Privacy Policy - Florentia Village China

Introduction

Welcome to our products and/or services. The service provider of Florentia Village (hereinafter referred to as “we” or “us”) highly respects your privacy and fully recognizes the importance of your personal information. When you use our products and/or services, we may collect and use your relevant information. We will, in accordance with applicable laws and regulations, implement appropriate security measures to protect your personal information to the best of our ability. This policy aims to explain how we collect, use, store, share, and transfer such information when you use our products and/or services, as well as how we provide you with access to, update, delete, and safeguard this information.

This policy is closely related to the online and/or offline services we provide to you through various channels, as well as the various business functions included in such services (hereinafter collectively referred to as “our products and/or services”). Before you start using our products and services, please carefully read and understand this policy. You should pay special attention to the terms highlighted in bold or bold underlined, and ensure that you fully understand and agree before using our products and services. We have tried to explain professional terms in this policy in a simple and easy-to-understand manner for your convenience. If you have any questions, comments, or suggestions regarding this policy, you may consult our customer service. When necessary, you may make choices you deem appropriate in accordance with the guidance of this policy.

This policy will help you understand the following:

I. Definitions and Scope of Application
II. How We Collect and Use Your Personal Information
III. How We Use Cookies and Similar Technologies
IV. How We Share, Transfer, and Publicly Disclose Your Personal Information
V. How We Protect and Store Your Personal Information
VI. How You Manage Your Personal Information
VII. How We Handle Minors’ Personal Information
VIII. Protection of Children’s Personal Information
IX. Notifications and Revisions
X. Complaints and How to Contact Us

I. Definitions and Scope of Application

(A) Definitions

Florentia Village Outlet GO: refers to the WeChat Mini Program “Florentia Village Outlet GO+.”

Service Provider of Florentia Village: refers to the operators and their respective management personnel of the offline Florentia Village stores located within the territory of the People’s Republic of China, including but not limited to Shanghai Luxury Outlet Mall Co., Ltd., Tianjin Luxury Outlet Mall Co., Ltd., Chengdu Luxury Outlet Mall Co., Ltd., Chongqing Luxury Outlet Mall Co., Ltd., Foshan Luxury Outlet Mall Co., Ltd., Wuhan Luxury Outlet Mall Co., Ltd., and RDM Management Consulting (Shanghai) Co., Ltd.

Personal Information: refers to various types of information recorded electronically or by other means that are related to an identified or identifiable natural person, excluding information that has been anonymized.

Sensitive Personal Information: refers to personal information which, if leaked or used illegally, may easily lead to the infringement of the dignity of a natural person or endanger the personal or property safety of such person. This includes information such as biometric data, religious beliefs, specific identities, medical and health information, financial accounts, location tracking, and personal information of minors under the age of fourteen (in this policy, sensitive personal information will be prominently marked in bold or bold underlined).

Children: refers to minors under the age of fourteen.

De-identification: refers to the process by which personal information is processed so that it cannot be used to identify a specific natural person without additional information.

Anonymization: refers to the process by which personal information is processed such that it cannot identify a specific natural person and cannot be restored.

(B) Scope of Application

This policy applies to: 1) Browsing or using Florentia Village Outlet GO, the Florentia Village WeChat Mini Program, Florentia Village Heart Card WeChat Mini Program, Florentia Village Welfare WeChat Mini Program, Florentia Village Member Parking Deduction WeChat Mini Program, and Florentia Village Happy Food & Fashion Party WeChat Mini Program; 2) Visiting Florentia Village locations across China or, in any other way, using our offline products and/or services; 3) Browsing or using any online channels owned or operated by us, including but not limited to websites, official social media accounts (including but not limited to WeChat Official Accounts, Xiaohongshu, Douyin, Weibo), applications (including but not limited to WeChat Official Accounts, WeChat Mini Programs, and other third-party applications), collectively referred to as “Online Channels”; and 4) Any visitor, Florentia Village member, or individual who communicates, interacts, or participates in our products, services, prize activities, promotional campaigns, or membership programs in any manner (hereinafter collectively referred to as “you”).

