Privacy Statement

Introduction

Shui On Xintiandi Ltd. operates a web site at www.shuionxintiandi.com (“Site”). We respect the privacy of each user of the Site (referred to as "you" or "a user"). This Privacy Statement gives you specific information about how we protect your privacy, how we treat information we collect on the Site that identifies an individual user ("Personal Information"), and how we use these information.

BY REGISTERING FOR OR USING THE SITE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT, YOU CANNOT USE THE SITE. We reserve the right to modify this Privacy Statement from time to time by posting a notice on the Site's home page. We may also consider providing you with the additional notices of significant changes if applicable. We suggest you read the notice relating to the modification (if any) of this Privacy Statement because your use of the Site indicates to us that you completely agree to this Privacy Statement which is subject to modification by us from time to time.

Scope of this Privacy Statement
This Privacy Statement applies to the Site

1.

Collection and Use of Your Personal Information
We collect your Personal Information in order to enhance the services we offer you. We collect Personal Information from you only when you voluntarily submit it in order to obtain certain services or information, including but not limited to (A) registrations for special communications, such as online registration; (B) requests to contact us; (C) applications for employment.

Contacting Us
If you contact us, we collect your Personal Information, which will be retained by us or referred to an independent Franchisee or sales associate depending on the nature of your inquiry. If your enquiry or complaint requires a response from us, your Personal Information will be referred to the appropriate department for research and a response. The Personal Information we collect from you will not be used in any other way and will not be retained by us for more than one year after collection.

Employment Inquiry
If you are seeking job opportunities in the Site, you will be asked to provide Personal Information about yourself. We will refer your Personal Information to the appropriate department which is responsible for the related matters.

2.

Collection of Non-Personal Information
Even if you do not send us any Personal Information, we will collect information regarding how you use our site (referred to as "Non-Personal Information"). Non-Personal Information cannot be used to identify you personally and will be explained in more details below under "Non-Personal Information".

Cookies
A cookie is a small data file, usually including an anonymous unique identifier, which is sent from a web site's computer and stored on your computer's hard drive. Use of cookies is common on the Internet. A web site can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser permits a web site to access only the cookies it has already sent to you, not the cookies sent to you by other sites. You can configure your browser to accept all cookies or reject all cookies, or notify you when a cookie is sent to you. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.) You can reset your browser to refuse all cookies or indicate when a cookie is sent to you. But if you refuse cookies, some parts of the Site will not function properly and may not provide services or information you have requested.

Non-Personal Information
Similarly to many other sites, we obtain Non-Personal Information such as IP (internet protocol) addresses, browser types, the name of your ISP (internet service provider), information about where a user comes from before arriving at our Site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor performs this service for us by sending a cookie to gather this information, compile it, and report to us. We use Non-Personal Information to customize the content you see, improve our services, conduct research, and provide anonymous aggregated reporting for internal audits and third-parties.

3.

Use of Information
We will use the Personal Information and the Non-Personal Information we collect on the Site in the following ways (included but not limited to): (A) provide you with the services that you ask for through the Site; (B) to answer your enquires or complaints ;(C) for analytical purposes to help us improve the Site and for our business generally.

4.

Sharing Your Information
We do not rent, sell, or share with third parties the Personal Information we collect from you on the Site except (i) to provide information or services that you have requested;(ii) with your permission;or (iii) under the following circumstances:

A.

Third party vendors we engage to provide services, included but not limited to, of web-site hosting, developing, and supporting on our behalf of the Site, have access to Personal Information, but they owe a duty of confidentiality to Shui On Xintiandi.

B.

There may arise special circumstances where it is necessary for us to disclose or use Personal Information and/or Non-Personal Information, if the disclosure is to (A) comply with any law or pursuant to an order of a court or any request of any regulatory agency or body;(B) protect the safety of anyone; (C) provide to subsidiaries and associated companies of Shui On Xintiandi; (D) investigate, prevent, or take action regarding illegal or improper activities; (E) carry out a merger or consolidation with another entity, a sale or transfer of some or all of our assets, or any similar transaction; (F) or for any other reasons we determine in good faith are necessary and appropriate.

5.

Security
Our hosting services maintain its systems in accordance with reasonable industry standards to reasonably secure your Personal Information. However, no data transmission through the Internet can be guaranteed to be 100% secure. Therefore, we could not make undertaking to you of absolute security of your Personal Information on the Internet and your use of the Site is at your own risk.