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PRIVACY POLICY

General

 

Respecting and protecting our customers’ privacy are always important to Secoo Investment Holding Limited (collectively, “we” or “us”).

Concerning General Data Protection Regulation (GDPR) has come into effect across the European Union on 25 May, 2018, we have taken the opportunity to make the required updates in order to safeguard the privacy of our customers and users whilst continuously improve our retail experience to all of them.

This Privacy Policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.

Throughout this Privacy Policy, the term "personal data" means any data relating directly or indirectly to you, from which it is practicable for your identity to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.

By visiting our website or mobile view owned by us www.secoo.net (collectively, our “Site”) or providing us with your personal data via other means (including via our physical campaigns or telephone enquiries number, or via your application for or use of our services, such as our Privilege Cards or Private Sales), you agree that we will collect, use and store your personal data in accordance with this Privacy Policy, as amended from time to time. This Privacy Policy is incorporated into and forms part of our Terms of Service.

If you would like more information about this Privacy Policy, you can contact us at any time at privacy@secoo.com.

 

What Personal Data Do We Collect?

 

We collect, use and store your personal data to ensure we can provide various services to you and offer you a personal online experience. This may occur when you navigate to our web(www.secoo.net) or mobile view, or by transacting , by registering an account and otherwise interacting with us ( such as by email, telephone, social media , instant chart) .

Under the law, we have a vaid legal basis to process your data and the personal information we collect includes the following:

  • Personal information including payment related information you give us when you register or purchase through the site or mobile app;
  • Content that you generate when interacting with our customer services team including details we require to contact you and verify your identity;
  • Content we generate via machine learning algorithms as they apply to personalising your experience by curating more specifically the items you have an interest in, as well as supporting general service optimisation including bid / markdown automation;
  • Other content that you generate through browsing activity including intended purchases, your marketing preferences, completion of surveys, wishlists, and participation in promotional activity; and
  • Device identifiers such as IP addresses, cookie IDs, IDFAs and other device identifiers, as well as geo location information, IoT technologies and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your browsing history, hashed email addresses, and your web log information.
 
How Do We Use The Personal Data We Collect?

 

We collect and process personal data from customers such as browsing behaviour, purchase data in order to optimise and personalise your retail experience with Secoo.net. Below are the outline of the main purposes:

  • When you purchase a product from our website, we ask you for the personal data necessary to allow us to fulfil our contract with you including taking payment, any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return.
  • When you visit our website, we will collect the minimum personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag.
  • When you visit our website, we will use some data about your use of the website to help us improve the website and our promotion of the website. This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • We also collect data about your use of our website by using cookies.
  • When you register on our website, we will collect the data necessary to ensure that we can recognise you on return visits and provide you with the services registration offers, such as creating a Wish List. If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.
  • When you sign up for our marketing communications and personalised offer, we will ask you for your email address. If you would prefer not to receive these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Service team.
  • If you have purchased from our website, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. This contact will normally be via email, but in certain circumstances we may contact you via other methods e.g. we may call you if an item we know you have been eager to purchase comes back into stock. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email or update your contact preferences on our website by contacting our Customer Service team.
  • We analyse contact data, purchase history, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences. For example, if you have been browsing or have previously purchased a particular shoe designer, we may send you an email to tell you that these are now on sale or display similar products to you as part of our internet advertising.
  • When you contact our customer service team, we will use the personal data you provide and that we have collected to respond to your requests for help or information.
  • When you use the App version of our website, we will collect data regarding your use of the App and your IP address, in order to send you push notifications about products and services that we believe may be of interest to you.
  • We will use the contact information that you provide to deliver service messages such as any change to our Terms and Conditions or Privacy Policy, delivery updates or other non-marketing communications.
     
What Are Your Rights?

 

  • You have certain rights for the access, modifications and deletion of your personal information.
  • You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us using your data until it has been corrected. We want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate.
  • If you have given us your consent to use your personal data for marketing, you have the right to withdraw your consent at any time.
  • You have the right at any time to oppose our processing of your personal data on the basis of our legitimate interest. You will need to explain the reasons behind your request and allow us to consider your request and respond.
  • You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate it will be our responsibility to promptly cease processing and to delete your personal data.
  • You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, we can transfer your data directly to a third party indicated by you.
  • You have the right to withdraw your consent at any time by unsubscribing at the bottom of each email received from us.

To exercise any of these rights, please contact us at privacy@secoo.com. Please note that we will require you to verify your identity before responding to any request to exercise your rights and that can include asking a set of security question to ensure it is you.

 

Who Will Process Your Data?

 

We are the data controller of your personal data and is repsonsible for the use in accordance with the law applied with. To provide the Website and our services, we work with a number of carefully selected third parties. We use third party platforms to manage and deliver customer relationship management (CRM); email marketing campaigns; online advertising, customer analytics, events; booking of appointments, fulfilment of orders, delivery, returns, refunds, IT services; etc. In providing the services, your personal information will, where applicable, be used by the service provider on our behalf.

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal information.

 

How Long Do We Keep Your Data?

 

We keep your personal data provided to us for as long as you have your account with us, and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.

When you provide us with personal data in order to use the services from us, such as marketing communications, we will retain your personal data for this purpose. After your termination of the use of our service, we may store your information in an aggregated and anonymised format.

 

Security

 

We protect the personal data that you provide to us by reasonable physical, electronic and managerial measures. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times.

To protect your personal data while you are on our Site, we will encrypt any personal data you transmit to us via our Site using Secure Socket Layer (SSL) — an industry standard for encryption over the Internet.

Furthermore, we undertake to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of processing.

Please note that if your age is under 18, you must inform your parent or guardian about our privacy policy to obtain their agreement to the privacy policy before registering, subscribing or placing an order with us.

 

Updates

 

This Privacy Policy was last updated on 25 May, 2018.

We regularly review this Privacy Policy. Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates and changes to this Privacy Policy.

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