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PRIVACY NOTICE

Privacy Notice

Effective as of August 1, 2025

At PITANIUM ("we" or "us"), we believe in being clear and open about how we collect and use personal information related to you. In the spirit of transparency, this Privacy Notice provides you with information about the types of personal information we collect, how we use such personal information and to whom and under what circumstances we disclose it.

This Privacy Notice applies to personal information we collect from you, or that you provide to us, and communications from us, in connection with your use of our websites, our mobile applications (if available in your country), promotions in which we are involved, and social media. Please read this Privacy Notice carefully so that you understand your rights in relation to your personal information, and how we will collect, use, and process your personal information.

If you do not agree with this Privacy Notice in general or any part of it, you should not use our websites, or request material from us, as applicable.

If you are a California resident, please see the California Residents Privacy Addendum for additional information about our privacy practices and your rights as a California resident.

If you are resident of the European Economic Area (the "EEA") or the United Kingdom, please see the EU/UK Privacy Addendum for additional information about our privacy practices and your rights as a resident of the EEA or the UK.

What INFORMATION DO WE COLLECT, HOW DO WE COLLECT IT, AND HOW DO WE USE IT?

We collect information about you in many ways from many places. Some of the information we collect may include information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device ("personal information"). In some countries like those in the EEA or the UK or in states like California, things like IP address or cookie and mobile device identifiers may also be considered personal information. When we collect information from you, we indicate any information that you are required to provide to us, and the consequences of the failure to do so.

Whenever we use your personal information, we will have a reason to do this.

We use your personal information for one or more of the following business purposes:

  • to fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our brands or products, we will use that personal information to respond to your inquiry.
  • to provide, support, and develop our websites, products, and services;
  • to process your requests;
  • to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
  • to deliver requested news alerts via email (with your consent, where required by law);
  • to help maintain the safety, security, and integrity of our websites, mobile applications, products, and services, including to detect, prevent, or otherwise address fraud, security, or technical issues; and
  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.

In particular, in the table below, we explain:

  • what activity or scenario you are involved in when we use or collect your personal information;
  • what categories of personal information we collect when you take part in a particular activity;
  • what we do with your personal information, and the purposes for collecting and using it; and
  • solely for purposes of the General Data Protection Regulation (the "GDPR") (or UK equivalent) (which is only applicable to residents of the EEA or the UK, as applicable), our legal basis for using your personal information

What We Collect

News Alerts Identifiers that we collect, or you give us, when you sign up for our news alerts: your email address.

How We Use It

We use this personal information to: send you the requested news alerts; keep an up to date suppression list if you have asked not to be contacted; and run analytics, statistics, and research.

Our Legal Basis for Processing, Using, and Storing It for Purposes of the GDPR or the UK GDPR

We base this processing on: your consent to receiving the requested news alerts from us; and our legitimate interests—we have a legitimate business interest in improving our products and services.

What We Collect

Questions and Customer Service Identifiers that we collect, or you give us, when you communicate with us whether in person, through our websites, mobile applications, through via email, over the phone, through social media or via any other medium, including: your contact details including: your first and last name, mailing address, email address, social media account name, or whatever method you use to contact us; the details of your communications with us; and the details of our communications to you.

How We Use It

We use this personal information to: answer and manage your questions; and run analytics, statistics, and research.

Our Legal Basis for Processing, Using, and Storing It for Purposes of the GDPR or the UK GDPR

We base this processing on: performance of a contract—so that we can answer and manage your questions; and our legitimate interests—we have a legitimate business interest in (i) improving our products and services; and (ii) securing our tools.

What We Collect

Online Browsing Identifiers and internet or other electronic network activity that we collect through your use of our websites (which may be through cookies), including: Internet Protocol (IP) address; MAC address; browser type; operating system; device identifying personal information; the specific web pages visited during your connection; the domain name from which you accessed our websites; and your browsing behavior, such as the date and time you visit our websites, the areas or pages of our websites that you visit, the amount of time you spend viewing our websites, the number of times you return to our website, and other clickstream data. For more information on cookies, see "Cookies and Traffic Data" Section.

How We Use It

We use this information to: allow our websites to function properly (for example, to ensure the proper display of content); improve our websites (for example, by testing new ideas or layouts) ensure our websites are secure and safe, and to protect you against fraud or misuse of our websites or services (for example through performing troubleshooting); and run analytics, statistics, and research.

Our Legal Basis for Processing, Using, and Storing It for Purposes of the GDPR or the UK GDPR

We base this processing on: our legitimate interests—we have a legitimate business interest in (i) operating and improving our websites, products and services; (ii) preventing fraud; and (iii) securing our tools.

We obtain all of the above personal information directly from you.

Cookies and Traffic Data

Cookies

Certain cookies and web beacons that we employ are necessary for the operation of our website. Other cookies that we employ are not necessary for the operation of our websites but are employed to enhance your use of our websites and shopping experience.

Our cookies include session cookies (temporary cookies that identify and track users within our websites which are deleted when you close your browser or leave your session) or persistent cookies (cookies which enable our websites to "remember" who you are and to remember your preferences within our websites and which will stay on your computer or device after you close your browser or leave your session).

We use the following different types of cookies:

Strictly Necessary

These are cookies which are needed for our websites to function properly, for example, these cookies allow you to access secure areas of our websites or to remember what you have put into your shopping basket.

Performance

These cookies allow us to keep a record of traffic data, count visits, traffic sources, access rates, page hits and page views so we can measure and improve the performance of our website. They help us know which pages are the most and least popular and see how visitors move to and from and around our website.

