eefit Membership - Privacy Policy Statement

eefit Club - Privacy Policy Statement

This Privacy Policy Statement applies to all individuals whose personal data may be handled by Yubo Technology Limited ("the Company" or "we") as a data user or processor.

This Privacy Policy Statement sets out how we collect, use, manage, and protect any personal data provided by you to us, or collected, generated and/or compiled by us from time to time in connection with your purchase of products and services (including the eefit Membership Program, the official eefit website, and the eefit mobile application) (collectively, "Personal Data").

1. Protection of Your Privacy

• We endeavor to handle your information in accordance with prescribed standards, including safeguarding your privacy and ensuring the security of your Personal Data, in particular and where applicable, in compliance with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong (the "Ordinance").

• Before using or providing your Personal Data for the purposes set out in this Privacy Policy Statement, we may be required by law to obtain your written consent. In such circumstances, we will only begin to use your Personal Data in the specified manner after directly or indirectly obtaining your consent.

2. Your Personal Data

To the maximum extent permitted by applicable law, in order to provide you with comprehensive services, products, and exclusive privileges under the Program, we may collect from you or request that you provide the following categories of personal data ("Personal Data"). If you fail to provide Personal Data marked as "mandatory," we may be unable to process your membership application, maintain your account, or provide you with the full services of the Program. The scope of Personal Data we collect includes, but is not limited to, the following:

• 2.1 Identity and Basic Contact Information: Including your full name, title, gender, date of birth, Hong Kong mobile phone number, email address, residential address, correspondence address, and delivery address.

• 2.2 Account, Membership, and Transaction Information: Including your membership account number, login password, eefit growth value, shopping credits, points balance, package purchase and redemption records, electronic coupon and promotional code records, detailed past spending records at eefit physical stores, online store, or exhibitions (including types of products/services purchased, quantities, amounts, dates, and locations), payment details (including partial credit or debit card numbers and expiry dates, e-wallet account information), billing records, and refund records.

• 2.3 Device, Technical, and Network Information: Including your Internet Protocol (IP) address, unique device identifiers (such as MAC address, IMEI, advertising identifiers), device model, operating system version, browser type and version, network configuration, time zone setting, language preference, and precise or approximate geolocation data of your device (where your device permission has been granted).

• 2.4 Behavioural, Interaction, and Usage Data: Including your clickstream data within the eefit App or website, browsing history, search queries, time spent, records of participation in promotional activities or lucky draws, reward redemption preferences, and all communications between you and our customer service team (including call recordings, emails, letters, and text conversations via messaging applications).

• 2.5 Health and Lifestyle Preference Information (Voluntarily Provided): For the purpose of providing more precise and personalized health advisory services, you may voluntarily provide us with information regarding your health condition, lifestyle habits, pain concerns, or preferences and feedback regarding specific eefit products (such as the Meridian Pro Illuminator).

• 2.6 Social Media Information: If you choose to register for or log in to the eefit App via third-party social media platforms (such as Facebook, Google, or Apple ID), we may collect your public profile information from such platforms in accordance with their respective policies.

3. How We Collect Personal Data

We primarily collect your Personal Data through the following lawful, fair, and transparent means:

• 3.1 Directly from You: When you submit a membership application, update account information, complete a purchase, buy a package, participate in promotional activities, complete surveys, or contact our customer service team through the eefit App, website, physical stores, or exhibitions, we will directly collect the information you input or provide.

• 3.2 Automatic Collection (Passive Collection): When you browse our website or use the eefit App, our servers and third-party analytics tools (such as Google Analytics) automatically record your technical information, clickstream data, and app usage behavior through cookies, web beacons, pixel tags, and similar tracking technologies. These technologies help us record login status, analyze traffic, and optimize user experience. You may refuse cookies by adjusting your device or browser settings; however, this may cause certain functions to operate improperly.

