PRIVACY POLICY

LAST UPDATED – March 2024

PVH Asia Limited (“Tommy Hilfiger”) is committed to respecting the privacy rights of our customers and all visitors to our web sites, web pages, interactive features, applications, blogs, social networks, and other online or wireless offerings, that post a link to this Privacy, Security and Cookies Policy (“Privacy Policy”). This Privacy Policy applies to the information gathered through the use of hk.tommy.com (the “Website”), and any other websites or mobile applications that we own and control and that link to this Privacy Policy. We are not responsible for the processing of your Personal Data through applications from third parties we offer to you. This Privacy Policy also applies to in-store activities, such as purchases and Wi-Fi use, as well as marketing activities.

On the Website you will find a number of links to other websites. Although these websites are selected with care, we are not responsible for the processing of your Personal Data (as defined below) through these websites. Our General Terms and Conditions of use and sale and this Privacy Policy are therefore not applicable to the use of such websites. This Privacy Policy may be changed over time without any prior notice: users of the Website are advised to regularly review this Privacy Policy for possible changes. This Privacy Policy was last modified as of the date stated above. Your continued use of the Website constitutes your acknowledgement and acceptance of such changes. 

What You Will Find in this Privacy Policy: 

• Who We Are
• What Data We Might Collect About You
• How We May Use Your Personal Data
• How Is Your Information Shared
• Cookies On This Site
• What Choices Can You Make About Your Data
• How Do We Protect Your Data
• Contact Information

1. WHO WE ARE

• In this Privacy Policy, "we", "our" and "us" refers to PVH Asia Limited, together with our parent and affiliates including but not limited to, Tommy Hilfiger, Inc., and "you" refers to the users of the Website, users of other websites or mobile applications that we own and control and that link to this Privacy Policy and customers and prospective customers who are subjects of in-store activities or any marketing activities.
• We use and process your Personal Data (as defined below) in accordance with the provisions of this Privacy Policy, the Personal Data (Privacy) Ordinance ("PDPO") in the Hong Kong SAR, the Personal Data Protection Act 2012 (No. 26 of 2012) in Singapore, Law 8/2005 – Personal Data Protection Act in Macau, the Personal Data Protection Act 2015 in Taiwan, the Personal Data Protection Act 2010 in Malaysia or other applicable laws (“Applicable Laws”). Your use of the Website indicates your acceptance of the current version of this Privacy Policy, which may be amended from time to time. You can determine when this Privacy Policy was last revised by referring to the "Last Updated" legend at the top of this page. If you do not agree with the terms of the revised Policy you should terminate your use of the Website.

2. WHAT PERSONAL DATA WE MIGHT COLLECT ABOUT YOU

When you visit our Website, we collect and process information, including your personal data (the Personal Data) that you knowingly disclose to us.

Information that you provide

• Identifiers: such as your name, postal address, email address, social media handle, telephone number, and identification materials used to verify your eligibility for discounts and other offers; 
• Demographic information: such as your age, date of birth, and gender; 
• Transaction information: such as information regarding purchases, returns or exchanges; product reviews you provide; clothing size/fit information; and communications between us; 
• Payment information, including gift card information; and 
• User generated content (UGC): such as photos, videos, blog posts, or social media posts. 

If you choose not to provide certain information to us, in certain cases, you may not be able to complete a purchase, participate in an experience, or receive other services or information. 

Information that we automatically collect from you 

When you visit any of our websites, applications, or stores, or access our in-store Wi-Fi, we may automatically collect: 

• Identifiers: such as device ID, IP address, and online identifiers, such as cookie numbers (for more information see section 5. Cookies On This Site)
• Internet activity information: such as device type; browser types and version; browsing history; search history; interactions with our websites, applications, communications, and advertisements; referring sites; network activities when using our Wi-Fi; and content and pages viewed; 
• Location information: such as geo-location of your devices and in-store location; 
• Audiovisual information: such as call recordings and CCTV; and 
• Inferences: such as your preferences and interests based on your online activities. 

