Date: July 31, 2026.

This Privacy Notice aims to give you information about how we collect and process your personal data when you use the website.

This Privacy Notice covers any personal data you provide when you create an account, purchase a product or otherwise interact with us.

We want to make sure you know who we are, how you can contact us, the personal data we process, how we use it, who we share it with, how long we keep it for and the choices you have to exercise your legal rights.

It is important that you read this Privacy Notice together with any other privacy notice we may provide when we collect or process your personal data so that you are fully aware of how and why we are using your data.

In particular, please read this Privacy Notice in conjunction with our Cookies Notice link

 1.     Who Are We?  

We collectively care about your data, in this privacy notice when we mention “Vivagoods”, “we”, “us” or “our”, we are referring to all companies listed below: 

Viva Retail Company Limited - is a company registered in Hong Kong with a registered office at 23/F, Hong Kong Li-Ning Building, 218 Electric Road, Fortress Hill, Hong Kong

 2.     Introduction 

We value and respect your privacy, and, we collect personal information during our interactions with you. This policy provides information about what and how we collect plus how we use, share, and otherwise process your personal data in accordance with relevant laws and regulations. 

3.     What Types of Data Do We Collect and Why Do We Collect It? 

Category of Personal Data	Purpose for Processing
Name and contact details:	Process any orders that you make either online or in-store (if any).
(such as email address, telephone number and postal address)	Send you service messages such as order updates; items left in your basket by email or SMS (if any).
	Respond to your queries, refund and/or return requests and complaints.
	Send you information by email, post or social media about our products or services e.g. if you sign up to our newsletter when you register an account with us.
	To enable you to book fitting appointments.
	To enable us to detect and prevent fraud.
	Undertake website personalisation to develop products, services, applications.
Purchase information/history	Maintain records of your purchases with us
	Invite you to provide feedback about our products and services in the form of online, email surveys.
	We use this information to help us improve and monitor the quality of our products and services provided to you.
	Send you relevant information by email, post or social media about our new products or services
	To better understand your preferences and make decisions about what  adverts are shown to you as you browse the web （For more information, please see our list of third-party suppliers under “Who we share your personal information with, if any）
Date of birth information	Fraud prevention and detection
	To send you personalised promotions on your birthday
Payment information (we don’t store this information)	Take payment and give refunds
	Fraud prevention and detection
Contact history with Vivagoods e.g., over the phone, email or on social media.	To ensure high level of customer service
Device information: information about your computer, phone or other device you use to view the website or app such as device type, operating system, hardware version, browser type, unique device identifier, IP address and advertising ID	Improve our website and set default options for you (such as language and currency)
	Showing you Vivagoods adverts as you browse the web
Log information: information about how you use our website such as the types of content you view or engage with, the frequency and duration of your activities, access times, language, your IP address and pages you visit before or after navigating away from the website;	Fraud prevention and detection
Device and log information will not be associated with you as a named individual unless you are logged into your account or you have given consent to receive email communications from us by subscribing to our emails.	Make sure the website display and function correctly on your device (e.g. make sure pages load correctly on your device and that the displayed language and currency are correct for the country you are in)  Provide us with analytical information about the use of the website Make the website secure  Make decisions about the pages, images and adverts to display to you on our websites To better understand your preferences and make decisions about the content we send you in our marketing emails  Make decisions about the adverts you see on websites that are not owned by us  When you sign up to our emails you consent to the use of email tracking technology (pixels) through third parties to collect data such as whether an email has been delivered to you and if you have opened it. This data is only visible at an anonymous level to our teams to enable them to review and take actions based on the effectiveness of an online campaign. You can opt out of receiving emails at any time  Associate different devices you use with each other so that the pages, images and offers you see across devices are consistent.
Social media comments and photos you post on social media pages where you have mentioned and tagged us	We may want to respond to you or react, particularly if you are happy, or unhappy with something.
	It is important for us to know what you think about us and the products we provide to you.

4. Where Do We Collect Your Data From? 

• Your Account

When you register on our online store or offline Store (if any), we ask for your first and last name, email address and you will need to set a secure password to set up your account. We also allow you the option of providing additional information, including, but not limited to, your date of birth and gender. The more we know about you, the more we can personalise your site experience and tailor our specific products and promotions to meet your interests. 

The information we collect through the "My Account" feature is used to help improve our Site, customize your site experience, deliver updates or notices about our organisation, allow you to review your order history, you can chose here to “opt in” to receive direct, digital, and/or email marketing communications about our products and promotions. 

• Purchase

When you make a purchase through our online store or offline Store (if any), we ask for information such as your name, email address, billing address, telephone number, payment card information, and shipping address. This information is used to process, confirm, and ship your order.  

When shipping an order to a third party, you will need to provide their name, shipping address, telephone number, and email address. Such information is used solely to complete the order and to notify the recipient of their shipment. We will not use the personal information of a third-party recipient for marketing purposes. 

• Email Communications and your choices

If you want to get emails or text messages from us about new products or special offers, you can choose to sign up when you create an account or make a purchase

You can unsubscribe at any time. Even if you unsubscribe from marketing messages, we may still send you important emails about your account or orders.

• Surveys and Contests 

We may, on occasion, run surveys, sweepstakes, or other like contests. If you choose to participate, we may ask for your name, mailing address, email address, social media profile and/or telephone number. We use this information to administer the relevant survey or contest and for award notification purposes, as applicable.  

• Product Ratings, Feedback and Reviews 

When making a purchase(s) you will be given a link post purchase or receive an email that allows you to provide ratings and reviews about our products. To submit a review, you need to provide some personal information. We are then able to associate you with the review you are submitting, we may use information in your review to personalize your site experience or tailor our product.