This policy does not apply to: 1) Information collected by third-party products or services accessed through our products and/or services (including any third-party websites), or other products or services linked in our products and/or services; 2) Information collected by third parties for the purpose of advertising or promoting our products and/or services; or 3) Information collected by third parties conducting advertising activities within our products and/or services. When using these third-party services (including any personal information you provide to them), you will be subject to the terms of service and privacy policies of such third parties rather than this privacy policy. Please read the relevant third-party terms carefully. You are advised to protect your personal information and provide it to third parties only when necessary.

II. How We Collect and Use Your Personal Information

We adhere to the principles of legitimacy, lawfulness, necessity, good faith, openness, and transparency. For the purposes described in this policy, we collect and use your personal information that you actively provide during the use of our products and/or services, information generated as a result of your use of our products and/or services, and relevant personal information obtained from third parties. If we intend to use your personal information for purposes not stated in this policy, or use information collected for a specific purpose for other purposes, we will notify you in a reasonable manner and obtain your consent again before such use.

The information we may collect in the process of providing you with our products and/or services may be used for the following purposes:

(A) Information You Authorize Us to Use

Our products and/or services include core functionalities necessary to provide shopping, membership services, after-sales services, and more. We may collect, store, and use the following information related to you to implement these functions. If you do not provide the relevant information, you will not be able to enjoy our products and/or services. Some membership features (e.g., points inquiry, membership level) can only be used after registration and/or login through the WeChat Mini Program. Our website currently only provides information display and service inquiry functions and does not proactively collect your personal information through registration or login.

These core functions include:

Membership Account Registration, Login, and Verification
When you register as a Florentia Village member, you are required to provide your personal mobile phone number. We will verify your identity through SMS verification codes or WeChat account login. Upon successful registration, you can use your membership account to log in to Florentia Village Outlet GO, the Florentia Village Membership WeChat Official Account, and other applicable online channels.

You may provide your Florentia Village membership account information to log in and use shopping functionalities in applicable online channels such as Florentia Village Outlet GO. If you do not provide such information, you will not be able to log in or make purchases. Basic browsing and search functions do not require membership registration or provision of the above information.

During registration, if you provide additional information to complete your profile - such as your WeChat nickname, gender, date of birth, location (province/city/district), email, and WeChat avatar - this will help us provide more personalized membership services, such as birthday privileges. These additional details are considered your “Account Information.” Providing such information will enhance personalized services, but not providing them will not affect basic functions such as browsing, searching, or purchasing.
Membership Points and Benefits
By providing membership information or logging into your membership account, you can access membership features and enjoy related benefits. For example, we may record your spending history, membership points, and account usage, and provide corresponding membership level privileges, including points redemption, birthday benefits, parking discounts, lucky draws, etc.
Shopping on Florentia Village Outlet GO
When shopping on Florentia Village Outlet GO, we may collect relevant information to provide the following services:
- (1) Order Placement and Management
  When you are ready to check out items in your shopping cart/bag, the Florentia Village Outlet GO system will generate an order for your purchase. You must provide the recipient’s name, delivery address, and mobile phone number. The order will also include the order number, purchased products or services, order time, payable amount, and payment method. If you require an invoice, you must provide the invoice title, tax identification number/social credit code, and the recipient’s email.
  All of the above constitutes your “Order Information,” which we use (including with third-party service providers) for identity verification, transaction confirmation, payment settlement, delivery, order inquiries, and customer service/after-sales support. We may also use order information to detect abnormal transactions and ensure transaction security.
- (2) Payment Function
  After placing an order, you may choose to pay through third-party payment institutions cooperating with Florentia Village Outlet GO (including WeChat Pay and UnionPay, hereinafter referred to as “Payment Institutions”). While the payment process itself does not collect your personal information, we must share your order number and payment-related information—including bank card number, expiration date, and repayment amount—with these payment institutions to complete the payment.
- (3) Product and/or Service Delivery
  To deliver products or services to you, you must provide accurate recipient name, delivery address, and contact number. If we entrust third parties to deliver, you agree to share the above information with them. You acknowledge and agree that third-party delivery personnel and our cooperating merchants or logistics companies will use your order information solely for the purpose of completing delivery.
  While providing delivery services, our delivery personnel may also assist in identity verification when legally required.
- (4) Photo/Video Access and Upload via Album
  You may enable album permissions to upload photos/videos to facilitate communication with customer service or provide proof. Uploaded images/videos may be used to identify the products or services you wish to purchase.
Florentia Village Heart Card
You may purchase Heart Cards via the Florentia Village Heart Card WeChat Mini Program. When logging in to create an account, we collect your mobile number, location, and information you authorized us to obtain via WeChat (including WeChat nickname, OpenID, avatar, bound phone number).

