Cookie Policy

1.1 Jingdong Retail (Netherlands) B.V. (“Ochama”, “we“, “us“ or “our“) attaches great importance to the protection of its users' privacy and personal information. We collect and use your personal data when you use our products and/or services. This Ochama Cookie Policy explains to you how we and other members of the Ochama group collect, use, save, share, transfer or otherwise process your personal data through the use of cookies and similar techniques when you, or in the case of business users any individuals acting on your behalf (your “Personnel”), use(s) our products and/or services, and the way we provide for you to access, update, delete and protect that information
1.2 References to Personnel below are relevant only to business users’ use of Ochama. Any references to “your” personal information shall be read as references to Personnel personal information for business users.
1.3 For more detailed information about how we process your personal data not gathered through cookies or similar techniques, we refer to our general Privacy Policy

2.1 The scope of this Policy is limited to processing activities to which the General Data Protection Regulation (“GDPR”) and its national implementation acts apply.

3.1 We will only process personal data in accordance with the applicable privacy legislation and as described in this Policy.
3.2 The website includes links to website of third parties. We are not responsible for the content of these websites, services provided by these third parties or their compliance with the applicable privacy legislation.

4.1 Cookies are small text files that can be placed on your computer, tablet, smartphone or other electronic device with which you can use to surf the internet via a web browser (“device”). Websites or apps that use cookies can then place these cookies on your device via your web browser if you visit such website or use an app. Examples of web browsers are: Internet Explorer, Firefox, Safari, Google Chrome and Opera.
4.2 After a cookie is placed on your device, your device can be recognised as you surf through the website via the same web browser or use an app. This will for instance enable the website or app to ‘remember’ your language settings, which pages you visited and the items in your shopping chart. If such cookies are placed by a third-party, such third-party can (also) recognise your device (third-party cookies). It is furthermore also possible that cookie information is afterwards shared with third-parties. For more information on cookies, please be referred to the website www.allaboutcookies.org. 4.3 Lifecycle cookies: after a cookie is placed on a device, it is only valid for a certain period.

• a. After the validity period of a cookie lapses, the cookie is automatically removed by the web browser. The validity period varies per cookie. For example, some cookies are only valid during the browser session. Other cookies can also recognise your device if you visit the website or app during a new browser session, e.g. for a year after being placed on your device.
• b. Early deletion/refusal of cookies: you can choose to delete a cookie manually before its validity period has lapsed. You can also decide to refuse cookies which may only be placed with your consent, in the first place. For more information on this, please see the section “How can you delete cookies or change your cookie setting?” below.

4.4 Similar techniques: in addition to cookies, other techniques are also used for similar purposes:

• a. HTML5 Local Storage and Flash cookie: HTML5 Local Storage and local shared objects (LSOs, also called “Flash cookies”) can be used for the same purposes as cookies.
• b. Web beacons: Web beacons (also called “tags”) are bits of programming code that can be included in web pages, emails, and ads. Web beacons can notify the user when those web pages, emails, or ads have been viewed or clicked on by you.
• c. Embedded scripts: Embedded scripts (also called “Javascrips”), are bits of programming code that can be included in web pages to measure how those web pages are used by you, e.g. by registering which links you click on.
• d. Device fingerprints: information collected about software or hardware of a device for identification and security purposes. This information is collected for two main purposes, namely (i) ensuring the security of your account by detecting hacking activities, security threats and related abnormal statuses of your account, and (ii) ensuring fair dealing and protecting your and our interests by detecting and blocking cybercrime or online deceptive activities.
• e. Event tracking: an event is your interaction or activity with a page, which will be tracked through the tracker. This information is collected for the following main purpose, namely identifying which ads or pages have led to purchases and calculating the conversion rate in order to optimize performance levels.

5.1 We use four types of cookies on this Site: (i) functional cookies, (ii) analytical cookies, (iii) affiliate cookies (iv) tracking cookies. More information on this is provided below.
5.2 Functional cookies:

• a. Functional cookies are essential for the proper layout and navigation of a website, and for us to remember whether cookies have been allowed or refused. It concerns cookies (i) that are placed with the sole purpose of facilitating communication over an electronic communication network or (ii) that are strictly necessary for providing you with the information-society service as requested by you.
• b. Functional cookies may be placed without your consent.

