We recognize the importance of your privacy and maintaining the confidentiality of your personal information. This Privacy Policy applies to all products and services provided by us and sets out how we may collect, use and disclose your personal information. This Privacy Policy is governed by and observes the requirements of the Data Privacy Act of 2012 (Republic Act No. 10173) (the "Act").

A. PERSONAL INFORMATION COLLECTION STATEMENT

A.1.1 Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our products and/services and to protect any account(s) you hold with us.

A.1.2 We may ask you to provide personal information when you use our website. The data ("Personal Information") that we may ask you to supply includes without limitation to salutation, name, day and month of birth, gender, telephone number, fax number, email address, residential/other address, payment account details and where applicable, your Loyalty Card (i.e. Go Rewards, Robinsons Rewards Card, Fresh, Marketplace, Star Sapphire, Wiseclub and Elite) number.

A.1.3 Please note that it is mandatory for you to provide certain categories of Personal Information (as specified at the time of collection). In the event that you do not provide any Personal Information indicated as mandatory, we may not be able to provide you with our products and/or services.

A.2. USE AND DISCLOSURE OF PERSONAL INFORMATION

A.2.1 If you provide any Personal Information to us, you are deemed to have authorized us to collect, retain and use personal information about you for the following purposes:

(a) providing you with customer service including but not limited to processing and effecting sales, orders, refunds and exchanges relating to products available for sale in our shops or through our website, and delivery services, putting together shopping lists for you, providing you with a more personalized experience on our website and responding to your queries, feedback or claims;

(b) providing you with rewards under our redemption programme(s);

(c) providing you with our promotional materials (including but not limited to updates to our website), discount vouchers and wellness information;

(d) performing research or statistical analysis in order to improve our products and services and for marketing and promotional purposes;

(e) verifying your identity;

(f) operating, processing, maintaining and/or managing your Loyalty Card account (where applicable); and

(g) making such disclosures as may be required for any of the above purposes or as required by law or in respect of any feedback or claims made by you.

A.2.2 You further agree that we may disclose or transfer (whether in the Philippines or abroad) in connection with the purposes stated inA.2.1, your Personal Information to Dairy Farm International Holdings, Limited, Jardine Matheson, Limited, any of their respective subsidiaries and affiliates, as well as tothird party service providers engaged by us to assist with providing you with our services (including data entry, managing our customer database, processing, effecting and verifying sales, orders, refunds and/or exchanges relating to products available for sale in our shops or through our website, contacting you regarding promotions, delivery services, and other customer service)(collectively, “Third Parties”).

These Third Parties are:(i) under a duty of confidentiality to us,(ii) only permitted to use your Personal Information in connection with the purposes specified at A.2.1 above, and not for their own purposes (including direct marketing), and (iii) required to observe the diligence mandated by the Act in processing your Personal Information.

A.2.3 When necessary we may also disclose and transfer (whether in the Philippines or abroad) your Personal Information to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations for purposes specified at A.2.1(g) above.

A.2.4 We may only use your name, phone number, residential/other address and email address with your consent or with your indication of objection to provide marketing materials to you relating to goods and services provided (a) in our retail stores (including Shopwise, Shopwise Express, Marketplace by Rustans, or Wellcome) ; (b) other business units owned and operated by The Dairy Farm Company, Limited Jardine Matheson, Limited, or any of their respective subsidiaries and affiliates. Such goods and services for each of the foregoing shall include the following classes: retail, cosmetics and beauty, health, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, betting (lucky draw), dining, travel, transportation, banking, electronics, home, household, textile, tele-communication, food and beverage, grocery, office and business supplies, technology, outdoor, furniture, lighting, décor, media (including digital), e-commerce platform and facilitator (including online trading, payment and auctions), and publications.

A.2.5 We may share aggregate data that does not allow you to be identified with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services.

A.2.6 Any personal information supplied by you will be retained by us and will be accessible by our employees, any Third Parties referred to at A.2.2 above, for or in relation to any of the purposes stated in A.2.1 herein.

A.2.7 We may permit individuals who are employees of Rustan’s Supermarket or other business units owned and operated by Rustan Supercenters, Inc. (including those stated above) ("Members") to use Rustan’s Supermarket account but such Members must at all times comply with all applicable codes of conduct and/or other relevant company policies of their employer when using Rustan’s Supermarketaccount. Notwithstanding anything stated herein, in the event it is found that a Member misuses Rustan’s Supermarket account in his/her capacity as a Member (including but not limited to using any confidential or other similar insider information to obtain an unfair advantage from any promotions or offers offered by Rustan’s Supermarket), we may disclose or transfer the Personal Information provided by such Member to his/her employer for investigation and/or disciplinary purposes.

B. CONFIDENTIALITY

B.1 Personal Information held by us relating to our online customers or to visitors to our websites will be kept confidential in accordance with this Privacy Policy.

B.2 Any questions, comments, suggestions or information other than Personal Information sent or posted to the site, or any part of the site, by visitors will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development, manufacture and marketing of products and services and to meet customer needs.

C. SAFETY OF PERSONAL INFORMATION

C.1 All reasonable efforts are made to ensure that any Personal Information held by us is stored in a secure and safe place, and accessed only by our authorized employees or authorized Third Parties.

C.2 You should be aware that no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet.

D. LINKS

D.1 This site may contain links to other sites and pages which are operated by third parties. We have no control over the content of the linked websites or the way in which the operators of those websites deal with your Personal Information. You should review the privacy policy for those third party websites to understand the ways in which your Personal Information may be used by those third parties.

E. INFORMATION COLLECTED WHEN YOU USE OUR WEBSITE

We may use 'cookies' on this site in order to:

Cookies are pieces of information stored in your hard-drive about your preferences on our site, which enable the site to be tailored to you in future visits. Customers who want to disallow cookies can do so on their web browser. However, by disabling cookies you may not be able to access all parts of our website.

F. RIGHT TO ACCESS/ CORRECT PERSONAL INFORMATION

F.1 Under the Act, you have the right of access to personal information held by us and to request correction of the information.

F.2 If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Information, you may send your request in writing to the following address:

Data Protection Officer

Robinsons Retail Holdings, Inc.

110 Eulogio Rodriguez Jr. Ave, Bagumbayan,

Quezon City, 1110 Metro Manila, Philippines

F.3 In accordance with the Act, we reserve the right to charge you a reasonable fee for the processing of any data access request.

G. AMENDMENTS

G.1 We may amend or update this Privacy Policy from time to time and all information will be governed by our most recent Privacy Policy, available on our website.