When purchasing a Heart Card through this Mini Program, an order is generated and we collect order number, creation time, payment amount, mobile number, and purchased product/service information. This information is processed to complete the transaction, ensure transaction security, enable order inquiries, provide customer service and after-sales support, and for other purposes explicitly stated in this privacy policy.

To complete the payment for your order, you may choose to make payment through a third-party payment institution cooperating with us. The page will redirect you to the payment page of the relevant third-party payment institution (e.g., WeChat Pay), to complete the payment, and you may be required to provide certain financial information (such as your bank card number or WeChat Pay account information). Please note that once you are redirected to the payment page of the third-party payment institution, your personal information will be collected and processed by the relevant third party, and we will neither have access to nor collect your bank card number or WeChat Pay account information.

If you wish to transfer an electronic card purchased through the Florentia Village Heart Card WeChat Mini Program to another person, you may use the electronic card gifting function provided in the Mini Program. When transferring the electronic card, you only need to send the electronic card transfer page to the recipient, and you are not required to provide the recipient’s personal information.

If you are the recipient of an electronic card, in order to identify and display your user identity as the card recipient, we will collect your WeChat authorization information based on your authorization.
Display of Services and Products
To present product/service pages, provide relevant search results quickly, and assess account security or transaction safety, we may collect:
- Device Information: with your authorization during installation/use, we may receive and record information about the device you use (such as device model, operating system and application version, and language settings).
- Log Information: when you browse Florentia Village Outlet GO or use our products and/or services, we will automatically collect information about your use of our services, including your search content, IP address, access date and time, and records of the web pages you visit.
Customer Service and After-Sales Support
When contacting us or requesting service, our call center and online customer service may use your account information for identity verification and security. For order-related customer service or after-sales support, we will access your order information. During your communication with our customer service personnel, you may provide additional information beyond the above, such as when you request changes to the delivery address, contact person, or contact phone number.
Location Information
You may choose to provide location information to help you find the nearest Florentia Village information. You may revoke your authorization for us to use your location information by turning off the location function on your device.
Live Streaming
When watching live streams via online channels, we may collect relevant information based on your authorization. The specific information collected may vary depending on the online channel and may include mobile phone number, account nickname, avatar, location information, etc. The specific scope of information collected will be subject to your authorization.
Subscription Messages
To inform you about marketing, promotions, and commercial promotional information that may be of interest to you, we may send marketing, promotional, and commercial promotional SMS messages to the mobile phone number you provide, or make phone calls inviting you to visit Florentia Village shopping centers to participate in our events, such as brand special sales events. You may choose whether to accept promotional information sent by us via SMS messages or phone calls, or you may opt out by contacting customer service.
Lucky Draws and Interactive Activities
In order to enable you to participate in interactive activities and lucky draw events organized by us, such as online lucky draw activities and other membership activities, we may require you to provide relevant personal information, such as your mobile phone number, email address, and membership information.
Surveys
We may collect additional information about you for reasonable purposes, including improving our services and promoting our products, such as information you voluntarily provide when participating in questionnaire surveys organized by us, including your responses to such surveys, as well as information obtained when you interact with our affiliates or business partners.

You acknowledge and agree that the above services may require the use of certain personal information or may require you to enable relevant access permissions on your device. You may decide at your own discretion whether to use or accept the above services or to authorize us to process your personal information. Please note that your voluntary provision of relevant information or use of our services shall be deemed to constitute your authorization for us to collect and use your relevant personal information. You may choose not to use the relevant services or to disable the corresponding functions or permissions, in which case we will cease collecting and using the relevant personal information based on such permissions, and we may be unable to provide the corresponding services that require such permissions. However, your decision not to use such services or to disable the permissions shall not affect the collection and use of information previously carried out based on your prior authorization or use of the services.

