Privacy Policy Statement

Thong Sia Sdn Bhd ("Thong Sia") shall fully comply with its obligations under the Malaysia Personal Data Protection Act 2010 and its regulations (collectively the "PDPA"). We shall at all times respect the confidentiality of and endeavour to keep safe Personal Data collected, stored, transmitted by us and/or used for or on our behalf.

In the event that there is any inconsistency between this Privacy Policy Statement and the PDPA, the PDPA shall prevail and the Privacy Policy Statement shall be amended accordingly.

In this Privacy Policy Statement, the meaning of the term "Personal Data" is as defined under the PDPA.

General Statement of Policies and Practices on Personal Data

Collection of Personal Data

1. For the purpose of carrying on our businesses, you may provide your Personal Data to us when you register as a Seiko Boutique Malaysia member, when you purchase a product or use our services, when you redeem gifts, when you submit any comments or feedback to us, when we ask you to verify your identity or when your image is captured by surveillance cameras at our Stores and Centres.
2. We also collect the Personal Data you may volunteer in response to surveys or questionnaires we may conduct.
3. We may collect the Personal Data when you visit our website (as detailed in section "Cookie" under this Privacy Policy Statement).
4. We may ask you to provide your Personal Data, including, name, age group, gender, contact number, email address, date of birth, purchase records, and physical address (if necessary) depending on the circumstances.
5. We will collect Personal Data on a lawful, open and fair basis.

Cookie

We may obtain information about your computer, including, where applicable, your IP address, operating system and browser type, for administration of the system and statistical analysis. This is used to obtain statistical data on how you browse our website.

We may obtain information about your online movements and general internal use by means of a cookie file that is stored in your computer's hard drive. The cookies contain information that is transferred to your computer's hard drive.

The cookies help us improve our website and provide a better and more personalized service. What this specifically allows us to do is:

• Make estimation on numbers and patterns of use;
• Store information about your preferences and personalize our website in accordance with your individual interests;
• Speed up your searches;
• Recognize you when you return to our website.

You may decline cookies by changing your browser's settings. However, if you do this, you may not be able to access certain parts of this website or avail of some of our services.

Use of Personal Data

We will collect and may use your Personal Data for the following purposes:

1. the provision, facilitation and improvement of our products and/or services to you at our Stores and/or Centres;
2. the provision, facilitation and improvement of our products and/or services to you on/through online platforms;
3. carrying out your instructions or responding to your enquiries, requests or complaints;
4. forming part of our customer data base necessary for the operations carried on by us;
5. research and analysis for marketing and promoting our products and/or services;
6. general security reasons;
7. transferring, disclosing or sharing your Personal Data amongst Thong Sia, our Affiliates and Business Partners within and outside of Malaysia;
8. to allow our Business Partners to carry out the purposes set out above;
9. any purposes related to and/or for the furtherance of the above; and
10. direct marketing purposes carried out by us, our respective Affiliates and/or Business Partners.

Without your consent, we shall not use your Personal Data for purposes other than that specified above.

Data Subject's Obligations and Accuracy

It is necessary for Thong Sia to collect and to retain your personal data. Therefore, it is also obligatory for you to supply personal data to us in the most accurate manner. If you do not provide us with personal data, we may not be able to process personal data on your behalf, for the purposes stated in this Privacy Statement, or effectively render our services to you.

We will take all practicable steps to ensure that Personal Data collected is accurate. Please endeavour to provide us with accurate Personal Data and where there are any changes to your Personal Data, please inform us as soon as possible.

Personal Data Sharing, Transfer and Disclosure

Your Personal Data may be processed and stored in territories outside of Malaysia. All Personal Data held by us will be kept confidential and we will not sell your Personal Data to any person or company but we may, where sharing, transfer or disclosure is necessary, provide such information to the following parties:

1. amongst Thong Sia, our respective Affiliates and Business Partners within and outside of Malaysia;
2. amongst Thong Sia, our respective Affiliates and Business Partners for direct marketing purposes if you have consented to do so;
3. any person or persons pursuant to any statute or as required by any court of law in Malaysia.

Access and Correction

You may check whether we hold any of your Personal Data and, if so, may request access and/or correction:

1. by sending an email to the Data Protection Officer at enquiry@thongsia.com.my;
2. by mailing us at Suite 2601-04, Level 26, Wisma Chuang, No. 34, Jalan Sultan Ismail, 50250 Kuala Lumpur, Malaysia (Attention: Data Protection Officer);
3. by calling our hotline at (603) 2141 5163.

We will take reasonable steps to verify your identity before granting access or permitting corrections to your Personal Data. We will charge a reasonable fee to cover our administrative costs when you request access. We will not charge a fee for corrections.

Security

We strive to ensure that your Personal Data will be protected against unauthorised or accidental access, processing, erasure or other use. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Data.

Retention of Personal Data

Your Personal Data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless this is contrary to any applicable laws.

Amendment to this Statement

We may amend this Privacy Policy Statement from time to time. If we make any amendments in the way we use your Personal Data, we will obtain your prior written consent through email.

Statement of Policies and Practices on Direct Marketing

We intend to use your name, email, contact number and birth month for direct marketing purposes as described below:

1. promotions and/or membership events relating to watch products/services sold/provided at our Stores and/or Centres in Malaysia, at our websites and such other online platforms and social media channels managed by us, our respective Affiliates and/or Business Partners;
2. marketing activities relating to watch products/services sold/provided at our Stores and/or Centres in Malaysia;
3. cross-marketing and promotional activities amongst Thong Sia, our Affiliates and Business Partners;
4. cross-marketing and promotional activities relating to the following types of products and services offered by our Business Partners: (i) Fashion, Footwear, Apparel & Accessories, (ii) Travel, Transport, Arts & Entertainment, (iii) Digital & Electronics, (iv) Hospitality, Food & Beverage, (v) Health, Fashion, Beauty & Accessories, (vi) Home & Office, and (vii) Sports, Toys & Games.

In future, if you do not wish to continue receiving our promotional materials for direct marketing purposes, please either send an email to the Data Protection Officer at enquiry@thongsia.com.my, or call our hotline at (603) 2141 5163 to notify us accordingly.

If there are any inconsistencies between the English version and the Malay version of this Privacy Policy Statement, the English version shall prevail.

Definitions

1. "Affiliates" mean in relation to us, another company that is a direct or indirect subsidiary of, or a direct or indirect holding company of, or another direct or indirect subsidiary of such a direct or indirect holding company of us.
2. "Business Partners" mean those persons or bodies corporate with whom we enter into arrangements with (whether directly or indirectly) for the provision of our products and/or services to you.