1. Introduction

This Personal Data Protection Policy (this “Policy”) addresses the basis on which Glamabee Limited (“we”, “ours”, and “us”) may collect, use, disclose or otherwise process Personal Data (as defined below) in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “PDPO”) and any other applicable law. This Policy applies to Personal Data in our possession or under our control.

By interacting with us, using this site (the “Site”), submitting information to us, or engaging our services (if any), you agree and consent to us and Third Parties (as defined below) collecting, using, disclosing and/or processing your Personal Data in the manner set out in this Policy.

This Policy may be updated by us at any time, and any amendments or revisions made to this Policy will be published on this Site.

2. Definition of Personal Data

“Personal Data” refers to any data relating, directly or indirectly, to a living individual from which it is practicable for the individual to be directly or indirectly identified.

3. Collection of Personal Data

We may collect and/or track the following Personal Data:

• your e-mail addresses and social media accounts/handles used to communicate with us or this Site through email and/or the relevant social media platform (as the case may be);
• information you knowingly provide in online forms, registration forms, surveys, through email or otherwise (including name, address, email address, social media accounts/handles and other personal data);
• information as detailed in our Cookies Policy; and
• information provided to us in relation to the provision of our services (if any).

4. Purposes for Processing Personal Data

The Personal Data collected from you may be used, disclosed and/or processed for various purposes, including but not limited to:

• performing our contractual obligations;
• providing and improving our services and/or content on the Site and social media platforms;
• responding to enquiries, requests or feedback;
• evaluative purposes, such as determining whether our created contents are of interest to you;
• maintaining and developing our relationships with you, our customers and prospective customers, users of our site, suppliers and other third parties;
• verifying your identity, processing payments and otherwise managing our administrative and business operations and administering the relationships with our customers;
• complying with applicable laws and regulations, guidelines, policies and other regulatory requirements issued by the relevant authorities;
• organising events, seminars and other marketing or promotional activities;
• forwarding administrative or other notifications;
• maintaining and improving the security and functionality of our site and information technology systems and tracking traffic and usage on our site, if any;
• protecting, establishing, exercising or defending our legal rights;
• processing, storing, monitoring, hosting, and backing up Personal Data, whether within or outside of Hong Kong;
• protecting any of our legitimate interests; and
• any other purpose incidental to any of the above.

5. Disclosure of Personal Data to Third Parties

We may disclose the Personal Data collected by it to the following parties (“Third Parties”), which may be located outside of Hong Kong:

• third parties involved in the provision of services to us or our customers and prospective customers;
• professional advisors, banks and financial institutions, auditors, insurers and other third-party service providers; and
• courts, tribunals, regulatory and governmental authorities, and law enforcement agencies.

6. Direct Marketing

We may collect, use, disclose or otherwise process your Personal Data to forward relevant marketing materials including updates, newsletters, and other communications to you. We will only send marketing materials after it has obtained your separate consent to do so. You may withdraw your consent for us to send marketing materials to you at any time by opting out or contacting us as detailed below.

7. Withdrawal of Consent

You may withdraw consent and request us to stop using, disclosing, and/or processing your Personal Data for any or all of the purposes listed above by submitting your request in writing or through email to us at admin@glamabee.com, with subject “Withdrawal of Consent (Personal Data)”.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on its relationship with you) for your request to be processed. In general, we will process your request as required by law. If you decide to cancel your withdrawal of consent, you must inform us in writing in the manner described above. Withdrawing your consent does not affect our right to continue to collect, use, disclose and/or process your Personal Data where such collection, use, disclosure and processing is permitted without consent or required under applicable laws.

8. Data Retention

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected in accordance with its data retention policies (including for the purposes of satisfying any legal, accounting, or reporting requirements) or as required or permitted by applicable laws. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data; the potential risk of harm from unauthorised use or disclosure of the Personal Data; the purposes for which it processes the Personal Data and whether it can achieve those purposes through other means; and the applicable legal requirements including the statute of limitations periods. For the avoidance of doubt, we may retain Personal Data in situations where its relationship with the data subject (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce its rights under any contract).

We will delete, anonymise, or securely dispose of your Personal Data when retention no longer serves the purposes for which the Personal Data was collected, and it is no longer necessary for business purposes.

9. Data Subjects’ Rights

Under the PDPO, you have the right to request access to and correct your Personal Data. If you wish to make a request, you may submit your request in writing or through email to us at admin@glamabee.com, with subject “Amendment of Personal Data”.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your access or correction request as soon as reasonably possible. If we are unable to respond to your request within forty (40) days of receipt, we will inform you, in writing, within this forty (40)-day period. If we are unable to provide you with any Personal Data or to make a requested correction, we will inform you of the reason(s) why it is unable to do so (except where we are not required to do so under the PDPO).

Depending on the request made, we may only provide you with (i) access to the Personal Data contained in the documents requested (not to the documents in their entirety), and (ii) where appropriate, confirmation of the Personal Data that we have on record where your Personal Data forms a negligible part of the document(s).

10. Data Security

We will take reasonable care to protect your Personal Data from unauthorised access, modification, or disclosure. However, no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we thrive to protect the security of your information. Transmission of your data to our us through any electronically means is at your own risk.

11. International Data Transfers

Your Personal Data may be transferred and/or shared both within and outside of Hong Kong to our business partners and third-party service providers for data storage, administration and other purposes. You acknowledge and agree, however, that in some cases your Personal Data may be exported to, processed and accessed in countries whose laws may provide a different level of protection that may not necessarily be comparable to that provided under the PDPO. Specifically, our websites and information technology systems are hosted on servers located in the Republic of Singapore.

Except as stated above, We will not generally disclose your Personal Data to Third Parties unless you consent or the disclosure is authorised or required by law.

12. Contact Information

If you (i) have any questions or feedback relating to your Personal Data or this Policy, (ii) would like to withdraw your consent to any use of your Personal Data as set out in this Policy, (iii) would like to obtain access or make corrections to your Personal Data, or (iv) would like to report a violation of this Policy, please contact admin@glamabee.com.

13. Changes to this Policy

We may revise this Policy from time to time without any prior notice. Please refer to the date of the Policy to determine when it was last updated. Your continued interaction with us constitutes your acknowledgement and acceptance of such changes.

Version: October 2025