PRIVACY POLICY

UPDATED: DECEMBER 2015

In order to make your visits to the various online channels of Optiontech. as responsive as possible, we provide this summary of what information we collect online, and how that information is used.

This privacy policy statement applies only to the information collected online through optiontech.com.hk, optiontech . microsites or mobile sites (collectively our “Websites”), our communications, social media sites and accounts, or mobile applications that Optiontech. provides for download to your mobile device ("Apps") that expressly adopt, and display or link to, this policy.

CONTENTS

WHAT IS PERSONAL DATA

INFORMATION WE COLLECT ONLINE

MOBILE APPLICATIONS

INFORMATION COLLECTED ON PAGES OPTIONTECH HK. HAS ON SOCIAL MEDIA SITES

USING INFORMATION WE COLLECT

INFORMATION WE SHARE WITH THIRD PARTIES

DIRECT MARKETING

STORAGE OF INFORMATION

COOKIES AND ADVERTISING

CONSENT

OPT-OUT

ACCESSING AND UPDATING YOUR PERSONAL DATA

PRIVACY OF CHILDREN

LINKS

UPDATES TO PRIVACY POLICY

SECURITY STATEMENT

QUESTIONS ABOUT PRIVACY

WHAT IS PERSONAL DATA

This policy will more specifically address the personal data we collect, transfer, use, and disclose, which generally includes name, address, telephone number, email address, date of birth, billing and payment information, account information, and other information that specifically relates to you, which we collect in the course of providing our marketing and goods and services to you.

INFORMATION WE COLLECT ONLINE

1. GENERAL BROWSING

We collect general information about our visitors’ experience with our Websites/Apps and this general information is not connected to personally identifiable information about individual visitors. This general information (for example, domain type, browser version, service provider or your IP address) will provide us with information regarding the general use of our Websites/Apps. The information collected includes which pages our visitors are viewing on our Websites/Apps and whether visitors arrived through a link for our Websites/Apps. It also includes information on the type of browser and service provider used. For visitors using a mobile version of our Websites, this includes technical information about the device used, such as screen size, cookies supported by the device, and how images may appear. All of this information helps us provide a better experience for our visitors by being able to determine such things as how to best format our mobile Websites/Apps for various devices, our most desired pages, products and features, how to best direct visitors to our Websites/Apps, and where there might be browser or service provider connection issues.

2. LOCATION INFORMATION

Our Websites, Apps, and communications may use your IP address to determine the city where you are located. This allows us to tailor content to you, such as a map of nearby stores. Mobile devices include your cell phone, and could include your laptop or tablet depending on the type of wireless connectivity used. If you do not consent to location-based services, or if you disable such services, we may ask you to manually select the region where you are located, or to enter your zip code; if you choose not to provide this information, some features of the Websites, Apps or communications may not be available. See the “Opt-Out” section below for the choices you have regarding collection of location information.

3. PERSONAL DATA

CONTACT US AND CLICK TO CHAT

If you complete a general "Contact Us" form on one of our Websites, we may collect your name, email address, and any information that you provide in the text of your message.

If you use the "Click to Chat" feature on our Websites, we may collect your name and any additional personal data or other information that you provide throughout the communication.

SIGN UP FOR MARKETING EMAIL LIST

If you sign up for our marketing email list, or the marketing email list for any of our affiliate brands, you will be asked to provide your email address. Our affiliate brands are: Abercrombie & Fitch and abercrombie kids. Signing up enables you to receive information and offers about the clothing and accessories and other products that we and/or our affiliate brands provide via email. Consent is needed from you in order for us to send you marketing emails and you will be providing consent at the time you sign up. Once you sign up you will receive an email to the email address you submitted confirming you are subscribed. In some locations on our Websites/Apps, you are given the opportunity to submit additional information, such as gender and date of birth, that will help us cater messaging and marketing emails we send to you. In addition, we may identify you when you click a link in an email to get to our Websites, and may personalize messaging, promotions or product recommendations. You can choose the frequency with which you receive marketing emails or unsubscribe if you no longer want to receive marketing emails from us. See the "Opt- Out" section below for more details.

