PRIVACY AND COOKIES POLICY

This is the Privacy and Cookies Policy for the website hosted at http://www.urbanrevivo.com/sg/ ("we", "us" and "our site")/the Urban Revivo app "our App" (together, the "Services").

The Services are operated by or on behalf of UR Fashion Group (Singapore) Co. Ltd. trading as Urban Revivo. We are committed to protecting and respecting your privacy and complying with applicable laws and regulations to ensure that the personal data we process about you is kept appropriately secure and processed fairly and lawfully.

This policy sets out:

Information we collect about you

Cookies and other technologies

How we use your information

Our promotional updates and communications

Who we give your information to

Where we store your information

Payment processing

How we protect your information

How long we keep your information

Your rights

Changes to this policy

Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By visiting and using our site or/and our App, you acknowledge you have read and understood this Privacy Policy. You must be at least 18 years’ old to use the site and app. If you are under 18 or a minor in your country or state or region of residence, please ask your parent or legal guardian to provide their information for you.

For the purposes of Personal Data Protection Act, (the "Data Protection Law"), the data controller is: UR Fashion Group (Singapore) Co. Ltd. of 68 Orchard Road #01-18 Plaza Singapura, Singapore.

Information we collect about you

We will collect and process the following personal data from you:

· Information you give us

This is information about you that you give us directly when you interact with us.

Find out more

This is information about you that you give us by filling in forms on our Services or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Services, subscribe to our service, search for a product, place an order on our website/via our App, participate in discussion boards or other social media functions on or via our Services, enter a competition, promotion or survey, submit a query, and when you report a problem with our Services.

The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description, login and password details, gender, date of birth, post code, delivery address, size information.

· Information we collect about you from your use of our Services:
We will automatically collect information from you each time you visit our site/use our App. This includes:

· Technical information

· Information about your visit

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• Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

• Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

· Information we receive from other sources.
This is information we receive about you:

· If you use any of the other websites or apps we operate or the other services we provide.

· From third parties we work closely with.

Find out more

In this case we will have informed you [via this policy] when we collected that data if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies and other technologies

Our Services use cookies to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Our Services use cookies and similar technologies to distinguish you from other users of our Services. This helps us to provide you with a good experience when you browse our site/use our App and also allows us to improve our Services.

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this.

A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Services and will last for longer.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

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We use cookies to create a unique device ID.

We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our website/App and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may also work with advertising networks that gather information about the content on our Services you visit and on information on other websites and services you visit. This may result in you seeing advertisements through our Services or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit https://analytics.google.com/.

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Services. If you disable all cookies, you will be unable to complete a purchase on our Services.

If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:

For Microsoft Internet Explorer:

1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting

For Google Chrome:

1. Choose Settings then Advanced
2. Under "Privacy and security," click “Site settings”.
3. Click “Cookies and site data”

For Safari:

1. Choose Preferences then Privacy
2. Click on “Remove all Website Data”

For Mozilla firefox:

1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

1. Choose the menu Files then “Preferences”
2. Privacy

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.

You can find more information about the individual cookies we use and the purposes for which we use them:

Cookie Name Purpose and lawful basis Expiry
Opt-in cookie grant This cookie is strictly necessary to store your consent and any individual cookie use choices on your device in order to determine whether you have granted your consent at your next visit to the website. Transient
Online shop cookie JSESSIONID This cookie is strictly necessary to uniquely identify the respective user within his session in the user account, i.e. until the end of the validity period of the login cookie or until the login cookie is deleted by clicking on "Logout". This cookie saves session ID of customer’s devices. Transient
Online shop cookie SHOPPINGCART This cookie is strictly necessary to provide the shopping cart function. This cookie is used to store information about the mini shopping cart, such as the identification details of the user associated with the aforementioned cart. This cookie saves IP address, type and version of your internet browser, operating system used, site accessed before visiting the site (referrer URL), date and time of the visit as well as article description, article number, quantity, size, colour, price, currency. Transient
Online shop cookies td_cookie This cookie is strictly necessary to record the user's type of browser in order to adapt the design of our website to the specifics of the relevant browser. Transient
Google Analytics cookie _ga This cookie contains a unique visitor ID and is used to distinguish different users from each other. We collect your consent to set this cookie. 2 years
Google Analytics cookie _gid This cookie is used to distinguish users from each other. We collect your consent to set this cookie 24 hours
Google Analytics cookie __utma This cookie stores the number of each visitor’s visits and the time and date of the first visit, previous visits and the current visit. We collect your consent to set this cookie 2 years
Google Analytics cookie __utmb This cookie is used to log how long each visitor stays at a website, i.e. when the visit begins and when it ends. This cookie stores the moment in time when a visitor enters a site. We collect your consent to set this cookie Transient
Google Analytics cookie __utmc This cookie is used to log how long each visitor stays at a website, i.e. when the visit begins and when it ends. This cookie stores the moment in time when a visitor leaves a site. We collect your consent to set this cookie 30 minutes
Google Analytics cookie __utmv This cookie stores the category into which the visitor fits.. We collect your consent to set this cookie 2 years
Google Analytics cookie __utmz This cookie stores the source or campaign that explains what route the user used to come to the website. We collect your consent to set this cookie 6 months

How we use your information

You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed here.

