The People’s Republic of China Addendum

The People’s Republic of China Addendum (this “Addendum”)

1. Application

River Square Company Limited ( “RSCL”, “we”, “us”, or “our”) is part of the New World group of companies including New World Development Company Limited and its affiliated or related companies from time to time (as listed here: https://www.nwd.com.hk/pics) (“NWG”) and is committed to protecting personal data of individuals in territories where we do business.

If you are:

(i) an individual located in Mainland China who visits or uses RSCL’s relevant website(s) or mobile application(s) of RSCL, or otherwise uses RSCL’s products and/or services by phone or any other means from Mainland China; and/or

(ii) an individual holding a Mainland China passport and/or resident identity card who uses RSCL’s products and/or services by phone or any other means in Hong Kong,

your personal data will be processed by RSCL in accordance with this Addendum in addition to the New World Group Privacy Policy Statement (“NWG’s Privacy Policy Statement”), RSCL’s Privacy Policy Statement (“Privacy Policy Statement”) and RSCL’s Personal Information Collection Statement (“PICS”), as well as the applicable data protection laws and regulations in Mainland China.

Therefore, before using RSCL’s products and/or services or providing any personal data to us, please ensure that you have carefully read, understood and agree to the PICS, the Privacy Policy Statement, the NWG’s Privacy Policy Statement and this Addendum.

For the purpose of this Addendum, “Mainland China” refers to the People’s Republic of China excluding the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the Macau Special Administrative Region of the People’s Republic of China and Taiwan. Unless defined otherwise, all defined terms (capitalised terms) in this Addendum shall have the same meaning as the defined terms in the Privacy Policy Statement, the NWG’s Privacy Policy Statement and the PICS.

In the event of any conflict or inconsistency, they shall be resolved in the following order of precedence (from higher to lower) in respect of such conflict or inconsistency: - (a) this Addendum; (b) the PICS; (c) the Privacy Policy Statement; (d) the NWG’s Privacy Policy Statement.

2. Personal data

In this Addendum, “personal data” refers to various information related to an identified or identifiable natural person recorded electronically or by other means and does not include anonymized information. Personal data involved in this Addendum includes those set out in Clause 5 of the NWG’s Privacy Policy Statement.

In addition, “sensitive personal data” refers to “personal data” that, once leaked or illegally used, may easily lead to violation of the personal dignity of a natural person or harm of personal or property safety. The “sensitive personal data” involved in the NWG’s Privacy Policy Statement, Privacy Policy Statement and this Addendum includes residential address, marital status, Log Files, Tracking Data, transaction information (including your characteristics and transaction behavior).

“Process” or “processing” of “personal data” includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of “personal data”.

3. How we collect and process your personal data

Apart from Clauses 5 and 6 of the NWG’s Privacy Policy Statement, the following also applies to how we collect and process your personal data:

Your personal data will be processed by RSCL for the purposes as further specified below and set out in the relevant PICS (“Purposes”). In particular, for us to carry out the Purposes and provide you with the relevant products/services, the personal data (including sensitive personal data) set out below is necessary. If such information are not available or not accurate, we may not be able to provide the relevant products/services to you:

No.

Purposes

Personal data we may collect

Identifying and verifying your identity and/or as a member

Name
Membership number
User name and password
E-mail address

Registering you as a user of the Application and/or the Website (as the case may be)

Name
Contact details/ number
E-mail address
Mailing/correspondence address

To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Application and/or the Website (as the case may be)

Log Files
Tracking Data

Log Files
Membership number

Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour (subject to your consent for direct marketing, if/where applicable) to provide other goods and/or services better tailored to your needs, and to assist us in selecting Marketing Subjects (see below) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining

Tracking Data
Occupation

For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website of, or by text message, email and/or mail, and/or other media whether now known or available in the future)

Name
Contact number
E-mail address
Membership number

Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website of, or by text message, email and/or mail, and/or other media whether now known or available in the future)

Name
Contact details/ number
E-mail address
Mailing/correspondence address
Interests and favourite activities

Improving the Application, the Website, the Purposes, and our and our Affiliates’ and Marketing Partners’ Goods and Services

Tracking Data

Direct marketing and cross-marketing for the Marketing Subjects, subject to consent

E-mail address
Contact number
Mailing/ correspondence address
Tracking Data

10.

Data analytics, profiling, information management and database administration

Tracking Data
Occupation

11.

Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal subject to the applicable laws and regulations in the Mainland China

Name
Contact details

12.

Collection or recovery of any debt owed by you to us or our Affiliates

Name
Contact details

13.

The normal management, operation, and maintenance of the Application, the Website and the provision of the Goods and Services to you

Name
Contact details
Mailing/correspondence address
Membership number
Contact number
User name and password

14.

