CLOVEREST INC, a United States limited liability company (“Silver Clover”, “we”, “us” or “our”) recognizes the importance of protecting your Personal Data (as defined hereunder). This Privacy Policy (“Policy”) describes how SilverClover collects, processes, uses, disseminates or makes available your personal data via SilverClover website (www.silverclover.com), including SilverClover mobile applications (collectively, “Website”) and other means (i.e, social media, cookies, etc.).

Last Modified Date: 1 July 2020

1. What Is Personal Data?
   For the purpose of this Policy, Personal Data means and includes your name, phone number, address, email address, online identifiers and any other data which, directly or indirectly, can identify you.
2. Personal Data We Collect
   1. Information Voluntarily Provided To Us. We collect your Personal Data and other information when you visit our Website, place orders, make purchases, sign up or create an account with us, when you interact with our customer service for support or giving us a feedback, when you visits our retail/pop-up stores, or when you subscriber/participate in our survey/review or marketing activities (e.g., subscribing to our newsletter/mailing list, participating in our loyalty programs, contests and sweepstakes, etc.). The Personal Data obtained and collected by us includes:
      • Contact information (i.e, your name, phone number, postal address, email address, birthday and any other personal data)
      • Details of purchase/order your made and your purchase history
      • Your payment information, such as billing address, credit card information and other information required for placing order or to complete the purchase
      • Your consumer behaviours and habits
      • Information and reason of contacting our customer service, and communication content between you and our customer service
   2. Information Automatically Collected By Us. When you visits our Website, or when you interact with our emails or advertisements on our Website, or other sites, certain information are automatically collected by cookies or other tracking technologies:
      • Internet protocol (IP) address and other device identifiersYour login information, browser type, browser plug-in types, operation system, time zone settingInformation about your visit of our Website pages (e.g, products you searched or viewed for, the amount of time you spend on each page, crashes and download errors and response times)

      For more details, please refer to the SilverClover Cookies Policy for more details. You may adjust your browser settings to decline cookies or limit certain tracking. However, such change, adjustment or limitation may impact your experience of certain services/features on our Website, or you may not be able to take full advantage of our offerings.

   3. Information Collected From Third Party Sources. We also obtain and collect certain of your information from third party sources, including social media, third party apps and similar technologies. The information may include your name, user name, postal address, phone number, email address, demographic information, habits, preference, interests and any other publicly-observed data.
   4. Facebook Connect. Our Website has an option of using the “Facebook Connect” feature, a service of the Facebook social media network, to log in your registered account on our Website. By using this feature, you will be redirected to the Facebook website and log in your registered account by using your Facebook user information. Your Facebook profile will then be linked with our Website, and those information you have consented to be used will be shared with us.

      These information may include your first name, last name, profile image, gender, birthday, email address, place of residence, list of friends, habits, preference and interests. For more information about Facebook Connect and access to the relevant privacy settings, please visit this Facebook webpage: https://www.facebook.com/about/privacy.