You can find more general information about cookies and generally how to manage them at www.allaboutcookies.org and www.youronlinechoices.com.

Google Analytics

We use Google Analytics, which is a web analytics tool that helps us understand how users engage with our website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect details about how users use our website. This information is used to compile reports and to help us improve our website. The reports disclose trends without identifying individual visitors.

Google Analytics services are provided in Europe by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and elsewhere by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and other affiliated Google entities.

How Long Do We Keep Your Personal Information?

How long we retain your personal information depends on why and how we collected it and how we use it. We will keep your personal information for as long as we need it to provide you with your requested service(s) or to meet our commercial or legal obligations as explained further below.

To determine the retention period of your personal information, we consider several criteria to make sure that we do not keep your personal information for longer than is necessary or appropriate. These criteria include:

  • the purpose for which we hold your personal information;
  • our legal and regulatory obligations in relation to that personal information, for example any financial reporting obligations or statutory retention obligations (for example, under commercial or tax law which usually last from seven years);
  • whether our relationship with you is ongoing;
  • any specific requests from you in relation to the deletion of your personal information; and
  • our legitimate business interests in relation to managing our own rights, for example the assertion or defense of any claims within the statutes of limitation, which is usually three years to the end of a calendar year but can be up to thirty years.

When we no longer need to retain your personal information, it will be deleted or be anonymized so that you can no longer be identified from it.

Please note, that, other than in response to a request to delete your personal information, we have no obligations to notify you when deleting your personal information and can do it at our sole discretion.

GDPR / UK GDPR Privacy Rights

Accessing, Correcting, and Updating Your Personal Data

You have the right to access, correct, and update your personal information. If you wish to access, correct, or modify any personal information (or if you wish to know the purposes for which your personal information is processed, the categories of data processed, third party recipients, if any, of your personal information, or third party sources, if any, of your personal information), please contact us using the contact information detailed in the "Exercising Your GDPR Privacy Rights" section.

Requesting Copies of Your Personal Data (Portability Request)

You have the right to request copies of your personal information held by us in a structured, commonly used, and machine-readable format and/or request us to transmit this personal information to another service provider (where technically feasible). If you wish to request copies of your personal information held by us, please contact us using the contact information detailed in the "Exercising Your GDPR Privacy Rights" section.

Requesting We Delete Your Personal Data

You have the right to request that we delete your personal information. If you wish to request that your personal information is deleted, please contact us using the contact information detailed in the "Exercising Your GDPR Privacy Rights" section.

We will need to retain certain records, for example those relating to open orders, payments, or customer service matters, or for legal and accounting purposes.

Objecting to Processing of Your Personal Data

You have the right to object, for legitimate purposes, to the processing of personal information as provided under applicable law. If you wish to object to processing of your personal information, please contact us using the contact information detailed in the "Exercising Your GDPR Privacy Rights" section.

Requesting that We Restrict Processing

You have the right to request that we restrict processing of your personal information. If you wish to request that we restrict processing of your personal information, please contact us using the contact information detailed in the "Exercising Your GDPR Privacy Rights" section.

Withdrawing Consent

If you wish to withdraw your consent to receiving news alert emails, please follow the applicable procedure in the "Your Choices" section or, if not addressed, please contact us using the contact information detailed in the "Exercising Your GDPR Privacy Rights" section.

Please note that if you withdraw consent for a particular feature, we cannot provide or continue to provide certain services or communications to you and that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Exercising Your GDPR / UK GDPR Privacy Rights

To make any of the requests or exercise any of your GDPR / UK GDPR privacy rights, including your right to access or deletion, please contact us using one of following methods. We respond to all data protection requests we receive in accordance with applicable data protection laws.

You can exercise these rights yourself or you can designate an authorized agent to make these requests on your behalf. We will request that your authorized agent have written permission from you to make requests on your behalf (or that you otherwise directly confirm the agent has permission to submit the request) and we will need to verify your authorized agent's identity.

Via the Internet. If you wish to exercise any of your GDPR / UK GDPR privacy rights via our websites, please use the following link "Privacy Rights Request Form" (note that this link will take you to a request form for PITANIUM, Inc. (our main operating subsidiary). Please follow the instructions on the form to make your request.

By mail. If you wish to exercise any of your GDPR / UK GDPR privacy rights, you can write to us at the following address. Please include your full name, mailing address, and any email address associated with your activity with us and let us know which GDPR / UK GDPR privacy right you are exercising and that you are exercising your GDPR / UK GDPR privacy rights with respect to PITANIUM so that we can process your request or exercising of your rights in an efficient manner.

PITANIUM, Inc.
30/F, Gravity, No.29 Hing Yip Street, Kwun Tong, Hong Kong
ATTN: Legal Department
RE: EEA/UK Privacy Info

You may also contact us using the contact information detailed in the "Contact Us" section. When you contact us, please let us know that you are exercising your GDPR / UK GDPR privacy rights, which GDPR / UK GDPR privacy right you are exercising, and that you are exercising your GDPR / UK GDPR privacy rights with respect to PITANIUM so that we can process your request or exercising of your rights in an efficient manner.

Contact Us

If you have questions or concerns about this Privacy Notice, please contact us by webform, by phone at +852 62975255 (Weekdays 9:30am-5:30pm EST) or by email at us@pitanium.com.

You may also write to us at:

PITANIUM, Inc.
30/F, Gravity, No.29 Hing Yip Street, Kwun Tong, Hong Kong
ATTN: Legal Department
RE: Privacy Info