(B) Security Protection Functions

To ensure system stability and security when using our products/services, and prevent illegal access to your personal information, we may collect or integrate membership information (e.g., delivery addresses, identity information, bank card information), historical online records, log information, IP address, location, browsing data, order information, and authorized information from our affiliates/partners to assess your account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary record-keeping, auditing, analytical, and remedial measures.

(C) You fully understand that, under the following circumstances, we may collect and use your personal information without obtaining your authorization and consent:

Directly related to national security or defense;
Directly related to public security, public health, or significant public interests;
Directly related to criminal investigation, prosecution, trial, or execution of judgments;
To protect your or others’ life, property, or significant lawful rights where obtaining consent is difficult;
Information publicly disclosed by you;
Necessary for the performance of agreements or written documents with you;
Collected from publicly available information, such as legal news reports or government disclosures;
Necessary to maintain the security and stable operation of our products/services, such as identifying or handling product or service failures;
Necessary for lawful news reporting;
Required for academic research institutions conducting statistical or academic research in the public interest, provided that when research results are externally disclosed, the personal information contained therein is de-identified;
Other circumstances stipulated by laws and regulations.

(D) Rules for Using Your Personal Information

We use collected personal information to implement our products/services in accordance with this policy.
Your personal information may be de-identified using technical means, such information cannot be used to identify a specific individual. You understand and agree that in such circumstances we may use the de-identified information for analysis and commercial purposes without revealing personal identity.
You understand and agree that all personal information you provide when using our products and/or services, unless you delete such information or refuse our collection through system settings, will remain authorized for our use throughout the period during which you use our products and/or services.
We may compile statistics regarding the use of our products and/or services and may share such statistical information with the public or third parties in order to demonstrate the overall usage trends of our products and/or services. However, such statistical information will not contain any information that identifies you personally.
When displaying your personal information, we will apply desensitization measures, including but not limited to content substitution and anonymization, in order to protect the security of your information.
Where we intend to use your personal information for purposes not specified in this Policy, or where information collected for a specific purpose is to be used for another purpose, we will obtain your prior consent. You understand that the products and/or services we provide may be continuously updated and changed. If you choose to use other products and/or services that are not yet specified in this Policy, we will explain in detail the purpose, method, and scope of the collection of your personal information through agreements, page prompts, or other means before collecting such information, and obtain your consent. If you do not agree to provide such information, you may be unable to use the relevant products and/or services, but this will not affect your use of the existing products and/or services.

III. How We Use Cookies

We use cookies and other tracking technologies to understand your use of our online channels. A cookie is a specific identifier that can recognize your device. By identifying your device, we can recommend personalized products and advertisements to you (including content from affiliate websites provided through this site). Information collected through cookies is considered personal information that cannot be used independently. You understand and agree that we may combine the information collected through cookies with your other information. Most browsers have cookies enabled by default. You can adjust your browser settings at any time to disable cookies. However, cookies allow you to enjoy higher-quality and more personalized services. If you disable cookies, you may not be able to fully experience all the services we provide. Therefore, we recommend keeping cookies enabled.

IV. How We Share, Transfer, and Publicly Disclose Your Personal Information

(A) Sharing

We do not share your personal information with any companies, organizations, or individuals outside of us, except in the following circumstances:
- (1) With Your Explicit Consent: We will share your personal information with other parties after obtaining your explicit consent.
- (2) Legal Requirements: We may share your personal information in accordance with laws and regulations, litigation or dispute resolution needs, or requests from administrative or judicial authorities made in accordance with the law.
- (3) Necessary for Providing Products or Services: When you purchase products or services via Florentia Village Outlet GO, we may share necessary transaction-related information from your order with the relevant product or service providers to fulfill your purchase, delivery, and after-sales service requirements.
- (4) Handling Disputes at Your Request: Sharing necessary information to process disputes or conflicts between you and others upon your request.
- (5) Pursuant to Agreements: Sharing information as provided under agreements signed with you (including electronically signed agreements and applicable platform rules) or other legal documents.
- (6) Academic Research: Use of information for academic research purposes.
- (7) Public Interest: Use of information in accordance with applicable laws and regulations for public or social interests.
Sharing with Affiliates: To provide you with full access to our products and services through the Florentia Village membership system and recommend information that may interest you, your personal information may be shared with our affiliates and/or their designated service providers. We will only share the necessary personal information and strictly for purposes stated in this policy. If we intend to share your sensitive personal information or if an affiliate changes the purpose of use or processing of personal information, we will obtain your consent again.

