THANN – VIP Membership

Personal Data (Privacy) Ordinance – Privacy Policy & Personal Information Collection Statement (the “Statement”)

(Last Update: 15^th July 2026)

WLS Limited (“We”) respects the privacy of each VIP member (“VIP Member”). We will do our best to ensure the collection, usage, storage, transfer and disclosure of your personal data according to the Personal Data (Privacy) Ordinance (Cap. 486). We will also ensure that our employees comply with the requirements of this Statement. This Statement explains our policies and practices on handling personal data.

1. Our Privacy Promise

• We respect your privacy and your choices;
• Save prior consent has been obtained from your good self, we will not send you any marketing communications. You may change your stance towards acceptance of any marketing communications at any time;
• Save prior consent has been obtained from your good self, we will not sell or offer to sell your personal data;
• We are committed to keeping your personal data safe and secure;
• We are committed to being open and transparent about our data collection practices, usage and sharing; and
• We respect your rights and we will use our best endeavours to accommodate your reasonable requests with respect to your personal data.

2. Types of Personal Data Collected

“Personal Data” refers to any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. membership ID number). Personal data includes but not limited to your name, gender, nationality, date of birth, age, personal identification number, address, phone number, email address, credit card details and earnings. Failure to provide such data and/or provision of incomplete or inaccurate data may prevent us from providing certain services under THANN – VIP Membership scheme to you.

If you are under 18, you must obtain prior consent from your parents or guardians before disclosing any of your personal data to us.

3. Purpose for Data Collection & Use of Personal Data

We might collect or receive data from you when you apply for THANN – VIP Membership via our forms, when you make any purchase of THANN products from us or when you join our promotion campaign. You may also be asked to provide or share with us your Personal Data directly (e.g. when you create an account at our website, when you contact us directly, when you make a purchase order from our website, physical stores or our beauty sanctuary).

Certain Personal Data is required to be provided on a mandatory basis if you wish to receive full services under THANN – VIP Membership scheme from us. These kinds of personal data will be marked with asterisks “*”/marked as “mandatory” in our VIP Membership application Form and you MUST provide your personal data to us if you want to receive service for which you are applying.  If Personal Data is only required on a voluntary basis, it will not be marked with asterisks“*”/marked as “mandatory” and you could reserve your right not to provide such information to us. Nevertheless, we may not be able to provide all of the following listed services in the event that certain Personal Data is not provided:-

• creating, managing and contacting you about your THANN VIP membership and the available VIP members’ rewards (including enquiries and implementation on loyalty points accrual or redemption);
• Accumulating loyalty points as our VIP member;
• Communicating to you your entitlements and privileges as our VIP member;
• Redemption of privileges as a VIP member;
• Notification of any amendment to the VIP membership program;
• Data cleansing and customers profile updates; and
• Other continuous customer support services in relation to your membership.

We might use the Personal Data provided by you (whether on an mandatory and/or voluntary basis) to enable us to provide the following additional services to you and/or carry out the following activities:-

• fulfilling, managing and contacting you about your purchase of our goods, treatments and/or services via our website or physical stores;
• creating, managing and contacting you about your THANN - VIP Membership and member rewards (including enquiries and implementation on loyalty points accrual or redemption);
• Market research;
• For internal research and analysis to enable us to provide rewards, services and product information or offerings better tailored to your needs;
• To enable our beauty ambassador/consultant to follow up;
• To distribute customer satisfaction surveys;
• To send our THANN – VIP Membership newsletters and THANN – VIP Membership updates;
• For direct marketing purposes (subject to any written consent you may provide) ;
• To discharge or perform any duties/obligations required under the applicable laws and regulations;
• To verify your identity for the purpose of performing the abovementioned purposes

(Collectively the “Purposes”).

We may contact and communicate with you by phone call, SMS, email or mail.

4. Where We Store Your Personal Data

Personal Data collected from your good self by us may be transferred to and stored at a destination outside Hong Kong Special Administrative Region. It may also be processed by employees operating outside the Hong Kong Special Administrative Region who work for us or our service providers. We will use our best endeavours to ensure the transfer or disclosure of Personal Data outside Hong Kong Special Administrative Region will be conducted in a safe and legal manner.

Given that certain countries/regions may not have enacted any legislation governing the use and transfer of personal data. In this regard, we will take all necessary steps to make sure that recipients of the Personal Data will adhere to the commitments set out in this Statement, in particular, reviewing the recipients’ privacy policy and entering into the necessary contracts safeguarding your interest with respect to the Personal Data.

5. Retention of Personal Data

We will keep your Personal Data only for as long as necessary to fulfill the Purposes.  We will keep a record of all our transactions with you in the course of our business for a reasonable period of time for review and verification purposes pursuant to our internal policy.  Personal Data collected by us will be destroyed when the Personal Data is no longer necessary (e.g. after you have cancelled your THANN – VIP Membership) and we are no longer required to comply with our obligations under the applicable laws and regulations.