• 3.3 From Third Parties: To the extent permitted by applicable law, we may receive supplementary information about you from authorized business partners, affiliate marketing partners, payment gateway service providers, anti-fraud agencies, or publicly available sources to verify your identity or enhance our database.

4. Personal Data Collection Statement

As the Personal Information Collection Statement of the Program, we hereby declare that the Personal Data collected will be strictly used for the following lawful and operational purposes and will be subject to the following important disclosure and promotional provisions:

• 4.1 Purposes of Collection and Use of Personal Data
We intend to use your Personal Data for (including but not limited to) the following purposes:

- Processing, approving, and evaluating your membership application, and performing daily account administration and operations;

- Calculating, issuing, managing, and deducting eefit growth value, shopping credits, packages, electronic coupons, and other membership rewards;

- Processing your orders and payment instructions, arranging logistics delivery, in-store pickup services, and handling refund requests;

- Verifying your identity and assessing your eligibility for specific discounts, upgrade privileges, or participation in exclusive events (such as health check events or luncheon seminars);

- Providing customer support and handling and following up on your inquiries, suggestions, complaints, or technical support requests;

- Sending service-related communications regarding account status, amendments to terms, system maintenance, and administrative notices;

- Conducting big data analysis, internal market research, behavioral statistics, and business planning to optimize the interface design of the eefit App, improve our products and services, and assist in the development of next-generation products;

- Displaying tailored product recommendations, content, and advertisements based on your spending habits and preferences;

- Monitoring, detecting, investigating, and preventing fraudulent activities, abuse of return mechanisms for points gain, cyberattacks, money laundering, or other potential illegal activities or violations of Program terms;

- Enforcing any contracts between you and us (including the Program Terms and Conditions) and recovering any outstanding amounts;

- Complying with any applicable legal, regulatory, court order, law enforcement, governmental, or regulatory disclosure requirements binding on the Company.

• 4.2 Disclosure and Transfer of Personal Data
We will keep your Personal Data strictly confidential. However, where absolutely necessary for the purposes set out in Section 4.1 above, we may disclose, transfer, or share your Personal Data with the following parties (whether within or outside Hong Kong):

- Yubo Technology Limited or relevant entities within our corporate group;

- Third-party service providers, contractors, or agents who provide us with administrative, cloud storage, data center, telecommunications, computer system maintenance, payment gateway processing, logistics delivery, data processing, telemarketing, data analytics, marketing, customer service, or other business operational services. Such providers are subject to strict confidentiality obligations and are authorized to process data only to the extent necessary to provide services to us;

- Persons under a duty of confidentiality to the Company, including our auditors, accountants, legal advisers, and other professional advisers;

- Relevant authorities to whom we are required to disclose information pursuant to applicable laws, regulations, court subpoenas, or requests from governmental or law enforcement authorities;

- In the event of merger, acquisition, asset sale, restructuring, or liquidation involving the Company, your Personal Data may be transferred as part of the business assets to potential purchasers, investors, or successor entities.

• 4.3 Direct Marketing

- With your consent, the Company (Yubo Technology Limited) may use your Personal Data (including your name, contact information, device-related information, product and service portfolio information, usage data, location data, transaction and billing patterns and behavior, demographic data, and related derived data) to send you direct marketing communications and for related purposes. Direct marketing communications may be conducted through various means (such as mail, email, WhatsApp, SMS, MMS, instant messaging, app push notifications, targeted television messages, in-store display messages, telephone calls, targeted and/or personalized social media, website advertisements, or other methods).

- With your consent, the Company may also provide your Personal Data (including your name, contact information, device-related information, product and service portfolio information, usage data, location data, transaction and billing patterns and behavior, demographic data, and related derived data) to: our corporate group entities; and merchants, advertising, marketing and media service providers, and/or data analytics solution providers and/or other third parties providing or marketing the specific categories of products and services described below, and/or operators or service providers of reward, loyalty, and/or brand collaboration programs ("Marketing Partners"), for them to send you direct marketing communications and for related purposes through the aforementioned means. The Company may receive remuneration for providing Personal Data to group entities and/or Marketing Partners.