If you were on the Optiontech HK. marketing email list prior to September 2014 and supply your email address on Optiontech.com.hk.hk you may receive emails catered to your location.

MY ACCOUNT

You are given the opportunity to create an account on our Websites and Apps. Creating an account requires you to enter your email address, first and last name, and to create a password, and allows you to provide postal addresses, a phone number, payment details, date of birth, gender, and favorite categories. By providing this information we are able to offer you a more personalized experience on our Websites, Apps, and in communications. In addition, we may identify you when you sign into your account and we may personalize messaging, promotions or product recommendations. Some of the features in the account section allow you to create an address book, save a wish list, subscribe to and update your marketing email frequency, access your order history, and enjoy "quick checkouts" by having us automatically enter your name, phone number, email, postal address, and payment details in the checkout process. When you create an account you will receive a welcome email that will be delivered to the email address you inserted into the email field on the create an account page.

To request to have your account cancelled, send an email to PRIVACY_POLICY@OPTIONTECH.COM.HK from the email address associated with the account you wish to cancel.

MY ACCOUNT – PAYMENT INFO

If you choose to add a payment type in the account section, you will be able to access this information during checkout when you are signed in. Your preferred payment type will pre-populate during checkout, or you can pick another type by selecting from the drop down list if you choose to save several payment types. If a payment card has expired we will indicate this by highlighting it in red on the Payment Info page, and you can remove this expired payment type and insert a new one if desired. You will have the option to add a new payment type during checkout by ticking a box indicating that you want to store the newly entered payment details in your account. If you reset your account password, your payment types will be deleted from your account for security purposes.

MY ACCOUNT – ADDRESS BOOK

If you have created an account on our Websites or Apps, you may use the personal address book which allows you to save all of the different names and addresses to whom you frequently send purchases or gifts. When you want to send a purchase to someone in your address book, sign into your account and once in checkout you can choose from the saved address list.

MY ACCOUNT - FORGOT PASSWORD

If you forget your password and select to reset it you will be asked to insert the email address for your account so we can send you an email. Once you receive the email, click on the link provided and when you are directed to the Website, enter and submit a new password that meets the requirements to reset it.

MY ACCOUNT - UPDATE INFORMATION

When you sign into your account you may be directed to an update information page. In order to proceed to your account you will be required to insert your first and last name, enter a password that meets the requirements, and agree to the legal terms as stated on this page. In addition, if you fill out the needed information on this page and submit it, and you have previously signed up to receive marketing emails from us, you will now receive marketing emails catered to your location.

SOLD OUT OR PRODUCT EMAIL ALERT

If you provide us with your email address to contact you when a product on the site is available for purchase or to show interest in a product, the email address you submit will only be used for such purpose. The email address will not be used for any additional promotional purposes by us or our affiliate companies, and will be purged after the email(s) are sent or if there is no longer a need to maintain the data. You will, however, be able to sign up to receive marketing emails via a link in the footer of the product alert email that you may receive.

PURCHASING AT THE ONLINE STORE

If you purchase merchandise through our Websites, we will gather your personal data (including your name, billing and shipping address information, email address, telephone number, and payment information), as well as information about your purchases on our Websites, which we may combine with your store purchase information. In addition, if you have created an account you will be able to view your order details in the account section. Some information provided in checkout may be used to personalize a future visit or communications or to cater products or offers to you.

SURVEYS

We will collect information when you fill out a survey offered on our Websites or in communications. This information will assist us in gathering feedback from you in order to improve our services and continue to offer features that you prefer.