Other information we collect

We may collect information about you from activities related to other Tommy Hilfiger businesses or third parties like web hosting providers, shipping providers, retail partners, analytics companies, social media platforms, data companies, and marketing and advertising services such as: 

• Identifiers: such as updated contact information, social media handles, device identifiers, cookie numbers or similar online identifiers; 
• Demographic information: such as your age, date or birth, or gender; 
• Internet activity information: such as content or reviews you post on social media or other third-party platforms; and 
• Inferences: such as information about your shopping preferences and interests. 

The information that we obtain from social media platforms depends on your account and privacy settings within the platforms and the platforms’ privacy policies. 

Some of the information above is collected on our websites through web browser cookies and other technologies (web beacons/gifs, pixels, page tags, script) that receive and store certain types of information whenever you interact with us or third parties that may direct you to our websites. We may use similar technologies to collect information when you use our applications. We use these tools for a variety of reasons, including to analyze and improve our websites and applications, or to remember your preferences and provide more personalized advertising. For more information, see the cookies section below.

Third party automated information collection and Interest-Based Advertising

We uses third party advertising companies to display ads tailored to you based on how you browse and shop online, a practice commonly referred to as “interest-based” or “behavioral” advertising. We allow these third parties to collect certain information when you visit our websites or use our applications, including non-personally identifiable information (browser type, subject of advertisements clicks on, session IDs) and personal data (such as static IP address). These third parties typically use cookies or tracking technologies to collect this information on websites and applications owned by us or third parties. 

3. HOW WE USE YOUR INFORMATION

We may use the information we collect for a variety of purposes, including: 

• To process your transactions and provide you with the products and services you request
• To provide, maintain, protect, develop, and improve our websites, applications and services
• To improve your experience on our websites and applications, and in our stores
• For customer service, including to respond to your inquiries and requests
• To communicate with you about our and third-party products and services (our marketing subjects), in accordance with applicable laws and with your consent where required 
• To analyze and learn about consumer trends and interests
• To learn about the devices you use to access our websites, applications and other online services
• To personalize the content you see on our websites and applications
• To administer contests, sweepstakes, surveys and other promotions
• To maintain your reward or loyalty program memberships
• To provide you with communications, recommendations, ads, and other information of interest to you, including via email, SMS and interest-based advertising based on your online activities on our websites, applications and other online services. 
• To maintain our community programs and focus groups
• To use your UGC on our websites, social media accounts, and other marketing platforms (with your consent)
• To verify eligibility for discounts and other offers
• To prevent and detect fraud, criminal activity and violations of our terms of use
• To protect our rights, as well as yours and others
• To comply with our legal obligations

We retain your Personal Data for as long as you wish to receive information from us. You can decide not to receive communications or updates from us at any time by contacting us or by using the unsubscribe option included in each communication forms. 

4. HOW IS YOUR INFORMATION SHARED

Tommy Hilfiger utilizes shared services and technology infrastructure of Tommy Hilfiger. This data may be used for data analytics, customer service and other operational purposes. We do not allow your Personal Data to be used for cross-brand marketing by Tommy Hilfiger’s other branded businesses or in any other way that violates our Privacy Policy. 

We may share your information with our third party service providers that work on our behalf, including by providing or fulfilling the products and services you request, authorizing and processing your payments, performing fraud protection and credit risk reduction, product customization, marketing and promotional material distribution, loyalty program, website and application evaluation, data analysis, website improvements, and, where applicable, data cleansing, marketing, promotions and other services performed on our behalf or on behalf of our parent or affiliates.

In addition, we may share or transfer information about you to unrelated third parties:

• When you engage in activities that are sponsored by third parties (e.g., cobranded offerings); 
• As required by law or a legal process, including investigating a potential crime;
• When we believe it is necessary to protect the rights, property, or safety of Tommy Hilfiger or other persons.