Storing your personal data (whether by a single or multiple Affiliates (including us) or our Marketing Partners) for the purpose of sharing such personal data with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above

Name
Contact details
E-mail address
Mailing/correspondence address
Membership number
Contact number
Tracking data

15.

Other purposes ancillary or related to the above

Name
Contact details
E-mail address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Occupation

In general, we process your personal data with your consent, and where appropriate, with separate consent from you for processing your personal data under specific circumstances required by the applicable data protection laws and regulations in Mainland China. You acknowledge and agree that under the following situations, we are not required to obtain your consent to process your personal data:

(i) the processing is necessary for the conclusion or performance of a contract to which you are a party, or where it is necessary to conduct human resources management according to lawfully formulated labour rules and lawfully concluded collective contracts;

(ii) the processing is necessary for the performance of our duties or obligations under any applicable laws and regulations, including those directly related to:

a) National security and national defence;

b) Criminal investigation, prosecution and trial and execution of court orders, judgments or related matters; or

c) Public security, public health, or major public interest;

(iii) the processing is necessary for responding to public health emergencies, or for the protection of life, health and property safety of natural persons under emergency circumstances;

(iv) the personal data is processed within a reasonable scope to conduct news reporting, supervision by public opinion and other activities in the public interest;

(v) the personal data is made available to the public by you or the personal data about you from legitimate public sources is processed within a reasonable scope in accordance with the laws and regulations; or

(vi) other circumstances as provided by the laws and regulations.

4. Your rights as the personal data subject

Please refer to Clause 15 of the NWG’s Privacy Policy Statement and the PICS in relation to your rights to access, correct your personal data and withdraw your consent. Further, in accordance with the applicable data protection laws and regulations in Mainland China, we will ensure that you may exercise the following rights over your personal data, including:

You may request to delete your personal data if:

（1）

（2）

our processing of your personal data breaches laws or regulations;

we collect or use your personal data without your consent;

（3）

our processing of your personal data breaches our agreement with you;

（4）

you no longer use our products and/ or services, or the purposes described in Clause 3 of this Addendum have been achieved or accomplished;

（5）

you withdraw your consent;

（6）

we no longer provide products and/or services to you;

Change the scope of your consent;

Obtain a copy of your personal data; or

Request to transfer your personal data to another personal data processor provided that such request is compliant with the applicable laws and regulations.

Such requests shall be made to our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or privacy@riverchain.com (marked Confidential, and with the name of River Square Company Limited). We will endeavour to reply to your reasonable requests in relation to the above within fifteen (15) PRC working days from the day we receive your request.

However, please note we may refuse your requests under the following circumstances:

Circumstances relevant to the fulfilment of our obligations under laws and regulations, including our provision of your personal data (including your sensitive personal data) generated during the transaction between you and us to the regulatory authority(ies) and or other governmental departments under the laws and regulations of Mainland China;

The data retention period required by any law or administrative regulation has not expired, or it is difficult to delete personal data technically (in such cases, we will take necessary security protection measures to ensure the security of your personal data or anonymize such personal data);

Circumstances directly related to national security and defence security;

Circumstances directly related to public security, public health, or significant public interest;

Circumstances directly related to criminal investigation, prosecution and trial, and execution of court decision;

Circumstances where we have sufficient evidence to prove that you have subjective malice, or you are abusing your rights;

Circumstances where protection of your or other individual’s life, property and other important lawful rights is involved;

Circumstances where responding to your request will cause serious harm to the lawful rights and interests of you or other individuals or organisations (including us); or

Circumstances where trade secrets are involved.

5. Retention of personal data

Your personal data will be kept by us for no longer than necessary for the fulfillment of the Purposes. Please refer to Clause 8 of the NWG’s Privacy Policy Statement for further details.

6. How we entrust others to process, share, transfer and publicly disclose your personal data

To achieve the Purposes under Clause 3 of this Addendum, you understand and agree that we may entrust the processing of your personal data (including sensitive personal data) to third party service providers as set out in Clauses 9 and 11 in the NWG’s Privacy Policy Statement.

The third party service providers entrusted by us have no authority to use your personal data for any other purposes. If there is any change to the purpose of processing of your personal data, we will ask for your consent again.

Your personal data may also be shared with the New World Group and joint venture companies together referred to as “Affiliates” and our “Marketing Partners” located within or outside Hong Kong, which include property developers, banks, financial and investment institutions, insurance companies, private clubs, concierge and customer service providers, retail outlets and online businesses (products and services including fashion and beauty, health and personal cares, luxury, home and living, food, wine, and beverage, books and stationery), shopping malls, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, catering service providers, healthcare and senior care, services and/or products providers including health and wellness, art and culture, gallery and exhibition, green and nature, sport and recreation, travel and accommodation, leisure and entertainment, transportation and logistics, telecommunication, media and information technology, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, pre-school, primary, secondary and/or tertiary education institutions etc., the details of which are set out in Index 1 of this Addendum.