SOCIAL MEDIA ACCOUNTS

To create an account on our Websites/Apps or to participate in certain features, our Websites/Apps may allow you to choose to let us access information from accounts you have created on social media sites such as Facebook, Twitter, Pinterest, Instagram, and other similar sites (“Personal Social Media Accounts”). If you choose to allow us access to your Personal Social Media Accounts, Optiontech HK. could collect some, and possibly all, of the data in the Personal Social Media Account to which you grant access. Depending on the terms of the social media site, this information could include: your name, email address, profile picture, gender, networks, user ID, list of friends, date of birth, likes, education history, work history, current city, hometown, interests, relationship status, and location. Once you grant this permission, Optiontech HK. will be able to continue to be linked to the permitted Personal Social Media Account and collect information without a further request for permission, which could include later revisions to existing information or new types of information that you add. If you no longer want your Personal Social Media Account(s) linked to our Websites/App, click on the ‘disconnect’ link located on our Websites/App near the corresponding social media button and we will stop collecting this information. You may also be able to stop our ability to link to information in your Personal Social Media Account by following instructions provided on the applicable social media sites.

This privacy policy does not cover the privacy and security practices of social media sites where you have Personal Social Media Accounts. Please review privacy policies and terms of service on the social media sites if you have any questions about their privacy or security practices.

INVESTOR EMAIL ALERTS

Our Websites offer investors the opportunity to sign up for email alerts, which are messages that are conveniently delivered to your email box whenever certain new company information is posted to our Websites. To receive these email alerts, investors must provide their email address, upon which they consent to the processing and transfer of their personal data for this purpose.

INVESTOR ELECTRONIC DELIVERY OF PROXY MATERIALS

If you are an investor and elect to sign up to receive your proxy materials via electronic document delivery, any personal data that you provide will be collected and sent directly to Broadridge Financial Solutions, Inc. in the United States, our third party service provider.

MOBILE APPLICATIONS

We offer Apps for download to your mobile device that provide you with various interactive features.

The collection and means of collecting information, as well as the use and sharing of information, through any currently existing or future App are discussed in this policy.

In addition:

Use of some features of an App will ask for permission to access data on your mobile device, such as your photos. We will only access this data if you provide consent when asked by the App. Please note, some features of the App are only available if you allow us to access the requested content

If you provide consent when asked, the App will send push notifications ("Notifications") to your mobile device. These Notifications can be sent to you and viewed by you even if you are not actively using the App. The Notifications may be specific to your interactions with us and may be location-specific if you have consented to location-based services.

See the "Opt-Out" section below for the choices you have regarding collection of location information and data from your mobile device, and receipt of Notifications.

INFORMATION COLLECTED ON PAGES OPTIONTECH HK. HAS ON SOCIAL MEDIA SITES

Personal information may be collected directly by Optiontech HK. through social media sites (“Social Media Pages”) and may also be collected by the social media site hosting the Optiontech HK. Social Media Page.

Personal Information collected directly by Optiontech HK.: The collection of personal information directly by Optiontech HK. on our Social Media Pages will include the type of information addressed under the "What is Personal Data" section above. Examples of how personal information may be directly collected on Optiontech HK. Social Media Pages include providing information through an application or form which has a link to this privacy policy. We will use and share the information we collect on our Social Media Pages in the manner specified below in the "Using Information We Collect” and "Information We Share With Third Parties" sections. Please refer to the "Direct Marketing" section below for details in relation to the use and provision of personal data for direct marketing purposes.

Personal Information collected by the social media sites: This privacy policy does not cover the privacy and security practices of the social media sites on which Optiontech HK. has Social Media Pages. Please review privacy policies and terms of service on the social media sites if you have any questions about their privacy or security practices.

The social media sites where Optiontech HK. has Social Media Pages may provide aggregate information and analysis to Optiontech HK. about your use of our Social Media Pages. This allows us to better understand and analyze our user growth, general demographic information about the users of our Social Media Pages, and interaction with content on our Social Media Pages. Overall, this information may be used to help us understand the types of visitors and users of our Social Media Pages and use of the content.

USING INFORMATION WE COLLECT

We use the information collected through our Websites, Apps, and communications for the following purposes:

To fulfil orders and complete transactions, including for processing payments, verifying addresses, and to ship merchandise.

To conduct appropriate anti-fraud checks in the course of which the personal information that you provide may be disclosed to a credit reference or fraud prevention agency, which may keep a record of that information.

To detect, and protect us, our affiliate companies and other third parties against negligence, fraud, theft, and other illegal activities and to audit compliance with our and their internal policies.

To comply with administrative, tax, investigative or other audit requirements or any other legal or regulatory disclosure requirements.