(B) Entrusted Processing

To achieve the purposes described in this policy, we may authorize partners to process your personal information on our behalf to help provide relevant operations and services. We only entrust processing for lawful, legitimate, necessary, specific, and clear purposes, and will provide only the personal information necessary for the services. Our partners are not permitted to use the entrusted personal information for any other purposes.

Currently, our authorized partners include:

Suppliers of Products or Technical Services: We may entrust your personal information to third parties that support our functions, including providing supply, infrastructure or technical services, logistics and delivery, payment services, data processing, and more. The purpose of sharing this information is to implement core functionalities of our products and/or services - for example, sharing order information with logistics service providers to arrange delivery, or sharing order numbers and amounts with third-party payment institutions to confirm payment instructions and complete transactions.
Promotional Partners: Occasionally, we may provide promotional services on behalf of other businesses to users of our products and/or services. We may share aggregated, non-personal user profiles generated from your personal and non-personal information with these promotional partners (hereinafter referred to as “Principals”). Only information related to promotion coverage and effectiveness will be shared; personal identifiers will not be disclosed, or we may provide aggregated information that does not identify any individual. For instance, we may report to the principal the number of views or purchases resulting from the promotion, or provide statistical information that cannot identify individuals, in order to help them better understand their audience or customers.
Third-Party Merchants: We must share necessary transaction-related order information with third-party merchants to fulfill your purchase requirements and enable subsequent after-sales services.

To provide the above services and functionalities, our online channels may integrate authorized partners’ application programming interfaces (APIs), software development kits (SDKs), or similar applications.

We will sign strict confidentiality agreements with all companies, organizations, and individuals with whom we share personal information, requiring them to process the personal information in accordance with our instructions, this policy, and other applicable security measures. For sensitive personal information, we require third parties to adopt data anonymization and encryption technologies to better protect user data. We perform rigorous security checks on APIs, SDKs, and other tools used by authorized partners and conduct information security audits for key third parties to ensure compliance with our personal information protection standards.

We may also exchange information with other companies and organizations to comply with laws, enforce our terms of use and agreements, or protect the rights, property, or safety of our online channels, you, or other Florentia Village members - for example, to prevent fraud or reduce credit risks. This does not include selling, renting, sharing, or otherwise disclosing personal information for profit in violation of the commitments in this policy.

Currently, the third-party SDKs we use include the following:

“Florentia Village Gift Card” WeChat Mini Program

SDK Name	Operator	Function	Types of Personal Information Collected	Privacy Policy Link
WeChat SDK	Shenzhen Tencent Computer Systems Company Limited	Automatically selects the nearest Florentia Village Gift Card stores based on user location; enables silent login for users	Geolocation (latitude and longitude), Open ID, Union ID	https://www.wechat.com/zh_CN/privacy_policy

“Florentia Village” WeChat Mini Program

SDK Name	Operator	Function	Types of Personal Information Collected	Privacy Policy Link
Aladdin	Shanghai Yike Information Technology Co., Ltd.	Data tracking and analytics	User identifiers, device information	https://www.ezrpro.com/privacy.html
Youshu	Shanghai Yike Information Technology Co., Ltd.	Data tracking and analytics	User identifiers, device information, user behavior	https://www.ezrpro.com/privacy.html

“Florentia Village Benefits” WeChat Mini Program

SDK Name	Operator	Function	Types of Personal Information Collected	Privacy Policy Link
link flow	Shanghai Yuanxi Information Technology Co., Ltd.	Member interaction	WeChat Union ID, mobile phone number	https://www.linkflowtech.com/privacy-policy

“FV OUTLET” WeChat Mini Program

SDK Name	Operator	Function	Types of Personal Information Collected	Privacy Policy Link
WeChat Mini Program	Nanjing Moboyunzhou Information Technology Co., Ltd.	Online mall product sales	WeChat account, mobile phone number, province/city/district address, date of birth	https://www.mobcb.com/#/