We disclose the following categories of information for our business purposes:

• Identifiers: disclosed to service providers; payment processors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
• Demographic information: disclosed to service providers; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
• Transaction information: disclosed to service providers; payment processors; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners. 
• In some locations, we also use third parties for solvency checks. We will keep information received from such third parties for as long as necessary to support our provision of services to you. Please check our payment section in our orders terms and conditions by clicking here for more details.
• Payment information: disclosed to service providers; payment processors; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; and retail partners.
• Internet activity information: disclosed to service providers; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
• User generated content (UGC): disclosed to service providers; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
• Location information: disclosed to service providers; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.
• Audiovisual information: disclosed to service providers; affiliates and subsidiaries; law enforcement, public and government authorities, and others; and advisors and consultants.
• Inferences: disclosed to service providers; advertising and marketing partners; affiliates and subsidiaries; law enforcement, public and government authorities, and others; advisors and consultants; retail partners; and joint marketing partners.

At Tommy Hilfiger, we do not share your personal data with third parties in exchange for money. We do share certain information with advertising and marketing partners in exchange for insights, digital advertising, and other valuable services. We disclose the following information in such circumstances:

• Identifiers;
• Internet activity information;
• Location information;
• Demographics;
• Inferences; and
• Transaction information.

We may also share your data in the event of an actual or potential sale, merger, acquisition or transfer of our business or assets. We may transfer Personal Data to an affiliate or third party as part of a transfer of business assets through a merger or acquisition.

We may use or share information that does not reasonably identify you with any third party and for any purpose.

To facilitate the purposes set out in this Section 4, we may transfer, disclose, grant access to or share your Personal Data with the third parties set out in this Section 4 and you acknowledge that those parties may be based outside the Hong Kong SAR, Singapore, Malaysia, Macau or Taiwan and your home location and that your Personal Data may be transferred to places where the data protection laws are substantially different to the Applicable Laws. We will ensure that the personal data transferred continue to receive an adequate level of protection that is at least comparable to that provided under the Applicable Laws where the personal data came from. 

5. COOKIES ON THIS SITE

The Website uses cookies. Cookies are small pieces of data sent by the Website and they are stored by your browser on your computer's hard drive so that we are able to recognize your browser when you return on the Website. Cookies can collect data on the use of the Website such as which pages are visited and the duration of a user session. When you use the Website, the cookie sends data to us. On our Website we use strictly necessary cookies, performance cookies, functionality cookies, advertising cookies, first party cookies, third party cookies, persistent cookies and session cookies.

Strictly necessary cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like shopping baskets or e-billing, cannot be provided.

Performance cookies collect anonymous information about how you use the Website and the pages that you have visited, for instance which pages you go to most often, and if you get error messages from web pages. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. This information is only used to improve how our Website works.

Functionality cookies remember your selection and choices to improve your experience in our Website. For instance, the cookies enable you to place products in your shopping cart and review the contents of your shopping cart. These cookies allow us to remember choices you make (such as your user name, language or the location you are in) and provide enhanced, more personal features. For instance, we may be able to recognize if the you already signed up for our newsletter or if the user is seeing a certain page for the first time. The information these cookies collect is aggregated and therefore anonymous and they cannot track your browsing activity on other websites.

Advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the Website operator's permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

First party cookies allow us to understand who has visited which page(s), to determine how frequently particular pages are visited and to determine the most popular areas of the site and to monitor the usage of the Website.

Third party cookies are used for analyzing traffic sources and visitor behavior as well as for controlling access and site features across the Website.

Session cookies are used to store information about your page activities so you can easily pick up where you left off on the server's pages. When you close the internet browser, the session is ended and the cookie is deleted.

Persistent cookies are employed to store your preferences and to recognize you at a subsequent visit.