7. How we store and transfer your personal data

In principle, we collect, produce and process the personal information in the PRC in accordance with the business purposes set out in Clause 3 of this Addendum and they will be stored in the Hong Kong. You understand, authorise and consent that we may transfer your personal information outside Mainland China to our headquarters in Hong Kong, Affiliates, Marketing Partners and other entities outside Mainland China (please refer to Index 2 of this Addendum for further details), and to the servers and/or data centres in Hong Kong of our partners, co-operators, agents, contractors, suppliers and service providers whom we have entrusted to process your personal information (please refer to Index 3 of this Addendum for further details), due to business needs and solely for achieving the business purposes set out in Clause 3 of this Addendum and to the maximum extent permitted by law and in accordance with the mandatory requirements under the laws and regulations of the PRC. The Mainland China and Hong Kong have enacted personal information protection laws, and we will also ensure that your personal information is adequately protected in accordance with this Addendum. If you would like to learn more about the storage and cross-border transfer of your personal information, withdraw your consent and/or exercise your other rights in accordance with Clause 4 of this Addendum, please contact us via the means set out in Clause 10 of this Addendum and we will respond to your request to a reasonable extent.

We will not transfer your personal data to any company, organisation or individual outside of RSCL, its Affiliates and/or Marketing Partners, except under the following circumstances:

（1）

Transfer with separate consent. After obtaining your separate consent, we will transfer your personal data to other parties in accordance with this Addendum;

（2）

When we are involved in any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer or purchase of RSCL’s business (please refer to Clause 18 of the NWG’s Privacy Policy Statement);

（3）

We may otherwise transfer your personal data in accordance with applicable laws and regulations, requirements under legal proceedings, compulsory administrative or judicial requirements.

8. How we process minors’ personal data

Our products and services are only provided to those who are above the age of eighteen (18). If we are aware that we have collected personal data of any individuals below the age of eighteen (18), we will immediately delete such personal data.

9. Miscellaneous

Further, the following Clauses in the NWG’s Privacy Policy Statement shall apply:

Clause 4 shall apply in respect of the use of cookies and other tracking mechanisms;

Clause 12 shall apply in respect of the security of personal data;

Clause 13 shall apply in respect of circumstances where RSCL excludes liability for disclosure of your personal data, which will be subject to the applicable laws and regulations in Mainland China;

Clause 17 shall apply in respect of the update of the NWG’s Privacy Policy Statement, the Privacy Policy Statement and this Addendum.

10. How to contact us

If you have any questions, comments or suggestions regarding this Addendum, or wish to exercise your rights over your personal data in accordance with the NWG’s Privacy Policy Statement, the Privacy Policy Statement or this Addendum, please feel free to contact our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or privacy@riverchain.com (marked Confidential, and with the name of River Square Company Limited).

11. Inconsistency or conflict

If there is any inconsistency or conflict between the English and Chinese versions of this Addendum, the English version shall prevail.

-End-

By River Square Company Limited,

Version 1: 31 May 2023

Index 1

Name of recipient

Purpose of sharing

Manner of sharing

Types of personal information being shared

Contact particulars

New World Development Company Limited

Provide solution development service

Generating the reports of the database

Name
Contact details
Email address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Interests and favourite activities
Occupation

privacy@nwd.com.hk

New World Corporate Services Company Limited

Provide solution development service

Generating the reports of the database

Name
Contact details
Email address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Interests and favourite activities
Occupation

tdshelpdesk@nwcs.com.hk

Index 2

Name of recipient

Purpose of sharing

Manner of sharing

Types of personal information being shared

Contact particulars

New World Development Company Limited

Provide solution development service

Generating the reports of the database

Name
Contact details
Email address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Interests and favourite activities
Occupation

privacy@nwd.com.hk

New World Corporate Services Company Limited

Provide solution development service

Generating the reports of the database

Name
Contact details
Email address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Interests and favourite activities
Occupation

tdshelpdesk@nwcs.com.hk

Index 3

Name of recipient

Purpose of processing

Manner of processing

Types of personal information being processed

Contact particulars

New World Development Company Limited

Provide solution development service

Generating the reports of the database

Name
Contact details
Email address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Interests and favourite activities
Occupation

privacy@nwd.com.hk

New World Corporate Services Company Limited

Provide solution development service

Generating the reports of the database

Name
Contact details
Email address
Mailing/correspondence address
Membership number
User name and password
Log Files
Tracking data
Interests and favourite activities
Occupation

tdshelpdesk@nwcs.com.hk

RSCL - PRC Addendum

Version 1: 31 May 2023