PRIVACY POLICY

This is the ZALORA Personal Data Protection Policy (“Policy”) which sets forth how BF Jade E-Services Philippines, Inc. (“ZALORA”) manages, collects, uses and discloses your Personal Data, in accordance with the Philippine Data Privacy Act of 2012 (“the Act”)..
This Policy supplements, but does not supersede, nor replace, any other consents you may have previously provided to ZALORA in respect of your Personal Data.
ZALORA may update this Policy to ensure that it is consistent with any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Personal Data Protection Policy as updated from time to time on our website.


Personal Data
In this Policy, Personal Data refers to any information whether recorded in a material form or not, from which the identity of a Customer is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify a Customer.


When you create a ZALORA account, the personal information we collect may include your: Name, Email, Gender, Birthday, Mobile Number and Delivery/Billing Address.


Purposes for which Personal Information shall be Processed
ZALORA may collect, use, and disclose your Personal Data to certain third-parties identified below, for the following purposes:
  - Fulfillment and delivery of products which you have purchased from ZALORA, and updating you on the status thereof;
  - Processing your orders, including processing thereof for payment;
  - Providing you with relevant product information, responding to your queries and requests, and other customer support functions;
  - Preventing, detecting, and investigating disputes or fraud, and analyzing and managing commercial risks;
  - Analytics and tracking;
  - Conducting market research and surveys to enable us to understand and determine customer preferences and demographics, to develop special offers, and marketing programs in relation to ZALORA's products and services, and to improve customer experience;
  - Developing and providing you with additional products, services, and benefits, including promotions, loyalty and rewards programs;
  - Advertising and marketing products and services offered by ZALORA, or relevant products and services from our preferred partners, administering contests, competitions and marketing campaigns;
  - Purposes which are reasonably related to the aforesaid; and
  - Other legal purposes.


Disclosure of Personal Information
Subject to the execution of Data Sharing Agreements in accordance with the Act, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
  - ZALORA’s related corporations, including its parent company, affiliates, and subsidiaries, to provide content, products, and services to you, address your questions and requests in relation to your customer accounts, subscription, and billing or order arrangements, to activate, deactivate, install, maintain and operate our systems and/or services;
  - Companies providing consultancy services to ZALORA;
  - Agents, contractors, or third-party service providers that provide operational services to ZALORA, such as courier services, telecommunications, information technology, payment, printing, billing, technical services, training, market research, security, or other services;
  - Vendors, partners, or third-party service providers in connection with marketing promotions and services offered by ZALORA or its preferred partners;
  - Commercial shops and retailers in relation to providing rewards and benefits;
  - Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the Company;
  - Our professional advisers such as auditors and lawyers;
  - Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
  - Any other party to whom you authorize us to disclose your Personal Data to.


Scope and Method of Processing
Generally, ZALORA collects Personal Data, either directly from you or from your authorized representatives (i.e. persons whom you have authorized, persons who have been validly identified as being you or your authorized representative pursuant to our then-current security procedures), from third-parties, or from publicly available sources or through our website in the following ways:
  - When you submit a form for registering as a customer on our website or any other forms relating to any of our products and services;
  - When you interact with our customer service team, such as, but not limited to, via telephone calls, letters, face-to-face meetings and emails;
  - When you request that we contact you, be included in an email or other mailing list;
  - When you respond to our promotions, initiatives or to any request for additional Personal Data;
  - When you are contacted by, and respond to, our marketing representatives and customer service team;
  - When we receive references from business partners and third parties, such as, but not limited to, where you have been referred by them; or
  - When you submit your Personal Data to us for any other reasons.


When you browse our website, you generally do so anonymously except as otherwise described below on automated access.


If you provide us with any Personal Data relating to a third-party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.


You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.


We may store your personal data while you are a Customer, or as long as may be necessary to fulfill the purpose for which it was collected.


Methods utilized for automated access
When you visit ZALORA, our company servers will automatically record information that your browser sends whenever you visit a website. This data may include:
  - Your computer's IP address
  - Browser type
  - Webpage you were visiting before you came to our site
  - The pages with in ZALORA you visit
  - The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics.

This information is collected for analysis and evaluation in order to help us improve our site and the services and products we provide. This data will not be used in association with any other Personal Data.


As part of the above, ZALORA may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings (https://www.google.com/settings/ads), you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.


ZALORA also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show ZALORA ads on sites across the Internet. ZALORA and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors’ past visits to ZALORA, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to ZALORA.


Data Protection
The Company shall implement reasonable and appropriate organizational, physical and technical measures to protect personal information against accidental loss or destruction, unlawful access, fraudulent misuse, unlawful destruction, alteration and contamination, including the implementation of an internal data protection policy to ensure compliance with the above measures.

In sharing your personal information with third parties, whether locally or abroad, we will ensure that contractual safeguards are in place for such parties to keep your personal information secure from unauthorized access, collection, use, disclosure, or similar risks and that they retain your personal information only for such limited periods as may be necessary for the purpose.


ZALORA uses 128 - bit SSL (secure sockets layer) encryption technology when processing your financial details.


Your Rights
If you intend to exercise your rights to make inquiries, access, update, erase, destroy copies of, or correct your Personal Data, withdraw consent to the collection, use or disclosure of your Personal Data, to obtain and electronically move, copy or transfer your data, or if you believe that your privacy has been breached, you may contact the Company through the Contact Information provided below.

Should you wish to withdraw your consent for the use and disclosure of your Personal Data to send you sales, marketing or promotional information via a specific mode, please inform us through the following:
  - To withdraw consent from receiving SMS promotions: please unsubscribe by following the steps provided in the promotional SMS;
  - To withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;
  - To withdraw consent from receiving promotional material with your order package: please email customer service, with the words “PERSONAL DATA” in the subject line, at the address provided below.

Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the products and services that you hold or have subscribed to with ZALORA.


Contacting Us
For any questions relating to your Personal Data or about our Privacy Policy, you may write to our Data Privacy Officer at Level 2, B7, Bonifacio High Street, Bonifacio Global City, Taguig City, Philippines, or contact +632 8580706 or email DPO@ph.zalora.com.