5.3 Analytical and affiliate cookies:a. Analytical cookies are used to analyse and map the use of a certain website, so that the quality and/or effectiveness of the website can be improved.b. Affiliate cookies are used to keep track of what ad leads to the purchase of a product/service, so that the party that has displayed this ad (the affiliate) can get a reward from the advertiser.c. We do not need your consent to place cookies for obtaining information about the quality or effectiveness of a provided information-society service (analytical or affiliate cookies), if this will have little or no impact on your private life. In other cases, we will not place analytical or affiliate cookies without your consent.
5.4 Tracking cookies:

• a. Tracking cookies are used to follow the behaviour of website visitors across multiple websites. If such cookies are placed by another party, these are called third party tracking cookies.
• b. We will not place tracking cookies without your consent.

For a full overview of all the cookies we use, please be referred to the paragraph “What cookies and techniques do we use? Full overview”, below.

6.1 On our Site, we use the following cookies and techniques:

	Name cookie	Purpose of the cookie	Categories of personal data collected	Is this cookie placed by a third-party or is the cookie information shared with third parties by Ochama?	Validity period	Consent required
Functional cookies	mca	Store user selected address id so that user does not need to select this again while using application	Address ID	First party	365days	No, we base our processing activities on our legitimate interests, namely ensuring proper layout and navigation of a website, facilitating communication between you and us, and ensuring uninterrupted shopping experience.
	redirectUrl	Store user latest url visited before logged in, so that user can be redirect to the url after logged in	url	First party	365days
	deviceId	The random string used to identify user when not logged in	none	First party	365days
	hasCookieAggreementRead	Identify if user has accepted	Agreement acceptance status	First party	365days	Yes
	i18n_language	The language preference	UI language	First party	365days	Yes
	storeId	The store id	none	First party	365days	Yes
	lighting-nl	The user login token	User Pin	First party	365days	Yes
	searchHistory	The history of keywords	Keywords used	First party	365days	Yes
	cookieVer	The cookie agreement version	none	First party	365days	Yes
	_jda	Temporarily save information on your session (website visit).	none	First party	180 days	Yes
	_jdb	Temporarily save information on your session (website visit).	none	First party	30 minutes	Yes
Analytical cookies	>N/A
Affiliate cookies	_ga	Used to distinguish users	None	Third party	2years	Yes
	_gid	Used to distinguish users	None	Third party	24 hours	Yes
	_gat	Used to distinguish users	None	Third party	1minute	Yes
	AMP_TOKEN	Contains a token that can be used to retrieve a Client ID from AMP Client ID service.	None	Third party	30s – 1year	Yes
	_gac_<property-id>	Contains campaign related information for the user.	None	Third party	90 days	Yes
	_utma	Used to distinguish users and sessions.	None	Third party	2years after updating	Yes
	_utmt	Used to throttle request rate	None	Third party	10 minutes	Yes
	_utmb	Used to determine new sessions/visits.	None	Third party	session	Yes
	_utmc	this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.	None	Third party	session	Yes
	_utmz	Stores the traffic source or campaign that explains how the user reached your site.	None	Third party	6 months after updating	Yes
	_utmv	Used to store visitor-level custom variable data.	None	Third party	2years after updating	Yes
	_utmx	Used to determine a user's inclusion in an experiment.	None	Third party	18 months	Yes
	_utmxx	Used to determine the expiry of experiments a user has been included in.	None	Third party	18 months	Yes
	_gaexp	Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in.	None	Third party	90 days	Yes
	_opt_awcid	Used for campaigns mapped to Google Ads Customer IDs.	None	Third party	24 hours	Yes
	_opt_awmid	Used for campaigns mapped to Google Ads Customer IDs.	None	Third party	24 hours	Yes
	_opt_awgid	Used for campaigns mapped to Google Ads Customer IDs.	None	Third party	24 hours	Yes
	_opt_awkid	Used for campaigns mapped to Google Ads Customer IDs.	None	Third party	24 hours	Yes
	_opt_utmc	Stores the last utm_campaign query parameter.	None	Third party	24 hours	Yes
Tracking cookies	>N/A
Device fingerprints	App IOS	Identifying the device Securing the network and account Carrying out login risk checks Identifying the hardware Identifying the network identity Gathering application information	Device name IDFA Device type format System name System version Carrier name Carrier MCC code Carrier MNC code Current IP address Wi -Fi gateway Network type (Wi-Fi/4g/3g/2g/none) WiFi ssid External IP address Last system restart time Battery percentage Charging device orientation Whether it was in debugging process P_TRACED Jailbreak , simulator Headset connection Number of connected accessories Screen brightness Free disk space, used disk space, free memory space Used memory space Three-axis accelerometer force values (x,y,z) Gyroscope three-axis rotation angle values (x,y,z) Magnetometer three-axis magnetic values (x,y,z) Whether it is a high-definition screen MAC address Time zone Language List of installed apps systemAppAccount userAppAccount	Third party	5-6 years	No, we base our processing activities on our legitimate interests, namely as listed in clause 4.4d.
	App Android	Identifying the device Securing the network and account Carrying out login risk checks Identifying the hardware Identifying the network identity Logging operations	International mobile device identification code International mobile user identification number Hardware serial number System building unique identity AndroidID Carrier code (MCC-MNC) Linux kernel version Hardware brand Hardware model Industrial design name Manufacturer Phone product name Resolution Screen density Kernel hardware name Motherboard platform ROM all available space RAM all available space Bluetooth address Bluetooth name Whether to plug in the headset Whether there is a rear camera Whether there is a front-facing camera Battery charge, battery health, battery status, battery voltage Support for multi-touch Sensor list Speed meter Gyroscope Whether to support multi-touch Whether to support nfc whether to support Bluetooth Number of cameras Cpu platform information Cpu cores Cpu maximum frequency AP name AP physical mac address Signal strength Theoretical wireless transmission rate Routing IP Dns LAN IP Subnet mask Whether to connect Wi-Fi MAC address Time zone Language Process list Number of processes ID of the same cycle application Whether the adb bug is open Simulator field Root JNI validation field Pin Hook frame multi open	Third party	5-6 years	No, we base our processing activities on our legitimate interests, namely as listed in clause 4.4d.
	web	Identifying the device Securing the network and account Carrying out login risk checks Identifying the hardware Identifying the network identity	The browser's operating system Browser type Browser version, request URL IP address IP-owned province IP-owned city Screen resolution Screen depth Whether to turn on session storage Whether to turn on local storage Whether to support indexedDb Whether to support addBeavior Whether to open the database Whether the browser is turning on anti-tracking Cpu number of cores Audio acquisition rate The number of logical processors that can be used to run threads on the user's computer Time zone Language	Third party	5-6 years	No, we base our processing activities on our legitimate interests, namely as listed in clause 4.4d.
ZIWU Event Tracking	App (IOS and Android)	Identifying the device Securing the network and account Identifying the location Identifying the network identity	Network type (Wifi /4g/3g/2g) at log generation time Network type (Wifi /4g/3g/2g) Device type Platform type Device brand name Screen resolution Operating system version number International carrier code Sim card information Latitude Longitude Unique user id Channel First session time Last session time Current session time Current page PageID Previous page PageID Event ID	Third party	5-6 years	No, we base our processing activities on our legitimate interests, namely as listed in clause 4.4d.
		Identifying the device Securing the network and account Identifying the location Identifying the network identity	Operating system Operating system version number Screen size Unique device number Current page URL Page source URL Current session time Last session time	Third party	5-6 years	No, we base our processing activities on our legitimate interests, namely as listed in clause 4.4d.