“Florentia Village Outlet GO+” WeChat Mini Program

SDK Name	Operator	Function	Types of Personal Information Collected	Privacy Policy Link
WeChat Mini Program	Shangpai Software Co., Ltd.	Online mall product sales	WeChat account, mobile phone number, province/city/district address, date of birth	https://www.mobcb.com/#/

(C) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

Transfer with explicit consent or authorization: We may transfer your personal information to other parties after obtaining your explicit consent or authorization.
We may provide your personal information as required under applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements.
We may provide your personal information in accordance with the relevant agreements you have signed with us (including electronic agreements signed online and related platform rules) or other legal documents.
In the event of a merger, acquisition, asset transfer, or similar transaction involving personal information transfer, the new entity holding your personal information will be required to continue to comply with this Policy. Otherwise, we will require the new entity to obtain your renewed consent.

(D) Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

When requested by you, and with your explicit consent, we may disclose the personal information you designate in the manner you specify.
When required by laws, regulations, or mandatory administrative or judicial requirements, we may publicly disclose your personal information according to the types and methods specified in the request. To the extent permitted by laws and regulations, we will request the corresponding legal documents (e.g., subpoenas or investigation letters) before disclosing such information. We firmly believe that, with respect to requests for information disclosure, transparency should be maintained to the greatest extent permitted by law. We carefully review all requests to ensure they are legally valid and limited to data necessary for specific investigations by relevant government or law enforcement authorities. All disclosed documents are protected with encryption keys to ensure security, to the extent allowed by laws and regulations.

V. How We Protect and Store Your Personal Information

(A) Technical Measures for Protecting Your Personal Information

We take the security of personal information very seriously and implement all reasonably practicable measures to protect your personal information:

Data security measures
We adopt industry-standard, reasonable, and practicable security measures to protect the personal information you provide, preventing unauthorized access, use, modification, or damage. These measures include, but are not limited to: cloud protection, cloud firewalls, vulnerability scanning, security monitoring, VPN, encrypted API access, HTTPS network requests, and anti-malicious request risk control.
Only Florentia Village service providers, their affiliates, and authorized partners who need to know your personal information are granted access. Strict access controls and monitoring mechanisms are in place. All personnel who may access your personal information are required to comply with confidentiality obligations. Failure to comply may result in legal liability or termination of cooperation.
We take all reasonable measures to ensure that only relevant personal information is collected. Personal information is retained only as long as necessary to achieve the purposes described in this Policy, unless an extension is required or permitted by applicable laws. For example, the E-Commerce Law of the People's Republic of China requires that information on goods, services, and transactions be retained for at least three years from the completion of the transaction. After the retention period, we will delete your personal information or anonymize it according to applicable laws.
The internet is not absolutely secure. Communications via email, instant messaging, or social media with other users may not be fully encrypted. We recommend that you carefully safeguard your accounts and protect your personal information when using these tools.
Security incident handling
In the event of a personal information security incident, we will notify you promptly in accordance with applicable laws and regulations. This notification will include: the basic situation and possible impact, measures we have taken or plan to take, recommendations to mitigate risks, and remedial actions available to you. Notifications may be delivered via email, letter, phone, or push notifications. If individual notification is impractical, we will publish announcements reasonably and effectively. We will also report security incidents to regulators as required.
If you have any questions about our personal information protection measures, you may contact us through the contact details provided at the end of this policy. If you discover that your personal information has been disclosed, especially involving your account credentials (including verification codes), please contact us immediately using the contact information provided in Section X (Complaints and How to Contact Us) so that we may take appropriate measures accordingly.

(B) Storage of Your Personal Information

Storage location:
In principle, personal information collected and generated within the People's Republic of China (PRC) will be stored within the PRC.
We will comply with national regulations and standards, complete the necessary compliance procedures, and endeavor to ensure that your personal information receives equivalent protection within China.
Retention period:
We will retain personal information only as long as necessary to achieve the purposes described in this Policy, except where laws require longer retention. For example, under the E-Commerce Law of the PRC, goods, services, and transaction information must be retained for at least three years from the completion of the transaction. We determine the retention period based on the following criteria, taking the longer period where applicable:
- (1) To complete transactions with you and maintain records for potential inquiries or complaints;
- (2) To ensure the security and quality of services provided;
- (3) Your consent to a longer retention period;
- (4) Any other special agreements or legal/regulatory requirements regarding retention;
- (5) After the retention period, we will delete your personal information or anonymize it in accordance with applicable laws.
Please note that once you successfully delete your Florentia Village membership account, we will delete or anonymize your personal information. Due to applicable laws and technical limitations, some information may not be immediately removed from backup systems. During this period, your personal information will be securely stored and further processing will be restricted until it can be deleted or anonymized.
In the event we terminate our services or operations, we will notify you at least thirty (30) days in advance. Following termination, we will delete or anonymize your personal information.