   5. Combination of Information. We may combine the information we collect, obtain or receive from and above you set forth in clauses 2.1 to 2.4 above.
3. How We Use Your Personal Data
   1. To Perform A Contract With You. We use and process your Personal Data to perform a contract with you and carry out our contractual obligations, including processing the order(s) you have placed and the payments, or take step that you have requested to enter into a contract.
   2. For Our Legitimate Interest. We use and process your Personal Date for our legitimate interests, and our interests are not overridden by your interests, fundamental rights or freedoms. Our legitimate interests include:
      • To manage your registered account(s) or membership with us
      • To run and develop our business activities
      • To pursue and conduct general marketing and promotional activities
      • To provide you with our customer services, such as after-sale service, answering your queries, and providing you with the required products, services or information
      • To invite your feedback in order to improve our products, service and Website
      • To conduct research, review and analysis
      • To manage and administer our accounts and record
      • To prevent or detect fraud and abuses of our Website
   3. Based On Your Consent. In addition, based on your consent, we also use and process your Personal Date for other marketing purpose:
      • To communicate with you on updates about our products
      • To deliver the type of product that may be of interest to you, including tailored advertisements
      • To personalize and customising your Website experience
4. Who And How We Share Your Personal Data
   We do not sell your Personal Data. We do share your Personal Data as follows:
   1. Authorized Personnel. Within SilverClover, only the duly authorized personnel would have access to your Personal Data as necessary to perform duties for the purposes set forth in clause 2 above.
   2. Other Third Parties. In addition, we share your Personal Data to the following third parties:
      • Service Providers, including service providers for (a) web hosting, analytics and related services, (b) payment processing, (c) order fulfilment and shipping, (d) fraud protection and credit risk reduction, and (e) marketing services on our behalf. The service providers are obligated contractually not to use, share or disclose your Personal Data unless as necessary to perform the services on our behalf or to comply with the applicable laws and regulations.
      • Business Partners with whom we may collaborate in offering offer products
      • Advertising Partners, who will be allowed to set cookies or other tracking tools to collect information regarding your activities on our Website. We may also share with them certain selected personal information, such as purchase records and demographic information. They may use the information collected for “interest-based advertising” and “online behavioural advertising, i.e, to deliver tailored or targeted advertisings to you on other websites.
      • Trusted Third Parties, where disclosure is necessary (a) to protect the security or integrity of our databases or our Website; (b) for legal proceedings (e.g, legal action against pirated, counterfeit or unauthorised products) and to take precautions against legal liability; (c) in connection with the management of our business and operations; (d) in the event of a sale, merger, reorganization, change of control or any other similar event, to the extent permitted by applicable law; or (e) as required by applicable law or regulations, to the extent compatible with this Privacy.
5. Transfer of Personal Data
   1. Outside Of The Origin Country. Your Personal Data may be transferred outside of the country from which it was originally collected and may be shared both intra-group and with third parties located in other jurisdictions, which may not have similar data protection laws. All such transfers of Personal Data will be pursuant to the applicable data protection laws.
   2. Outside Of EEA. For residents in the European Economic Area (“EEA”), we implement appropriate safeguards for the transfer of your Personal Data outside of the EEA, such as an appropriate data transfer agreement (based on the EU Commission Standard Contractual Clauses for the transfer of data to third countries (Article 46, 2., (c) of the GDPR, as of 25 May 2018)) or binding corporate rules (Article 47 of the GDPR as of 25 May 2018). All Personal Data so transferred should have adequate protection in accordance with applicable data protection rules.
6. Security And Retention
   1. Security. We place great importance on and are committed to protect the security of your Personal Data. We take appropriate technical and organizational measures to protect your Personal Data against accidental loss, unlawful or accidental destruction, alteration, unauthorized disclosure or access. However, there is no electronic transmission or storage of information is 100% secure. While we will use commercially reasonable effort to protect your personal information, we cannot guarantee its absolute security and any transmission of your personal information through the internet is at your own risk. For the best possible protection of your personal data and information, we recommend that your device should be protected (i.e, the latest antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (i.e, firewalls and anti-spam filtering).
   2. Retention. We retain your Personal Data for the time necessary to achieve the purposes set forth in this Policy, and in any event within the legal limitation periods under the applicable laws.
7. Your Rights With Respect To Your Personal Data
   You have the rights to:
   • Get a copy of your Personal DataAccess, correct and update your Personal DataRestrict our use and processing of your Personal DataObject our use and processing of your Personal Data for direct marketing and other purpose based on a “legitimate interest”Request to delete your Personal DataWithdraw a consent given to us previouslyNot to be subject to a decision based solely on automated processingMake a complaint against us with your local data protection supervisory authority

   You may exercise any of these rights by sending an email to us ([email protected]) with a subject of “Personal Data Right”. We will take step to verify your identity, please provide us with your name, email address and evidence of your identity. We may also contract you asking for certain information for verification purpose. We will honour your above requests free of charge, however, to the extent permitted by law, we reserve the right to charge a reasonable fee or not to act on the request in case of the request is manifestly unfounded or excessive.

8. Links To Social Media Platforms And Other Sites
   1. Social Media Platforms. Our Website contain social media plug-ins, including Instagram, Facebook, Twitter, Pinterest and Snapchat. If you interact with these plug-ins, your activity on our Website will also be made available to those social media platforms. We do not have control of these social medial platforms and do not endorse or make any representations about the third party websites/applications, we are not responsible for their privacy practices or content. We encourage you to read the privacy policies of such social media platforms with which you interact.
   2. Other Sites. Our Website may also contain hyperlinks to other third party website/applications which are not controlled or operated by us. The hyperlinks are for your reference and convenience only. We do not endorse or make any representations about the third party websites/applications, and are not responsible for their privacy practices or content. We encourage you to read the privacy policies of any website/application you visit before you visit the website/application or provide your Personal Data to them.
9. Children’s Privacy Protection
   We are concerned about the safety of children when they use internet. Our services and Website are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. Children should obtain their parent’s consent before giving out their personal information. If we are made aware of that personal information of a child under the age of 13 (or the age of 16 in certain EU member countries) are collected without verifiable parental consent, we will delete such information from our files as soon as possible and cease and terminate the child’s register account/membership. If you are concerned of your child’s use of our Website, we recommend you to use web-filtering technology to supervise your child’s access to our Website.