We use information held about you in the following ways:

· Information you give to us:

We will use this information to:

• Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:

o administering your account with us;

o verifying and carrying out financial transactions in relation to payments you make online/through the Services;

o notifying you about changes to our service.

• Provide you with information about our goods or services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications'.

• Ensure in our legitimate interests that:

o content from our site is presented in the most effective manner for you and for your computer.

o we provide you with the information, products and services that you request from us.

· Information we collect about you from your use of our Services

We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:

• To administer our Services and for internal operations, including but not limited to troubleshooting, data analysis, testing, research, customer service, statistical and survey purposes.

• To keep our Services safe and secure.

• For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

• To improve our Services to ensure that content is presented in the most effective manner for you and for your computer.

• To allow you to participate in interactive features of our service, when you choose to do so.

· Information we receive from other sources

We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal data for marketing analysis and to provide you with promotional update communications by email about our products.

You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to karl.li@ur.com.cn

Who we give your information to

We may share your information with:

· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy or who provide shared content and services (such as registration services, transaction processing, proposition about their products or services) that we jointly offer with other members of our worldwide group. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.

· Selected third parties.

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Our selected third parties may include:

• Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the Services in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.

• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy.

• Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual).

• Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data, a list of whom can be found here [insert link].

• Payment processing providers who provide secure payment processing services.

We will disclose your personal data to third parties:

· In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.

· If UR Fashion Group (Singapore) Co. Ltd. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property, or safety of UR Fashion Group (Singapore) Co. Ltd., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we store your information

The data that we collect from you may be transferred to, and stored at, a destination outside Singapore that may not be subject to equivalent Data Protection Law.

Where your information is transferred outside Singapore, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

Find out more

We may transfer your personal data outside Singapore:

· In order to store it.

· In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details excluding credit card details (card association, card scheme, credit card numbers, CVM codes and expired date), and the provision of support services.

· Where we are legally required to do so.

· In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

We may transfer your personal data to the following countries and using the following safeguards outsideSingapore:

• China (PRC) - Standard Contractual Clauses;

• Hong Kong - Standard Contractual Clauses;

• Thailand - Standard Contractual Clauses; and

• UK - Standard Contractual Clauses.

Payment processing

Payments made on the Services are made through:

1. our payment gateway provider, Adyen. You will be providing credit or debit card information directly to Adyen which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to Adyen is not within our control and is subject to Adyen's own privacy policy and terms and conditions.

2. our payment provider, Paypal, You will be redirecting to Paypal’s website which operates a secure server to process payment details, encrypting your paypal account information and authorising payment. Information which you supply to Paypal is not within our control and is subject to Paypal's own privacy policy and terms and conditions.

How we protect your information

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

How long we keep your information

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

· You have the right under certain circumstances:

• to be provided with a copy of your personal data held by us;

• to request the rectification or erasure of your personal data held by us;

• to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);

• to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section;

• to request that your provided personal data be moved to a third party.

· Your right to withdraw consent:

Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us [link to contact us section]. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;

You can also exercise the rights listed above at any time by contacting us at karl.li@ur.com.cn.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The Personal Data Protection Commission is the supervisory authority in the Singapore and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 29/7/2020.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

Karl Li

karl.li@ur.com.cn

Purpose and lawful basis for processing of personal data

This table sets out:

• What personal data we process

• What we use that data for

• The lawful basis for the processing

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer and confirm your identity (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To administer and protect our business and this website//app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). Where required by the Data Protection Laws, we will collect your consent for such data processing activities.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
To comply with laws and associated document retention obligations (a) Identity
(b) Contact
(c) Payment
(d) Transaction
Necessary to comply with our legal obligations
To keep records of transactions to prevent transaction disputes (a) Identity
(b) Financial
(c) Transaction
Necessary for our legitimate interests (to recover debts due to us and exercise our legal rights)
To assert, exercise or defend legal claims (a) Identity
(b) Contact
(c) Financial
(d) Transaction
Necessary for our legitimate interests (to exercise our legal rights)