VI. How You Can Manage Your Personal Information

We value your rights regarding your personal information and take all reasonable steps to enable you to access, correct, delete, or withdraw consent, ensuring your privacy and security. Your rights include:

(A) Accessing and Correcting Your Personal Information

Unless otherwise restricted by law, you have the right to access and correct your personal information at any time, including:

Account information: You can access, modify, or supplement such information through our WeChat mini-programs, official accounts, or other network channels.
Delivery information: You can access, modify, or supplement such information through our WeChat mini-programs, official accounts, or other network channels.
Order information: You can access, modify, or supplement such information through our WeChat mini-programs, official accounts, or other network channels .
If you need to access or correct any other personal information collected during your use of our products and/or services, please contact us. We will respond in accordance with the method and time frame specified in this Policy.

(B) Deleting Your Personal Information

You may directly delete certain personal information (e.g., order information, shipping address) through our product and/or service pages. You may also request deletion in the following circumstances:

If our processing of your personal information violates laws or regulations;
If we collect or use your personal information without your consent;
If our processing violates any agreement with you;
If you no longer use our products or services, or you have deleted your Florentia Village membership account;
If we terminate our services or operations.

If we decide to fulfill your deletion request, we will also notify entities that have obtained your personal information from us to delete it promptly, unless otherwise required by law or you have independently authorized these entities. If we respond to your deletion request, please note that we cannot guarantee immediate deletion from backup systems, but your information will be deleted during subsequent backup updates.

(C) Changing or Withdrawing Your Consent

You may change the scope of consent for the collection of personal information, or withdraw your authorization, by deleting information, disabling device features, or contacting our customer service. You may also withdraw consent entirely by deleting your account.

Please note that certain basic personal information is required to provide our services. If you withdraw consent, we may no longer be able to provide the corresponding services or process the related information, nor will we continue to process your relevant personal information. However, withdrawing consent does not affect the legality of prior processing conducted under your consent.

(D) Account Deletion

You may request account deletion by contacting our customer service. Upon account deletion, we will stop providing products and/or services and, except as otherwise required by law, delete your personal information in accordance with your request.

(E) Obtaining a Copy of Your Personal Information

You have the right to obtain a copy of your personal information. To do so, please contact our customer service. We will provide a copy of your personal information in compliance with applicable laws and where technically feasible.

(F) You may opt out of receiving promotional messages at any time by:

Following instructions in the promotional SMS to unsubscribe;
Contacting our customer service to stop receiving promotional or product-related information;
We will not send promotional messages containing sensitive content related to religion, sexual orientation, or other similar private matters.

(G) Responding to Your Requests

If you are unable to access, correct, or delete your personal information via the methods above, or if you wish to access, correct, delete, or obtain copies of other personal information collected during your use of our products and/or services, or believe we have violated applicable laws or our agreements with you, you may contact us at customerservice@fvoutlet.com or through the contact methods in Section X (Complaints and How to Contact Us). To ensure security, we may require written requests or identification documents. We will respond within fifteen (15) days after verifying your identity. In principle, reasonable requests are free of charge. However, we may charge a reasonable fee for repeated requests and requests that exceed reasonable limits. We may also refuse requests that are unreasonably repetitive, require excessive technical measures (e.g., developing a new system or fundamentally changing existing practices), pose risks to the lawful rights and interests of others, or are otherwise impractical (e.g., where the information involved is stored on backup tapes).

We cannot respond to requests in the following situations, as required by law:

Where requests relate to the personal information controller’s compliance with legal obligations;
Where requests relate to national security or defense;
Where requests relate to public safety, public health, or significant public interest;
Where requests relate to criminal investigations, prosecutions, trials, or enforcement of judgments;
Where there is evidence of malicious intent or abuse of rights;
Where responding would endanger the life, property, or significant legal rights of individuals and consent cannot be obtained;
Where responding would seriously harm the legitimate rights of you or others;
Where requests involve trade secrets.