• Direct Mail Communications

When you sign up as a member or make an online purchase, your mailing information is automatically added to our direct mail distribution list. If you wish to unsubscribe from our direct mail list, you may E-mail us to unsubscribe.  

We want to ensure that your user experience is tailored so that you get the most relevant information about our products and services. In order to do this, we may need to create a profile of you for marketing purposes, so we can share with you products we think you’ll enjoy.  

You do not have to provide us with any information, but without it, we cannot personalise your experience and may not be able to fulfil your online purchases.   

5.     What Legal Basis Do We Use to Process Your Personal Data?

We are keen to ensure that you trust us when sharing your personal data with us. We only collect, use, retain, and share personal information that is adequate, relevant, and reasonably necessary to fulfil the purposes for which it was collected. We do not process personal data for purposes incompatible with those disclosed initially, unless we first obtain your consent, as required by law.

We collect your personal data under the following legal bases: 

• Your Consent – e.g. You provide your consent and chose to receive or not receive marketing emails. It is your choice, and we will respect that. You can withdraw consent at any time.  

• We have a contractual obligation – e.g. You have placed an order with us.  

• We have a legal obligation – e.g., for the purposes of tax legislation and reporting. 

• We have a legitimate interest – e.g., to prevent fraud.  

 6.     Who Do We Share Your Data With?  

We share your personal data with the following categories of companies as part of being able to provide our services to you: 

• Members of our group companies, where they assist us in providing services to you. 

• Companies that help us get your order to you, such as payment service providers, warehouses operators and delivery companies. 

• Marketing service providers, such as marketing agencies and advertising partners who help us market our business. 

• Technology service providers, such as companies that support our IT, help us analyse the data we hold, send communications to our customers, and help us develop and host our websites and apps. 

• Professional advisors, such as companies that provide us with legal or financial advice. 

• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud and other unlawful activities. 

• Companies approved by you, such as social media sites. 

• Applicable third-party hosting providers for events and ticketing companies. Where your consent if provided, photographs and videos of these events may be shared on our social media and our website; and 

• If any part of our business is outsourced, sold, or merged, where permitted by law, we will share your data with the new provider so that we may continue to sell products to you and they may use your personal data in the same way as set out in this policy. We will of course inform you of any such change and give you an opportunity to opt out of your data being shared with a new provider. 

We share personal information with trusted service providers who support our operations, such as hosting, analytics, payment processing, and customer service. These providers are contractually bound to use your data only as instructed by us and solely for the purposes of providing those services.

We ensure that appropriate legal safeguards are in place to protect your information in accordance with applicable privacy laws.

If you have any questions about how your data is shared or protected, please contact us in onlineenquiries.hk@clarks.com.  

7.     How Long Do We Keep Your Data?  

We will only store your personal data for as long as is necessary and only for the purposes outlined above. Certain information such as payment details will be kept longer as this is reasonably necessary or required by law or other regulations. (To prevent fraud or resolve disputes).

8.     How to Exercise Your Rights and Lodge a Complaint 

If you have any questions or concerns about how we handle your personal information, we encourage you to contact us at onlineenquiries.hk@clarks.com.

Verification Of Consumer Requests and Data Retention of The Requests

We reserve the right to respond only to verifiable consumer requests. A verifiable consumer request is one made by:

• The consumer who is the subject of the request,

• A parent or guardian on behalf of a minor child who is the consumer, or

• A natural person who can demonstrate that they are lawfully authorized to act on behalf of the consumer.

9.     Data Retention

We will retain personal data for the time strictly necessary to provide users with the requested services or to fulfil legal or tax obligations for the minimum period prescribed by law.

In order to establish the retention period for personal data collected and stored through the Website with the User's consent, We will consider multiple factors to ensure that personal data is not stored for a period longer than is strictly necessary for the purposes for which it was collected or for compliance with legal obligations. These criteria also include:

·         the purpose for which the Website retains personal data;

·         legal, tax, and regulatory obligations;

·         the type of ongoing relationship with the Data Subject user or customer (how often the user accesses their personal account on the Website, whether the user maintains active consent to receive commercial communications, how often they browse and/or make purchases on the Website, etc.);

·         any specific requests from the Data Subject regarding the erasure of personal data.

Therefore, we shall retain:

·         personal data collected and processed in relation to the Data Subject's personal account for a maximum period of 3 years from the date of the last interaction between the Data Subject and the Website or other contact (email, customer service) with us;

·         The detailed data of each online purchase is stored for a period of up to 10 years from its last registration.

We undertake to implement procedures that ensure the timely and secure erasure or anonymization of your personal data from the moment it is no longer necessary or the grounds for its lawful retention cease to exist.

10. Links to Other Sites 

Our Site may contain links to other company websites and resources, none of which are controlled by us. We is not responsible for any non-affiliated websites, whether linked or otherwise. Those websites may have their own privacy policies and terms and conditions which will govern your access and use of their site. 

11. Consent 

By using our Sites or services, you acknowledge that you have read this Privacy Policy and understand our practices regarding your personal data. Where legally required, we will request your explicit consent. 

12. Keeping your personal information safe 

We have appropriate security measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13.  Updates to this Privacy Notice

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technologies. When we make changes, we will update the “Last Updated” date at the top of this notice and post the revised version on our website. If the changes are significant, we will provide additional notice or seek your consent as required by applicable law.

We encourage you to review this Privacy Policy periodically to remain informed about how we collect, use, and protect your personal information.

14. Applicable Law

If any dispute arises regarding any of our products or services or these Terms and Conditions that cannot be resolved in good faith, you agree that these Terms and Conditions shall be governed by the laws of Hong Kong. The courts of Hong Kong shall have exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms and Conditions or the use of this website.