect your personal data in compliance with this Privacy Policy. This Privacy Policy applies to all the users of the website at localhost:81/WordPress or whenever we request your personal data in whatever method/platform by us. This Privacy Policy applies to all products and services provided by us and sets out how we may collect, use and disclose your personal data.

Personal Data Collection Statement

Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our products and/or services and to administer and protect any account you hold with us.

We may ask you to provide personal data when you use our website or service. The personal data that we may ask you to supply includes salutation, name, date of birth, place of birth, gender, phone number, email address, residential/other address, ID or passport number, and payment account details, where applicable.

Please note that it is mandatory for you to provide certain categories of personal data

(as specified at the time of collection). In the event that you do not provide any personal data indicated as mandatory, we may not be able to provide you with our products and/or services.

Use and Disclosure of Your Personal Data

You understand and agree that we may collect your personal data when you browse our website, communicate with us or otherwise utilise our services. In particular, we may collect your personal data:

• directly from you

• automatically from the website when you browse the website or utilise our services;

• from information that you provide by filling in forms on our website, if applicable

• from records and copies of any correspondence we may have with you

• from your responses to surveys that we might ask you to complete.

If you provide any personal data to us, you are deemed to have authorised us to collect, retain and use personal data about you for the following purposes:

(a) providing you with customer service including but not limited to processing and effecting sales, orders, refunds and exchanges relating to products available for sale in our shops, putting together shopping lists for you, providing you with a

more personalised experience on our website and responding to your queries, feedback or claims;

(b) operating, processing, maintaining and/or managing any account you may have with us, if applicable;

(c) providing you with rewards under our redemption or promotional programme(s), if applicable;

(d) contacting you for marketing and promotional purposes, where we have appropriate consents from you to do so; in this regard, we may use your name, phone number, residential/other address and email address to provide marketing materials to you relating to goods and services provided (a) in our retail stores; and (b) in other business units owned and operated by us or our business partners; such goods and services for each of the foregoing shall include the following classes: retail, cosmetics and beauty, health, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, betting (lucky draws), dining, travel, transportation, banking, electronics, home, household, textile, tele-communication, food and beverage, grocery, office and business supplies, technology, outdoor, furniture, lighting, décor, media (including digital), e-commerce platform and facilitator (including online trading, payment and auctions), and publications;

(e) to respond to your requests to access, correct or delete your personal data, or to withdraw your consent to use of your personal data;

(f) performing research or statistical analysis in order to improve our products and services, including this website; and sharing aggregate data (that does not allow you to be identified) with third parties for various purposes (including marketing and advertising), and we may use this personal data in order to better understand your needs and to improve and adapt our products and services;

(g) verifying your identity; and

(h) making such disclosures as may be required for any of the above purposes or as required by law or in respect of any feedback or claims made by you.

You understand and agree that we may disclose and transfer (whether in Cambodia or abroad) your personal data to third party service providers engaged by us to assist us with administering or otherwise processing your personal data for the abovementioned purposes (including data entry, managing our customer database, processing, effecting and verifying sales, orders, refunds and/or exchanges relating to goods available for sale in our stores, contacting you regarding promotions and other customer services) and securely disposing of your personal data. Such third party service providers are under a duty of confidentiality to us and are only permitted to process your personal data in connection with the purposes stated above. Where necessary, we may also disclose and transfer (whether in Cambodia or abroad) your personal data to our employees

professional advisers, law enforcement agencies, insurers, government and regulatory agencies, and other organizations in relation to the purposes specified above.

Confidentiality

Your personal data held by us will be kept confidential in accordance with this Privacy Policy.

Any questions, comments, suggestions or information (other than personal data) sent or posted to us by visitors will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company.

Data Security and Retention

We maintain organizational, physical, and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the use of that personal data. Our security measures are evaluated on an ongoing basis. Any servers containing personal data are protected by anti-virus software and firewalls, among other measures.

You should be aware that no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet.

This site may contain links to other sites and pages which are operated by third parties. We have no control over the content of the linked websites or the way in which the operators of those websites deal with your personal data. You should review the privacy policy for those third party websites to understand the ways in which your personal data may be used by those third parties.

Your personal data will only be kept for the period necessary to fulfil the purpose for which it was collected. For example, for the purpose of a Membership Card and/or Lucky Draw. Your personal data will be deleted after completion of the said purpose in accordance with our applicable retention period.

Information collected when you use our website

We may use ‘cookies’ on this website in order to:

· enable tighter security;

· enable online customers to keep browsing;

· personalise sites for customers; or

· build online customer or visitor profiles.

Cookies are pieces of information stored in your hard-drive about your preferences on our website, which enable the website to be tailored to you in future visits. Customers who want to disallow cookies can do so on their web browser. However, by disabling cookies you may not be able to access all parts of our website.

Right to Access and Correcting Your Information

You may request at any time, to access, correct or delete your personal data that you have provided to us. We will take reasonable steps to comply with your requests for access, correction or deletion of your personal data, as well as any withdrawal of your previous consent permitting us to process your personal data. We reserve the right to charge you a reasonable fee for the processing of any personal data access request.

Change to Our Privacy Policy

Please read this Privacy Policy thoroughly and carefully to understand our policies and practices regarding your personal data and how we will treat your personal data. By accessing or otherwise using this website and/or our services, you agree to the terms of this Privacy Policy.

If you do not agree with our policies and practices, your sole remedy is to discontinue using our website and/or services.

We may amend or update this Privacy Policy from time to time. Any future amended or updated version will be effective from the date uploaded onto the website. Your continued use of this website and/or our services after we make changes to this Privacy Policy is deemed to be acceptance of those changes.

Contact Information

If you have any questions regarding this Privacy Policy or if you wish to access, correct or delete your personal data, or withdraw your consent to our use of your personal data, you may send your request in writing to the following address:

• Cambodia Data Protection Officer

No. 01, St. 55P, Sangkat Toek Thla,

Khan Sen Sok, Phnom Penh

• Tel: +85581222355

• Email: info@dfilucky.com