VII. How We Handle Personal Information of Minors

We presume that you have the corresponding civil capacity. If you are a minor, we require that your parent or legal guardian carefully read this Policy and provide their consent before you use our services or submit any information to us. For cases where personal information of minors is collected with parental or guardian consent, we will only use, share, transfer, or disclose such information in accordance with applicable laws and regulations, with the explicit consent of parents or guardians, or as necessary to protect the minor.

VIII. Protection of Children’s Personal Information

(A) Our products, websites, and services are primarily designed for adults. Children should not create their own user accounts without parental or guardian consent.
(B) Children under the age of 14 should use our services under the guidance of their parent or guardian to ensure safety while using our services and making transactions. Parents or guardians should monitor whether children under their care are using our services with proper authorization.
(C) We strictly comply with laws and regulations concerning the protection of children’s personal information, following principles of legality, necessity, informed consent, clear purpose, data security, and lawful use. With parental or guardian consent, we collect and use children’s personal information only as required. Specifically, for children under 14 years old, we take the following measures:
- 1. Any personal information collected from children will be handled in accordance with this Policy and the Regulations on the Protection of Personal Information of Children Online, ensuring legality, necessity, informed consent, clear purpose, data security, and lawful use. If we discover that we have collected personal information from a child without verifiable parental consent, we will take steps to delete such information promptly.
- 2. We strictly follow the Cybersecurity Law of the People's Republic of China, the Law of the People's Republic of China on the Protection of Minors, the Regulations on the Protection of Personal Information of Children Online, and other applicable laws and regulations regarding the storage, use, and disclosure of children’s personal information. Information will only be retained for as long as necessary to fulfill the purpose for which it was collected and will be deleted or anonymized after that period.
- 3. When you, as a guardian, choose to use our products or services for the minor under your supervision, we may need to collect the minor’s personal information to provide necessary services to you. In such cases, we will obtain your authorization and inform you of the purpose and use of the information. Guardians are responsible for properly exercising their duty to protect children’s personal information. If a child needs to register or use our products or services, you should provide proper guidance and supervision.
(D) If you have any questions about the personal information of a child under your supervision, please contact us using the methods provided in Section X (Complaints and How to Contact Us). We will arrange for a dedicated team to handle children’s personal information matters.

IX. Notifications and Revisions

(A) To provide you with better services and as our business evolves, this Policy may be updated from time to time. However, we will not reduce the rights you are entitled to under this Policy without your explicit consent. We will post the updated version on the relevant online channels and notify you of updates through announcements or other appropriate means before they take effect. We also encourage you to regularly check our online channels to stay informed of the latest privacy policy.
(B) For material changes, we will provide more prominent notifications, including but not limited to emails, SMS, or special prompts on web pages, specifying the exact changes to the Privacy Policy. Material changes include but are not limited to:
- 1. Major changes in our service model, such as purposes of personal information processing, types of personal information processed, methods of using personal information, or cross-border transfer of personal information;
- 2. Significant changes in ownership or organizational structure, such as business operations, mergers, acquisitions, or bankruptcy that result in changes of ownership;
- 3. Changes in the main entities with whom personal information is shared, transferred, or publicly disclosed;
- 4. Significant changes in your rights regarding personal information and the way to exercise those rights;
- 5. Changes in the department responsible for personal information security, contact information, or complaint channels;
- 6. When a personal information security impact assessment indicates a high risk.
(C) We will maintain archived versions of our privacy policies on the relevant online channels for your reference.
(D) To ensure timely receipt of notifications, we recommend that you promptly update us with any changes to your contact information. If you continue to use our services after the updated Policy takes effect, you are deemed to have fully read, understood, and agreed to be bound by the updated Policy.

X. Complaints and How to Contact Us

If you have any complaints, questions, or suggestions regarding this Privacy Policy, you may contact us using the following methods. We will handle your feedback appropriately and generally respond with our handling opinion or results within fifteen (15) days.

Company Name: RDM Management Consulting (Shanghai) Co., Ltd.
Email: customerservice@fvoutlet.com
Tel: 400-820-6828