7.1 You can you change your cookie settings in general – for all websites you visit – via your browser settings. You can also change your cookie setting just for our Site.2 Within your browser you can change your cookie preferences and choose whether you wish to accept cookies or not. If differs per browser which sort of choices you can make, such as denying all third-party cookies. For further information on how you can change your browser settings, please be referred to: www.aboutcookies.org/how-to-control-cookies/3 You can change your cookie settings just for our Site below. Please be referred to the paragraph “What type of cookies and other techniques do we use?” for more information on the below types of cookies.

8.1 For any questions, comments or requests, you may contact us via support@ochama.com. Please let us know by e-mail if you prefer to have further contact over the phone
8.2 Further, the data protection officer can be contacted at support@ochama.com. Please note that our data protection officer is located in China.

9.1 Ochama is entitled at all times to delete your personal data without notice. In such a case, Ochama owes no compensation to you as a result of the termination of the account
9.2 If provisions from this Cookie Policy are in conflict with the law, they will be replaced by provisions of the same purpose that reflect the original intention of the provision(s), all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged
9.3 Ochama reserves the right to change this Cookie Policy on a regular basis. Where required, Ochama will inform you of updates made to this Cookie Policy. The current version is always available on our website and in our app. This Cookie Policy was last amended and revised in September 2021.

10.1 In this Cookie Policy, the following definitions apply:

Applicable privacy legislation	Applicable privacy legislationAll applicable privacy legislation, including the General Data Protection Regulation (“GDPR”) and the relevant national implementation acts.
Cookie Policy	This present Cookie Policy.
Ochama	Jingdong Retail (Netherlands) B.V. Da Vincistraat 5 2652 XE Berkel en Rodenrijs Chamber of Commerce-number: 80456774
Website	www.ochama.com
App	Ochama

10.2 Other terms that are defined in the applicable privacy legislation, such as ‘personal data’, (joint) controller, processor, data subject and processing will have the meaning as described in the applicable privacy legislation.