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Data Protection & Confidentiality

Last updated: 22 September 2026

This notice explains how LuxePartnerDeFee collects, uses, protects and discloses personal data, and sets out the confidentiality obligations that apply to all Data accessed through the Platform. It is issued in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region (the “PDPO”).

1. Processing of Your Personal Data

Personal data collected on the LuxePartnerDeFee platform with your consent is processed for the following purposes:

  • the storage and validation of your supporting documents, enabling you to be listed as a business-introduction partner with the maisons, brands, chains and partner boutiques of LuxePartnerDeFee;
  • the declaration and validation of your invoices and purchase receipts, and the calculation and tracking of the corresponding commissions.

This processing is based on your consent. Providing the mandatory fields is necessary to enable LuxePartnerDeFee to manage and administer the validity of your files; without them, no validation can be carried out. Providing the other fields is optional. The processing is carried out under the responsibility of LuxePartnerDeFee.

2. Categories of Data Collected

The data collected includes the data required to verify your identity (name, gender, email address, geographic address, telephone number, nationality, passport), your country of residence and country of tax residence, your travel documents where applicable (Schengen visa, Schengen entry and exit stamps), your legal status as an independent or salaried business-introduction partner (tourist guide card, freelancer proof, business licence, certificate of incorporation and similar documents), your bank details where applicable, and the invoices and purchase receipts you declare on the Platform.

3. Recipients of Your Personal Data

The recipients of the data collected may be:

3.1. the single maison, brand, chain or boutique that has sent you a specific invitation to register on its dedicated space on LuxePartnerDeFee, which will be the sole recipient of your personal data; or

3.2. LuxePartnerDeFee together with those of its commercial partners with whom you have expressly consented to collaborate.

The recipient(s) of your personal data will be expressly identified in the particular conditions to which you must consent upon registration.

4. Confidentiality and Security of Your Data

In order to preserve the confidentiality and security of your personal data, and in particular to protect it against unlawful or accidental destruction, accidental loss or alteration, or unauthorised disclosure or access, we implement appropriate technical and organisational measures, including: encryption of passwords, encrypted transport (HTTPS / SSL), role-based access control, logging of operations on personal data, and hosting of data within a secured environment. Your data is stored on secured personal spaces accessible only to the administrators of LuxePartnerDeFee and of its partner maisons, brands, chains or boutiques.

5. Strict Prohibition on Disclosure of Data — Liability

The public disclosure of Data is strictly prohibited. Violators will be held liable.

All Data accessed through or obtained from the Platform — including personal data, partner data, client data, invoices, transaction records, pricing and commission rules — is confidential and is the property of LuxePartnerDeFee and/or its partners. No person may disclose, publish, disseminate, reproduce, transfer, sell or otherwise make such Data available to the public or to any third party, by any means or in any medium, whether during or after their use of the Platform, without the prior written consent of LuxePartnerDeFee.

Any person who discloses Data in breach of this clause shall bear full legal liability. LuxePartnerDeFee reserves the right to suspend or terminate the offending account immediately, to report the matter to the competent authorities, and to pursue all civil and criminal remedies available under the laws of the Hong Kong Special Administrative Region, including injunctive relief, damages and an account of profits. The offending party shall indemnify LuxePartnerDeFee and its partners against all losses, liabilities, costs and expenses arising from the breach.

6. Retention of Your Personal Data

The data collected is retained for the following periods:

  • to validate your business-introduction partner file and your invoice declarations: five years from their validation, a period justified by the statutory retention requirements applicable in the event of an audit;
  • where your data is used for commercial-communication purposes: two years from the collection of your most recent consent.

Upon expiry of the periods above, the data is deleted, save where your consent is renewed.

7. Your Rights

In accordance with the PDPO, you have the right to request access to and correction of the personal data we hold about you, to be informed of the purposes for which your data is used, and to request that we cease using your data for direct-marketing purposes. You may also withdraw your consent to the processing of your data at any time; such withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise these rights, please contact us through the Platform. For confidentiality and security reasons, we may need to verify your identity before responding. If you consider that your rights have not been respected, you have the right to make a complaint to the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk).