PRIVACY POLICY

1. SONDER LIVING’S APPROACH TO PRIVACY

1.1 This Privacy Policy of Sonder Living Limited a company incorporated in Hong Kong with company number 1813535, with its registered office at 21/F, Vertical Square, 28 Heung Yip Road, Wong Chuk Hang, Hong Kong (“we”“our”“us”), describes the types of information we may collect when you visit our website www.sonderliving.com (the “platform”). We value the information you provide to us and want you to be confident that we are committed to protecting and respecting your privacy in accordance with the applicable data protection legislation (the “Data Protection Legislation”). This privacy policy (“Privacy Policy”) sets out how we collect, use and share information that identifies you or is associated with you (“personal data”).

1.2 For the purposes of the Data Protection Legislation, we are the data controller of the personal data we collect and process about you. If you have any questions related to this Privacy Policy, please use the contact details provided in Section 12 below to get in touch. In addition, you can contact our Legal Team at legal@rochdalespearsgroup.com.

1.3 You should also be aware that we use cookies to store and access information whilst providing access to our platform. You can find out more about our use of cookies in our Cookies Policy.

2. PERSONAL DATA WE COLLECT ABOUT YOU

2.1 We collect personal data from you when you voluntarily submit information directly to us or via our platform. This can include information you provide when you register to use the platform by submitting your email address, visit one of our stores/showrooms, visit us at trade shows, log in into our wifi using your personal information at one of our showrooms, complete a form, apply for credit terms, provide feedback or reviews on our products or platform, enter competitions through our platform, correspond with us, purchase products advertised on the platform, subscribe to our email lists or respond to surveys or promotions. Other personal data is collected indirectly, for example your browsing activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.

2.2 The categories of personal data we collect include the following:

  • (a) Personal details: name, age/date of birth and gender
  • (b) Contact details: Such as your email address, your telephone number (including mobile numbers) and addresses(including billing and delivery addresses).
  • (b) Comments and opinions: Such as, comments and opinions you share on our services, when you provide feedback or reviews on our products or platform, or when you respond to our surveys, competitions and promotions.
  • (c) Messages to us: Messages you send to us at info@sonderliving.com, marketing@sonderliving.com, sonder@sonderliving.com, to our Facebook page or to our Instagram account or via the contact form on the ‘About Us’ section of the platform or any other such emails and written correspondences sent to us using our services.
  • (d) Payment and transaction information: Records of the products and services you purchase from us and the payment method, and credit/ debit card details, you use for the transaction.
  • (e) Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location but this will be no more precise than the city, state or country you are using your device in.
  • (f) Log Files: our platform’s web server collects and saves the default information customarily logged by World Wide Web server software. Our logs contain the following information for each request: date, time, originating IP address and domain name, object requested, and completion status of the request. We use these logs to help improve our service by evaluating the level of demand for our platform and detecting any errors on the site that might occur. These logs may be kept for an indefinite length of time and used at any time and in any way necessary to prevent security breaches and protect the integrity of the data on our servers.
  • (g) Information from fraud prevention organizations: Where permitted by law, if fraudulent activity is suspected relating to your account, we may be provided with information by credit reference, fraud and crime prevention organizations.

2.3 We also automatically collect personal data indirectly from you such as information about the pages you look at on the platform or the device you connect to the platform with, or the products you add to your favorites list/cart using a tablet or similar device in one of our showrooms.

2.4 We may also collect personal data about you from Facebook or Instagram: When you send messages to our Facebook page or Instagram account, the received information includes profile information such as your user name and photo and other information from that service as permitted by you and that service.

2.5 We are committed to protecting the privacy of children. Our platform is not intended for children and we do not knowingly collect data relating to children.

2.6 This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.

3. HOW WE USE YOUR INFORMATION

3.1 We will also use your personal data for the purposes specifically described below:

  • (a) Contact details: we will use your contact details so that we can communicate with you directly via phone, SMS messaging, or email, in particular, about queries, issues, problems we have detected or concerns you have. We may also use your contact details to send you information about similar products and services that we think may be of interest to you (such communications will be in accordance with your marketing preferences as explained in more detail in Section 5 below).
  • (b) Payment and transaction information: we will use payment and transaction information you provide to process payment for any product or service you purchase from us. We may also use the history of your transactions with us to determine similar products and services that may be of interest to you.
  • (c) Messages to us: we will use messages you send to us to help us respond to any query, issue or concern you raise and to provide our services to you.
  • (d) Information about products you have looked at: we use this information to send you reminders and further information about these products. We will also use this information to determine similar products and services that may be of interest to you.
  • (e) Information about how you use and connect to the online service: we use this information to present the platform to you on your device. We will also use this information to determine similar topics, products and services that may be of interest to you.
  • (f) Information about your location: we may use an approximate location to ensure content on the platform is relevant to the city, state or country you are using your device in. We will not collect or track your precise location without your consent.
  • (g) Information about fraudulent activity relating to your account: we will use information about fraudulent activity relating to your account for the purposes of preventing fraud or crime.
  • (h) All personal data on an aggregated basis: we will use all the personal data we collect to: (i) monitor and improve the platform and our procedures and processes; and (ii) to help us develop new products and services.

3.2 We may anonymize and aggregate any of the information we collect (so that it does not identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the platform, developing new products and features or displaying information about the purchases made via our platform such as the most popular purchases or purchases based on an approximate location.

3.3. We process your personal data (i) with your consent, (ii) when we need to do this to fulfill a contract with you (for example, the contract of sale), (iii) where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation), and/or (iv) when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in offering and providing our products and services, deter fraud and carry out direct marketing.

4. INFORMATION WE SHARE WITH THIRD PARTIES

4.1 We may share your personal data with the following parties:

  • (a) Companies in the same group of companies as us: our subsidiaries (i.e. any organization we own or control) or our ultimate holding company (i.e. any organization that owns or controls us) and any subsidiaries it owns. These companies will only use your personal data in the same way as we can under this Privacy Policy.
  • (b) Service providers, partners and advisors: third parties who provide a service to us, partner with us on certain business activities, advise us or that we work within other business capacities. For example, we use a third party delivery service to deliver any products you buy to your postal address. We may also pass your personal data to our marketing and other business partners and other carefully selected third parties who may wish to offer you other goods or services that we or they have identified as likely to be of interest to you. These third parties will only be allowed to use your personal data in accordance with our instructions or your marketing preferences (where applicable) and will be required to keep your information secure.
  • (c) Purchasers of our business: personal data may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of the sale.
  • (d) Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal data to or who we need to disclose your personal data to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.

4.2 We do not disclose personal data to anyone else except as set out above, where permitted by law and/or with your consent. We may provide third parties with aggregate statistical information and analytics about users of the platform but we will make sure that no one can be identified from this information before we disclose it.

5. MARKETING AND ADVERTISING

5.1 Email Marketing – From time to time we may contact you by email with information about our products and services which we think you may be interested in. Thereafter, if you do not want us to send you email marketing, please use the contact details provided in Section 12 below. You can also unsubscribe from our marketing emails at any time by clicking on the unsubscribe link in the emails we send to you.

5.3 Email Notifications About Your Order or Changes to the Services We Provide – We may send you email notifications in relation to your order or changes to the way we provide our services to you.

5.4 Advertising on the Site and other social media websites – We, or our advertising partners, may show advertisements to you on our platform or on other platforms. To do this we, or our advertising partners, may collect information about how you use the platform or the types of other web pages, content and ads you, or others who are using the device you connect to the platform, interact with, visit or view. The information collected might also include the IP address of the device you connect to the platform or the e-mail address you provide to us or our platform. We, or our advertising partners, use the information that is collected to make sure adverts you see either on the platform or other platforms or apps (where our partners have advertising space) are more relevant to you.

5.5 The techniques our advertising partners use recognize the device or e-mail address you are using. Typically, cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our Cookies Policy.

6. STORING AND TRANSFERRING YOUR PERSONAL DATA

6.1 International Transfers of your Personal data: the personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in, including, in particular, outside the European Union. Some of these jurisdictions offer differing levels of protection in respect of personal data and may, in certain instances, be less protective than the jurisdiction you are resident in. We ensure that your personal data is treated securely and in accordance with this Privacy Policy.

6.2 We put in place European Commission approved standard contractual clauses or rely on alternative transfer mechanisms to protect this data. A copy of these clauses is available for your review upon request to us using the contact details provided in Section 12 below.

7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

7.1 You may have various rights with respect to our use of your personal data:

  • (a) Marketing: As stated above in Section 5, you may opt-out of receiving such emails from us by using the contact details provided in Section 12 below, or by clicking on the unsubscribe link in the emails we send to you.
  • (b) Cookies: Please see our Cookies Policy for more information about your rights as regards our use of cookies.
  • (c) Access, rectify, port, block, complete, delete and update: You have the right to access, rectify, block, port, complete, delete and update your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data.
  • (d) Object: In certain circumstances, you also have the right to object to the processing of your personal data by us.

7.2 You can exercise the above rights by contacting us using the details provided in Section 12 below at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.

7.3 There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.

7.4 We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the competent data protection authority.

7.5 When we ask you to supply us with your personal data we will make it clear whether the data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

8.1 We will retain your information, whether or not your account is active, for as long as we believe it is necessary to fulfill our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

9. LINKS TO THIRD PARTY SITES

9.1 The platform may, from time to time, contain links to and from third party platforms of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these platforms, please note that these platforms have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those platforms.

10. CHANGES TO THIS POLICY

10.1 We may update this Privacy Policy from time to time, and when we do so we will update the “last modified” date at the top of this Privacy Policy. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

11. NOTICE TO YOU

11.1 If we need to provide you with information about something, whether for legal, or business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the platform. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.

12. CONTACTING US

12.1 Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to marketing@sonderliving.com or Sonder Living Limited, Vertical Square 21/F, 28 Heung Yip Road, Wong Chuk Hang, Hong Kong Attn: Marketing Team.

II. COOKIES POLICY

Last updated: 23 July 2018

1. SUMMARY

This cookies policy explains what cookies are and how Resource Decor Limited (“we”“us” or “our”) uses them on www.sonderliving.com (our “platform”). We encourage you to read the policy in full so that you can understand what information we collect using cookies and how that information is used.

2. WHAT ARE COOKIES OR SIMILAR TECHNOLOGIES?

Cookies (or similar technologies) are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a platform. Cookies can be recognized by the platform that downloaded them — or other platforms that use the same cookies. This helps platforms know if the browsing device has visited them before.

3. WHAT ARE COOKIES USED FOR?

Cookies do lots of different jobs, like helping us understand how our platform is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies can also help ensure information and advertising you see online is more relevant to you and your interests.

4. WHAT TYPES OF COOKIES ARE USED BY SONDER LIVING?

The types of cookies used on our platform can generally be put into one of the following categories: strictly necessary; analytics; functionality; advertising; and social media. You can find out more about each of the cookie categories in the table below.

Strictly Necessary Cookies These cookies are essential to make our platform work. They enable you to move around the platform and use its features. Without these cookies, services that are necessary for you to be able to use our platform such as accessing secure areas cannot be provided.
Analytics Cookies These cookies collect information about how people are using our platform, for example, we use Google Analytics cookies to help us understand which pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages. Overall, these cookies provide us with analytical information about how our platform is performing and how we can improve it.
Functionality Cookies These cookies allow us to remember choices you make and tailor our platform to provide enhanced features and content to you. For example, these cookies can be used to remember your user name, language choice or country selection, they can also be used to remember changes you’ve made to text size, font and other parts of pages that you can customise.
Advertising Cookies These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a platform and this information may be shared with other organisations such as advertising partners. This means after you have been to our platform you may see some advertisements about our services elsewhere on the Internet.
Social Media Cookies In order to enhance your internet experience and to make the sharing of content easier, some of the pages on our platform may contain tools or applications that are linked to third party social media service providers such as Facebook, Instagram, Vimeo or Pinterest. Through these tools or applications the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s platform for further details about how they use cookies.

5. HOW LONG WILL COOKIES STAY ON MY BROWSING DEVICE?

The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted.

6. FIRST AND THIRD-PARTY COOKIES

“First party cookies” are cookies that belong to us and that we place on your device. “Third-party cookies” are cookies that another party places on your browsing device when you visit our platform. You should check the third party’s website for more information about how they use cookies.

7. HOW TO MANAGE COOKIES FROM THIS PLATFORM

You can usually use the browser that you are viewing this platform through to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the platform and other parts of the platform may also not work properly.

You can find out more information about how to change your browser cookie settings at www.aboutcookies.org.uk .

Some third parties may use Advertising Cookies to help gather information about your browsing activity so that they can deliver platform advertising to you that is relevant to your interests. The advertising industries in EU have developed schemes to help you opt-out of receiving cookies used for these purposes. You can find out more about the EU scheme from www.youronlinechoices.eu .

8. CHANGES

Information about the cookies used by us may be updated from time to time, so please check back on a regular basis for any changes. The last modification date of this document is shown at the top of this page.

9. QUESTIONS?

Questions, comments and requests regarding this Cookies Policy are welcome and should be addressed to marketing@sonderliving.com or Sonder Living Limited, Vertical Square 21/F, 28 Heung Yip Road, Wong Chuk Hang, Hong Kong Attn: Marketing Team.