- The Company, its group entities, and/or its Marketing Partners may send you direct marketing communications relating to products and services they provide or promote, including but not limited to: health and wellness products, hair and skincare products, pain relief services, nutritional supplements, medical and health check services, television, telecommunications, OTT services, content services, mobile voice, messaging and data communications, internet connectivity, cloud services, electronic/mobile payments, entertainment, secretarial services, personal assistant services, information services (such as weather, health, financial and news information), device accessories, mobile applications and software, computer peripherals, accessories and software (including mobile phones, mobile devices and accessories, smart wearable devices), rewards, loyalty or premium programs, lifestyle, social events, travel, banking, sports, music, gaming, transportation, home products, dining, finance, stored-value facilities, e-wallets, insurance, wealth and asset management services and products, pensions, investment, financial advisory, credit and other financial services and products, education, beauty products and services, fashion and accessories, electronic products, social networking, technology, e-commerce, digital assets and related products and services, shopping malls and retail outlets, property development, public services, utilities, logistics, retail, home décor, media and high-end consumer products and services, and charitable and/or non-profit donations.

- You may, at any time, withdraw your consent to the use and/or disclosure of your Personal Data for direct marketing purposes by writing to the Company (by post to: Units A1–A5, 32/F, Tower A & B, TML Tower, 3 Hoi Shing Road, Tsuen Wan, Hong Kong; or by email to: member@eefit.com). You may, together with your registered name and membership account number, registered phone number or login account name (if applicable), submit a written request to the Company to cease receiving such promotional materials and/or communications (if you have previously consented to receive them).

5. Retention of Personal Data

We will retain your Personal Data strictly for as long as necessary to fulfill the purposes for which the data was collected.

• 5.1 Retention After Termination of Membership: Upon receipt of a written notice of membership termination and completion of the termination procedures, we will retain your Personal Data for nine (9) months to handle any potential subsequent refunds, points disputes, customer inquiries, or to fulfill accounting, tax, and other legal obligations.

• 5.2 Destruction Mechanism: Upon expiry of the retention period, unless applicable law requires continued retention, such Personal Data will be irreversibly and securely destroyed or thoroughly anonymized so that it can no longer identify you.

6. Data Security

The Company places high importance on and is committed to safeguarding the security of your Personal Data. We have implemented a series of industry-standard physical, electronic, and managerial security measures (including but not limited to the use of Secure Sockets Layer (SSL) encryption technology for transmitting sensitive data, strict server firewalls, and restricting access to Personal Data to authorized employees subject to confidentiality obligations) to protect your Personal Data against unauthorized or accidental access, processing, erasure, alteration, disclosure, or loss. However, data transmission over the Internet cannot be guaranteed to be 100% secure. Accordingly, when transmitting any data to us, you do so at your own risk and are responsible for safeguarding your account password.

7. Access and Correction of Personal Data

Under the Privacy Ordinance, you have the following statutory rights:

• To inquire whether we hold your Personal Data;

• To request access to a copy of your Personal Data held by us;

• To request correction of any inaccurate Personal Data;

• To withdraw your consent to our processing of Personal Data (please note that this may result in our inability to continue providing services under the Program).

The Company reserves the right to charge a reasonable administrative fee for processing any request for access to Personal Data, as permitted by law. We will respond within 40 days upon receipt of your request.

8. Contact Details

If you wish to exercise the above rights of access or correction of your Personal Data, request cessation of direct marketing communications, or have any inquiries, comments, or complaints regarding this Statement, please contact us through the following means:

• E-mail: member@eefit.com

• Mail: Units A1–A5, 32/F, Tower A & B, TML Tower, 3 Hoi Shing Road, Tsuen Wan, Hong Kong

(When submitting a request, please state your membership name, registered eefit membership number, and registered mobile phone number to facilitate prompt identity verification.)