Not strictly necessary cookies: Only if you have given prior consent, we place cookies that are not strictly necessary for providing the functionalities of the Website. Through such non-strictly necessary cookies we collect information about your use of the Website and remember your preferences. Examples of collected information are pages visited and the length of a user session. Through these cookies we aim to improve your user experience of our Website. If you do not consent to these cookies being placed on your browser, these cookies will be blocked.

Most web browsers automatically accept cookies and allow some control of most cookies through the browser settings, though you do not have to. We do not control the use of cookies by third parties other than the agents who provide the web analytics service for the Website. If you wish to disable cookies then you can do so by re-adjusting your browser settings. Please note that if you disable all or some of the cookies you may not be able to register with or use all features of our Website.

For more information on cookies and how to disable them generally please contact your helpdesk administrator or contact your web browsers support. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.cookies.org or www.allaboutcookies.org

Our Website uses Google Analytics, which is a web analysis service that is offered by Google Inc. (Google). Google Analytics uses cookies to analyze the usage of the Website by users. Google uses aggregated statistical data to give us an insight in the way you use the Website. Google may only provide these data to third parties if Google is required to do so by law, or to the extent third parties processing these data on behalf of Google. You can find more information on Google Analytics here.

6. WHAT CHOICES CAN YOU MAKE ABOUT YOUR PERSONAL DATA

Unsubscribe/Opt-Out

If you no longer wish to receive promotional emails or direct mail from Tommy Hilfiger, you can contact Customer Service (see below “How Do You Contact Tommy Hilfiger”). A request to opt-out will be handle as promptly as possible. If you have a Loyalty account with us, you may still receive communications related to your account, loyalty points or special offers (such as birthday discounts). An opt-out request will also not stop transactional emails related to your purchases.

If you no longer wish to receive the text messages that you had consented to previously, you can contact Customer Service. 

Accessing or Deleting your Data 

You may modify, correct, or update your Personal Data or request to have your Personal Data removed from our database. Upon request, we will provide you with a summary of any Personal Data collected and retained by us regarding you. We will only send copies of Personal Data to the email address on file for the visitor name associated with it. Under the Applicable Laws, we have the right to charge you a reasonable fee for processing and complying with your data access request.

If you would like to receive a copy of the Personal Data that Tommy Hilfiger has collected from or about you, you can contact Customer Service (see below “How Do You Contact Tommy Hilfiger”). You will be asked to verify your identity, including providing your name and email address.

If you would like Tommy Hilfiger to delete your Personal Data, you can contact Customer Service (see below “How Do You Contact Tommy Hilfiger”). You will be asked to verify your identity via the process outlined on the form, including providing your name and email address. [Unless you have separately opted-out from receiving communications from us, you] may continue to receive advertisements for Tommy Hilfiger regarding our products. Those advertisements may be delivered to you based on your future interactions with us or based on the determination of our business or advertising partners that you are a member of the desired audience for a campaign.

If you wish to exercise one of the above rights on behalf of someone else, you may use the channels listed above. 

Sale of Personal Data

At Tommy Hilfiger, we do not share your Personal Data directly with third parties for their own marketing purposes in exchange for monetary consideration. However, as mentioned in this Privacy Policy, we do engage in Interest-Based Advertising, where we allow third parties to place cookies, pixels, and trackers on our site to provide you with personalized ads. Please check the cookies section above for more information.

7. HOW DO WE PROTECT YOUR PERSONAL DATA

Security Methods

We use commercially reasonable technical, administrative and physical security measures to protect the information that we collect or receive, in addition to contractual safeguards. Our websites use an industry standard encryption protocol known as Secure Socket Layer (SSL) to protect your order information. Each payment transaction made through our websites and applications (or any successor or similar digital property) will be transmitted using SSL encryption. We review our security measures periodically. Despite these measures, please be aware that no security measures are perfect or impenetrable. The data you enter is automatically encrypted before it is sent. All the data is protected and only available to authorized personnel and subcontractors.