As required by applicable laws, rules, and regulations, and to comply with any legal or regulatory requirements.

To monitor and analyze your activity with us, interaction with our Websites, Apps, and communications, and the effectiveness of our advertising and your purchases.

To serve site content, including search engine options, personalized messaging, product recommendations, and interactive features on our Websites, Apps, and communications.

To assist you with any questions or requests you may have regarding our Websites and Apps - or through any form of contact you make with us, including by email, phone, postal mail or via our Websites.

To develop, market, sell, and provide our products, services, communications, advertising, and other areas associated with our Websites, Apps, and stores.

To provide communications to you, such as operational communications (associated with your order, account, and other interactions with our Websites and Apps) and, with your consent, marketing communications (for example regarding: coming soon, sold out, cart abandonment, product view, appeasement, product recommendations, promotions, services, offers, and events) (please refer to the "Direct Marketing" section below for details in relation to the use and provision of personal data for direct marketing purposes).

To understand your needs and preferences in order to personalize your experience of our Websites, Apps, store visits, marketing communications, and advertising regarding our products and services as well as our affiliated companies’ products and services.

To conduct surveys, sweepstakes or contests.

To provide location based information, marketing, and advertisements on our Websites and Apps, in communications, in search engines, on third party websites, and when you visit our stores.

To create, administer, and update your account(s) that you have set up on our Websites and Apps, including using features offered in the account section.

To manage and develop our business and operations, and those of our affiliated companies.

To consider you for employment, and administer and maintain application information provided.

Please note that if you do not provide us with the required personal information, we may not be able to provide the information, products or services you need or process your request.

INFORMATION WE SHARE WITH THIRD PARTIES

1. EMAIL ADDRESSES

We do not sell, or grant rights to external third parties, to use your email address for their own marketing purposes.

Please note, if you request to be removed from our email marketing list, you may still receive email confirmations from us regarding any orders placed by you on our Websites, or other operational emails.

2. POSTAL ADDRESSES

We intend to share the names and postal addresses in our postal mailing list, sometimes categorized by purchasing information, with our affiliates and business partners for their direct marketing purposes. Your consent is required before we do so. Please see the "Direct Marketing" section below for details in relation to the use and provision of personal data for direct marketing purposes. Please also see the “Opt-Out” section below for instructions on how to opt out of sharing your data with our business partners.

3. SERVICE PROVIDERS

Please be aware that we may share information collected with third parties to assist us with our e-commerce business, such as our Websites, Apps, and communications, and our Social Media Pages. Some examples of the assistance that may be provided by third party service providers are: fulfilling orders (including but not limited to, processing payments, assisting with shipment, providing fraud prevention services, and verifying addresses), providing advertising services - including on social media sites and internet search engines, sending marketing communications, your actions in response to our communications and the effectiveness of our advertising, monitoring and analyzing site activity, serving site content (including a site search feature, product options, and personalized messaging), organizing information, conducting surveys, administering and maintaining employment application information, offering interactive features on our App, evaluating potential models, and administering emails, sweepstakes or contests. Such third parties may have access to your personal data to provide services on our behalf, but may not use your information for any other purpose.

4. LEGAL DISCLOSURES

You should also be aware that we may disclose specific information about you if we are required, or we genuinely believe that we are required, to do so by law or if we reasonably consider that it is necessary to protect the users of our Websites and Apps. In the event that we, or our parent company, is acquired by a new owner, or if following a reorganization of our corporate group we become part of one of our affiliate companies, your information may be transferred to a new owner, or another affiliate company, as part of our assets. If this occurs, we will take all reasonable steps to ensure that our new owner or the affiliate which we become part of will use your personal data only in accordance with the terms of this privacy policy.

5. SHARING INFORMATION WITHIN OUR GROUP

We may disclose the information that you provide to us (including, without limitation, your personal data) to any member of our group, which means our subsidiaries, our ultimate holding company and the subsidiaries of our holding company for marketing purposes or for serving personalized messaging on our Websites, Apps, and communications with your consent, as discussed in the "Direct Marketing" section below.