   If you learn that your child has provided us with personal information without your consent, please alert us at [email protected] with a subject of “Children’s Privacy Protection”.

10. Cookies
    Please refer to SilverClover Cookies Policy
11. California Residents
    Please refer to SilverClover Privacy Statement For California Residents
12. Last Modified Date And Change
    This version of Policy is last modified and effective on 1 July 2020. We may from time to time change or modify our Policy to reflect changes to our privacy practices. If there is any modification or change, we will update the latest version which will be effective from the Last Modified Date. For any material changes, we will post a prominent notice on our Website, and where required by applicable law, we may also notify you of such material changes and seek your consent.
13. Questions And Concerns
    If you have any queries, concerns, complaints, feedback or comments regarding this Policy, please contact our Data Protection Officer at [email protected]. We will endeavour to respond to your request and resolve your concerns as soon as possible.

This SilverClover Cookies Policy forms part of the SilverClover Privacy Policy. This cookies policy describes which cookies are used on SilverClover website (www.silverclover.com), including SilverClover mobile applications (collectively, “Website”), which is operated by CLOVEREST INC, a United States limited liability company (“SilverClover”, “we”, “us” or “our”), and how you can manage the cookies setting.

1. What Is Cookie? A cookie is a small data file sent to your browser and stored on your computer’s hard drive, mobile phone or other device. The “first party cookies” are the cookies set by the website owner, and are used to make the website work, and work more efficiently, also to provide reporting information. The “third party cookies” are the cookies set by other third parties, which allows third party features/functionality to be functioned on our Website, such as website analytics and advertising. Also, they can recognize your device when you visit or interact with our Website and when you visit or interact with other sites. Cookies can also classified as “session cookies” which would be deleted automatically when you close the website browser, and “persistent cookies” which would last for more than one visit. The sites with these cookies can recognize you when you re-open your browser.
2. Types Of Cookies We Use.
   1. Strictly Necessary And Functional Cookies – These cookies are necessary for basic site functionality and to provide you with services on our Website, i.e, allowing your access to our Website, identifying you when you sign in your registered account, allowing your use of Website functions such as shopping carts and securing customer account pages. If you choose to disable these cookies, you will be unable to place order. These cookies are first party and session cookies.
   2. Performance And Functionality Cookies – These cookies are not strictly necessary but can enhance the Website’s performance and functionality by tracking usage on the Website. For example, they allow us to remember your site preference. If you choose to disable these cookies, certain functions such as the personalized features may become unavailable. These cookies are also first party cookies and can be session or persistent.
   3. Analytics and customization cookies – These cookies collection information about how you use the Website, such as which pages you visits, and help us customize the Website for your. They also include analytics allowing us to obtain statistics about website access and the effectiveness of our marketing campaigns. The information so collected is aggregated and no personal identification information would be collected by these cookies. These cookies are mix of first party and third party cookies, and can be session or persistent. The third party cookies include pinterest.com, facebook.com and twitter.com.
   4. Advertising And Marketing Cookies – These cookies collect information to create tailored advertising to your interest on our Website, social media platforms or other sites. They identify your preferences and analyse your online interactions with us. If you choose to disable these cookies, it may result in receiving advertising that is not as relevant to you. These cookies are mix of first party and third party cookies, and can be session or persistent. The third party cookies include naver.com, line.me, shop.pe, doubleclike.net, linksynergy.com, facebook.com, twitter.com and bing.com.
   5. Social Media Cookies – These cookies enable you to connect to third party social media networks and share content from our website through to the social media networks. If you choose to disable these cookies, you will be unable to connect to the social media networks effectively and to share content. These cookies are mix of first party and third party cookies, and can be session or persistent. The third party cookies include pinterest.com, facebook.com and twitter.com.
3. Google Analytics. We use Google Analytics to collect information about how you use our Website. The information generated by the cookies about your use of our Website, such as time, place and frequency of your visits to our Website, including your IP address, will be transmitted to Google’s servers in the United States and stored there. Google will use these information on our behalf to analyse your use of our Website, compile reports regarding activities on our Website and other internet usage. The information that your browser conveys within Google Analytics will not be merged and associated with any other data held by Google. You may at any time opt-out from being tracked by Google Analytics. For more details, please visit: http://tools.google.com/dlpage/gaoptout.
4. How To Manage Your Cookies. You can set your browser for notification when you receive a cookie, you can then decide accepting it or not. Also, you are always have the option to accept or decline the use of cookies by changing your web browser settings, and you may also delete cookies. Currently, our Website does not respond to browser “Do Not Track” signals. Here are the links of certain browsers with details of the cookies setting:
   • Chrome
   • Firefox
   • Internet Explorer 7 and 8
   • Internet Explorer 9
   • Safari
   • Opera