Where your Personal Data is transferred pursuant to Section 4, we take steps to ensure that the third party recipient residing outside of the Hong Kong SAR, Singapore or your home location accord your Personal Data with a standard of protection at least equivalent to the Applicable Laws and, as required, the laws of the jurisdiction where you reside. We also require that such third parties keep your Personal Data confidential.

Minors providing Personal Data

Tommy Hilfiger is concerned about the safety of children when they use the Internet. Our websites and applications are not directed to children under the age of 18. Persons below the age of 18 may only provide Personal Data to us if they have written permission of one of their parents or their legal guardian who has read this Privacy Policy. You must be 18, however to establish an account with us. If we become aware that a user is under the age of 18 and has registered an account with us without prior verifiable parental consent, we will remove their Personal Data from our files. If a parent or guardian discovers that a child under the age of 18 has provided us with Personal Data, we ask that they contact us at customerservicehk@tommy.com.

8. HOW DO YOU CONTACT TOMMY HILFIGER

If you have any questions, comments or complaints about us or how we process your Personal Data, this Privacy Policy, or in case you wish not to be contacted by us for direct marketing purposes anymore, please contact us at the email below. 

Our contact details are: customerservicehk@tommy.com. 

Appendix 1 – Additional Clauses for local markets 

MALAYSIA, MACAU SAR AND TAIWAN 

In addition to Section 4 above (How Is Your Information Shared), we will ensure that where your personal data is transferred outside of the jurisdictions in Section 4 of Appendix 1 that we will:

(a) Take all reasonable steps and due diligence to ensure that your personal data will not be processed in a manner that would contravene the Personal Data Protection Act of Macau SAR and the Personal Data Protection Act of Taiwan (hereinafter referred to as “the Laws”); 

(b) Ensure that the destination of where your personal data is transferred to offers an adequate level of protection as the original location of where your personal data was collected; According to the Macau SAR PDPA, the Macau SAR Data Protection Office shall decide whether a jurisdiction ensures an adequate level of protection.

(c) Where applicable under the Laws, obtain your consent before we transfer your personal data to a destination outside of Section 4 of Appendix 1. 

(d) Macau SAR only:

We shall comply with all requirements and formalities determined by law with respect to data privacy, including transfer of data to other jurisdictions outside Macau SAR. 

We may transfer personal data to third parties in cases where this proves to be necessary for the provision of the services you have engaged or for compliance with the obligations to which we are subject.

The transfer of data to third parties is carried out in accordance with the applicable data protection legislation and within the limits of the purposes and lawful bases established in this privacy policy.

In cases where the transfer of personal data involves an international transfer of personal data, and whenever such transfer is to a jurisdiction where the level of protection of personal data is deemed as not sufficiently adequate, we might still transfer the data in the following situations:

• When it is necessary to perform a contract between you and us;
• When it is necessary to conclude a contract, in your interest, between us and a third party;
• When it is necessary or legally required for the protection of an important public interest, or for the declaration, exercise or defense of a right in a judicial process;
• When it is necessary to protect your vital interests;
• When it is carried out from a public registry, destined for public information.

In keeping with the potential transfers set out above, by clicking the provided opt-in checkbox you give your express consent, that by providing your personal data, you expressly consent to transfer of said personal data to jurisdictions outside Macau SAR. 

In addition to Section 6 (What Choices Can You Make About Your Personal Data), you acknowledge that by clicking the provided opt-in checkbox you give your express consent for the use and treatment of your personal data, including that you have read, understood, and agreed to the matters specified in this privacy policy.

You have the right to lodge a complaint with the relevant supervisory authority about matters related to the processing of your personal data. In Macau SAR, the infringement of privacy rights can be reported to the Macau SAR Data Protection Office. To know more, visit https://www.gpdp.gov.mo/.

SINGAPORE 

Withdrawing Your Consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. 

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

The Data Protection Officer of PVH Singapore can be contacted at DPO_SG@pvh.com. 

Access to and Correction of Personal Data

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we will generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Singapore Personal Data Protection Act 2012).