DIRECT MARKETING

We intend to use the personal information that you provide to us and the personal information we collect from various channels as discussed in this policy to send you information, offers and promotions about clothing and accessories and other products which we and our affiliate companies provide. We may share such information with other members of our group, our affiliate companies, and business partners which provide the same products for their direct marketing purposes. Your consent is required before we do so.

STORAGE OF INFORMATION

All of the information gathered through our Websites, Apps, and communications that you provide to us is sent to the United States and Hong Kong. We store and process your personal data and any other information that we collect from you through our Websites, Apps, and communications in the United States and Hong Kong. Our third party service providers who offer services to us from time to time may also store and process your personal data in the United States and Hong Kong. We, and our third party service providers mentioned above, may need to disclose your personal data that we store if required to do so under any applicable laws, rules or regulations.

COOKIES AND ADVERTISING

1. WHAT ARE COOKIES, PIXEL TAGS AND URL LINKS, AND HOW ARE THESE USED ON OUR WEBSITES OR IN OUR EMAILS?

Our Websites use, and our third party service providers may use, a browser feature known as a cookie, which assigns a unique identification to your computer or device. The cookies are typically stored on your computer's hard drive or mobile device. The information collected when visiting our Websites may include the following: an IP address, the URL of the page from which you arrived; your browser type; other technical information about your device used to visit our Websites; the pages you view; the features you use; whether you create an account, or sign in and where you go on our Websites once signed in; whether you complete a transaction; whether you have previously completed a survey; and the time of your visit. This information allows us to determine such things as which parts of our Websites are most visited or used, what products are browsed and/or purchased, the effectiveness of the Websites, your specific interaction with our Websites, and difficulties you may experience in accessing our Websites. With this knowledge, we can improve the quality of your experience on our Websites by recognizing and delivering more of the most desired features and information, personalize your experience, and resolve access difficulties. In addition, our Websites use cookies to help keep track of items you put into your shopping cart, whether you purchase any or all of those items, and to tell us whether you have visited one of our Websites in the past. This allows you to maintain shopping carts between visits and allows us to inquire about your continued interest in items in your shopping cart or that you viewed on one of our Websites. Our Websites also use cookies to help keep track of checkout information, other than payment method information, while you remain on our Websites. In addition, the information collected by us or our service provider(s) may be linked to and combined with information that we collect about you from your visits to our Websites.

Our Websites use, and our third party service providers may also use, Pixel Tags (also known as Web beacons, Web bugs, and Clear GIFs) on the Websites and in emails. A Pixel Tag is a nearly invisible pixel-sized graphic image on a Webpage or email message. Pixel Tags may be used to collect the same information about your visit that is collected through cookies, as noted above. We may also collect information about a search engine used, and a search engine advertisement clicked to navigate to the Websites. Pixel Tags in emails help us confirm the receipt of, and response to, our emails (including your interaction with our Websites as a result of receiving the email) and the time our email is viewed. This information helps us to make similar evaluations about our Websites and emails as with cookies and to determine the most desired features and information so that we can provide those features and information to you and personalize our interactions with you. This information may also be linked to and combined with information that we collect about you from your visits to our Websites.

In addition, our email communications to you may include a "click-through URL" linked to a particular page on one of our Websites. By clicking on one of the URLs, you will automatically enter one of our Websites and we may collect information related to the "click-through". You may avoid having this information collected by not clicking on the URL links in our email communications.

2.HOW THIRD PARTIES SERVE YOU OUR ADVERTISEMENTS ON OTHER WEBSITES AND YOUR CHOICES

We contract with third party advertising companies to serve you online display and banner advertisements on other websites. To serve this advertising, these third parties may place, use or rely on technology, such as cookies and/or Pixel Tags, to collect information about your interactions with our Websites and Apps and interactions with other websites. These advertising companies may use and share the information gathered to deliver our ads more tailored to your interests on other websites that are a part of their online advertising networks and/or search engines. We receive aggregate information from these third parties to gauge our advertising effectiveness. To opt out you can click on the icon that may appear on some of our advertising served through these technologies. We may use more than one third party company for