6. Disclosure of Personal Data

When we collect Personal Data, we will:-

• Inform you (by way of this Statement or by a separate notification) that we are doing so and the purpose(s) for which we will use the personal data collected;
• Where relevant, give you the opportunity to opt out; and
• Tell you how we will store your personal data and how you can review, change and delete the personal data we have stored.

All personal data collected and held by us will be kept confidential but we may provide and/or disclose such information to the following parties (whether within or outside Hong Kong (China) for the Purposes:-

• Any member companies, subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with WLS Limited;
• Any agent, contractor or third party service provider (“Third Party Service Providers”) who provides administrative, IT, telecommunications, web-hosting, computer, targeted advertising and other services (for the purpose of maintaining and supporting our databases) to us in connection with the processing and storage of your data. For the avoidance of doubt, our Third Party Service Providers are under a duty of confidentiality and are contractually bound to use your personal data in connection with the Purposes and not for their own purposes (including direct marketing).;
• Advertising, marketing, digital and social media agencies to help us to deliver advertising, marketing, and campaigns, to analyze their effectiveness, and to manage your contact and questions;
• In the event that we sell any business or assets of WLS Limited, we may be required to disclose your Personal Data to the potential buyer of such business or assets. If WLS Limited or a part of its assets is acquired by a third party, Personal Data held by us regarding its assets will form part of the transferred assets. In such case, the buyer being a new data user will process such Personal Data pursuant to its privacy policy.
• Any actual or proposed assignee, transferee or successor of WLS Limited; and
• Government or regulatory authorities, law enforcement agencies or other organizations as required or authorized by law.

We rely on the Third Party Service Providers to assist our business operations. In order to allow the Third Party Service Providers to discharge their respective duties, it is inevitable for us to disclose part of the Personal Data to certain Third Party Service Providers. That said, we will ensure only information that is requisite for the Third Party Service Providers will be provided and we will request the Third Party Service Providers not to use the Personal Data disclosed to them for any purpose other than performing their duties.

7. Use of Data in Direct Marketing

We may also use your personal data, including name, telephone number, address and email for direct marketing. Pursuant to Personal Data (Privacy) Ordinance (Cap. 486), we may not use your personal data for this purpose unless we have received your prior consent.

Subject to your consent, Your Personal Data may be used for the following purposes for direct marketing:-

• Communicating to you regarding new product launch and other promotional offers, including where applicable, aromatherapy oil, aromatherapy candles, skincare products, cosmetics products, make-up products, beauty health supplements, body care products, make up services, body care services and facial services;
• Communicating to you regarding our promotional events including where applicable, makeup classes and/or demonstrations, skincare seminars, other beauty classes, Public Relation events, VIP gatherings, value sets, shop opening events, store announcement/ events, exhibitions, fashion shows and news update;
• Communicating on-counter or out-of-counter services and events related to skincare, makeup or beauty services for promotion or reward purposes;
• Marketing reward programs, birthday celebration offers, free sampling, digital campaigns, roadshow/ outpost, in-store promotion updates;
• Communicating joint promotion or events with shopping malls, department stores, credit cards, banks, trades, celebrities, magazines, television, websites, mileage programs, cultural, art or musical societies/ organizations, charities or nonprofit organizations; and
• Cross-brand joint promotions and/ or events with brands within WLS Limited.

If, at any time, you wish to unsubscribe or opt out of our direct marketing communication, you may contact us via email (email address: info@thann.com.hk).

8. Partners

We may share the Personal Data collected and held by us with our Partners. In this Statement, “Partners” refers to our business partners, venue hirers, service providers, online platforms and social media platforms. Notwithstanding the aforesaid, we will not share any of your Personal Data with the Partners without obtaining your prior consent.

In the event that you agree to receive direct marketing, promotion and commercial communications from our Partner through a dedicated opt-in, your Personal Data will be processed by our Partner acting as a new data user pursuant to its own terms and conditions and its privacy policy.

9. Security

All personal data provided by you will be properly stored in our customer service system and can only be accessed by authorized persons

10. Right to Access and Correction

You may at any time request access to and to correct your Personal Data collected and held by us. In this regard, you are entitled to request access, deletion and correction of your Personal Data by emailing our Customer Service Department via info@thann.com.hk.

You may also request us to delete you or your Personal Data from any active mailing or distribution list. If you no longer wish to receive any future promotional or direct marketing material from us, please contact us by email our Customer Department via info@thann.com.hk, and indicate that the email is communicated on a confidential basis. In response, we may ask you to provide certain Personal Data to ascertain the authenticity and validity of the request.