Privacy Policy

Overview

Respecting and protecting the privacy and personal data of our customers is of paramount importance to our company and its related entities (including all subsidiaries and affiliated companies) (collectively referred to as "we"). This Privacy Policy will help you understand how we collect, use, and protect your personal data when interacting with you. In this Privacy Policy, the term "personal data" refers to any information directly or indirectly related to you that can be used to identify you (directly or indirectly) and is in a form that allows access or processing.

By browsing any website owned and operated by us (cigarera.cn, our "Website"), or by providing us with your personal data through other means (including calling our inquiry hotline, or applying for or using services such as member promotion activities), you confirm and agree that we will collect, use, store, and disclose your personal data in accordance with this Privacy Policy, which may be revised from time to time. This Privacy Policy is incorporated into and forms part of our Terms of Service.

We will regularly review this Privacy Policy and may revise its provisions by updating this webpage from time to time. Your continued use of our services after modifications to this Privacy Policy constitutes your acceptance of the revised Privacy Policy. Therefore, please review this webpage regularly to obtain the latest information on the Privacy Policy.

Your Personal Data and How We Use It

We collect, use, and store your personal data to ensure that we can provide you with various online services and create a personalized shopping experience. These actions may occur through our Website or other means. At all times, we will keep your personal data confidential in accordance with this Privacy Policy and will only collect, use, store, and disclose such data as specified herein.

Collecting Your Personal Data

We collect your personal data for the following purposes and uses:

• If you are not a registered user, you will browse our Website as a guest.

• When registering on our Website, you will be required to provide certain personal data (such as your name and contact information) to access the features and services available to registered users (e.g., receiving member promotional emails, responding to your inquiries, and participating in member promotion activities).

• We will only collect data necessary to fulfill relevant orders (e.g., your name, contact information, and payment/credit card details). However, if you log in using our social network features and agree to share information about your interests and social media links with us to use these features, we will also collect such information.

• You may provide us with your personal data from time to time when applying for or using our services at events hosted by our partner merchants, providing feedback (e.g., through questionnaires), or participating in promotions such as member activities.

• You may also log in to our Website using login services linked to your social network accounts. These services will verify your identity and offer you the option to share certain personal data with us (such as your name and email address) to complete pre-filled registration forms on our Website. These services also allow you to choose to post information about your activities on our Website to your personal page and share it with others in your personal network.

Using Your Personal Data

We will use the personal data you provide to us for the following purposes (and any purposes directly related thereto) (collectively referred to as the "Relevant Purposes"):

• To provide you with our services (including evaluating any applications for such services and managing them). This includes responding to any questions you may have, providing product recommendations on the Website, retaining your selected shopping cart on the Website, evaluating your applications for any of our services, issuing our member VIP cards to you, allowing you to participate in desired promotions and marketing activities, and fulfilling your orders (including verifying your data, conducting security checks, and processing your payments).

• To send you direct marketing information.

• To match your personal data with information you have provided to us through other means.

• To analyze trends, usage, and shopping behaviors (at both individual and collective levels) related to us. This helps us better understand how you and our broader customer base access and use our Website and services, enabling us to improve our services and respond to customer needs and preferences. For these purposes, we may use your gender, age, interests, location, Website usage, shopping habits, and other personal data.

Additional Notes on Your Personal Data

If you do not provide us with your personal data, we may be unable to provide you with certain services and features.

Unless otherwise required or permitted by law (to protect our interests):
(a) We will retain your personal data only for as long as necessary to achieve the Relevant Purposes;
(b) If you choose to cancel your account with us, we will delete the personal data we store about you to the extent reasonably feasible;
(c) If you choose to cancel your account or terminate the use of social network features, we will prompt third parties to delete the data they hold about you.

You may from time to time provide us with the personal data of third parties (e.g., to obtain offers we provide). You agree that, before providing a third party’s personal data to us, you have obtained their consent for us to collect, use, store, and disclose such data in accordance with this Privacy Policy.

Collecting Anonymous Data

In addition, we may collect certain other anonymous data on the Website that is insufficient to identify individuals, for the purpose of compiling statistics on Website usage:

• We automatically collect data about your access to our Website to provide our services, gather statistics on server usage, and help us better meet your needs and expectations. This may include (but is not limited to) your browser type and version, operating system, and IP address and/or domain name.

• We also use unique identifiers to track your usage of our Website across different electronic devices, ensuring that your activities are recorded under a single user profile in our system rather than multiple users.

Disclosing Your Personal Data

We strictly comply with the provisions of the Personal Data (Privacy) Ordinance (the Hong Kong Special Administrative Region’s personal information protection legislation) in handling personal data.

We will keep your personal data confidential but may disclose it to the following parties (which may be located outside the Hong Kong Special Administrative Region and may use your personal data outside the Region):

• (a) Any of our related entities (including affiliates and subsidiaries); (b) any person or company acting on our behalf or jointly with us; or (c) any service provider for features on our Website. Such disclosures are made to provide you with more information and services and enhance your user experience, provided that all parties comply with confidentiality and privacy obligations substantially equivalent to those set out in this Privacy Policy;

• Any financial institution, debit or credit card issuer, credit reference agency, or collection agency, to the extent necessary to establish and support payment facilities for the products and services you request; and

• Any other party if required by legal or contractual obligations, or as mandated by law or court order, or (where permitted by law) necessary to protect our interests.

We will not provide your personal data to any other third party unless we have obtained your explicit prior consent. We may from time to time transmit anonymous aggregated data to third parties, which may include your personal data in an anonymous format that does not allow third parties to identify you (except on our Website). This Privacy Policy applies to us and this Website but not to any other third parties (including any websites maintained by third parties). Before providing your personal data to such third parties (whether through our Website or otherwise), please review their privacy policies. We are not responsible or liable for any use or misuse of your personal data by such third parties.

How to Access and Update Your Personal Data

You can access, verify, or update your personal data through your member account.

Reporting Misuse of Personal Information

If you believe that the collection, use, or disclosure of your personal information violates this Privacy Policy or any applicable law, you may contact our Privacy Officer to report the matter (see "Our Contact Information" below for details). In your report, please provide the following information (where applicable):

• Details of the alleged violation of this Privacy Policy or applicable law in the collection, use, or disclosure of personal information;

• Screenshots of the relevant webpages related to your report; and

• Your valid email address and/or contact phone number.

We may contact you to obtain additional information about your report. Thank you for helping us improve the protection of your personal information. We will respond to you within 15 days of receiving your report.

Our Contact Information

If you wish to contact us regarding this Privacy Policy (including your rights under this Policy or any other questions you may have), please contact us.