   You may learn how to delete cookies at http://www.allaboutcookies.org/; and how to disable third party cookies and advertising or targeting cookies on your computer at http://youronlinechoices.com/.

   Please be aware that if you disable the cookies completely, our Website may not be able to function properly, and it may impact your experience of certain services/features, or you may not be able to take full advantage of our offerings.

If you are a California resident, please also note this additional statement which is supplemental to our main Privacy Policy. As required under the California Consumer Privacy Act or (“CCPA”), this statement will share with you certain additional information relating to our privacy practice.

1. Categories Of Personal Information We Collected.
   In the preceding 12-month period, we have collected the following categories of personal information:
   • Identifiers, for example, name, email address, billing and shipping address and phone number
   • Commercial information, for example, purchase habits and purchase history
   • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), for example, physical characteristics or description and payment information such as credit card number
   • Protected classifications under California law, for example, age (over 40 years old), race and gender
   • Geolocation data, for example, precise physical location such as IP address, billing address and shipping address
   • Internet and other similar network activity, for example, browsing history, search history, consumer’s interaction with a website, application or advertisement
   • Visual information, for example, the pictures/images you upload to our Website
   • Professional or employment-related information, for example, from employment candidates
   • Inferences drawn from other personal information, for example, consumer profiles reflecting certain preferences, characteristics and behaviour
2. Business or Commercial Purposes Of Collecting And Use Of Your Personal Information. Please see Section 3 of our Privacy Policy
3. Source Of Personal Information. Please see Section 2 of our Privacy Policy.
4. Disclosure Of Personal Information. We do not sell your personal Information. CCPA defines “sale” of personal information as exchange of personal information for money or valuable consideration. In the preceding 12-month period, we do shared the categories of personal information we collected (as set forth in Section A above) with third parties for business or commercial purpose. The third parties includes service providers, business partners, advertising partners and other trusted third parties. Please see Section 4 of our Privacy Policy for more details.
5. California Consumer Rights. As a California consumer, you have the rights to request:
   • access to your personal information that we have collected in the last 12 months, and additional information about our privacy practices, such as the categories of personal information we collected, how we collect such information, the business or commercial purpose to collect such information, how and who we share your personal information, the categories of personal information that we disclosed and sold and the categories of third parties to whom the personal information was disclosed and sold the past 12 months. You may make this request twice for each 12-month period.
   • obtaining a copy of your electronical personal information in a readily usable format
   • obtaining certain information about our disclosure of personal information to third parties for their direct marketing purposes (“Shine the Light” Law (California Civil Code Section § 1798.83))
   • deletion of your personal information that we have collected. We may need to keep certain information for our legitimate business purpose or as required by applicable law, but we will use commercial reasonable efforts to honor your request.
   • Opt out of disclosure and sales of your personal information to third parties
   • using an authorized agent designated by you to make requests under CCPA. Your agent must provide us with a copy of a signed written authorization or power of attorney authorizing the agent to act on your behalf. We will take step to verify that the agent has been duly authorized.
   • Not to receive discriminatory treatment for the exercise of any of your CCPA rights
6. You may exercise your California consumer right by sending an email to us ([email protected]) with a subject of “California Privacy Right”. As we are required under California law to verify that you are the person about whom we collected personal information, please provide us with your name and email address. We may also contract you asking for certain information for verification purpose. We will not discriminate against you if you choose to exercise your rights under the CCPA.