Privacy Policy

1. Please read carefully

R3A Group Limited (R3A) prioritizes the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how R3A, together with its affiliated companies worldwide (“R3A”, “CL1CK”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all R3A users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all R3A services, including our websites (including r3atech.com, cl1ck.biz and any of its subdomains, the “Website”), web applications (“R3A Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. 

 

2. What ‘Personal Information’ do we collect?

2.1. User information:

To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

  1. 1. Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., R3A’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).  

  2. 2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc

  3. 3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

2.2. Users of users ‘Personal Information’

We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.

2.3. R3A jobs applicant information

We also collect information that is provided to us by R3A jobs candidates (“Applicants”), when they apply to any of the open positions.

 

3. Why do we collect such ‘Personal Information’

We use your Personal Information for the following purposes:

1. To provide and operate the Services;

2. .To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;

3. To provide our Users with ongoing customer assistance and technical support;

4. To be able to contact our Users with general or personalized service-related notices and promotional messages;

5. To help us to update, expand and analyze our records to identify new customers;

6. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;

7. To analyze our performance and marketing activities;

8. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;

9. To provide you with professional assistance , only upon your request;

10. To enhance our data security and fraud prevention capabilities; and

11. To comply with any applicable laws and regulations.

We use your Personal Information for the purposes set out in Section 3 where:

1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);

2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or

3. Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of R3A by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.

 

In some circumstances and as required by applicable laws, we will seek your express consent when collecting your personal data. For example, we will seek your consent where there are new purposes for the use of your personal data or where we use and transfer your personal data for direct marketing purposes. In addition, you are able to withdraw your consent at any time by contacting us.

Access And Correction

You are entitled to certain access and correction rights to your personal data under the PDPO. We may charge a reasonable administrative fee for this service. In exceptional circumstances, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.

 

4. How we share your ‘Personal Information’

4.1.

We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

Third Party Service Providers:  R3A has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”). 

R3A may share the following categories of Personal Information with Third Party Service Providers for a business purpose:

• identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
 

• commercial Personal Information, for example Personal Information regarding products or services purchased, obtained, or considered.

 

4.2.

Law Enforcement, Legal Requests and Duties: R3A may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

 

 

4.3.

Protecting Rights and Safety:  R3A may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property or personal safety of R3A, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

 

4.4.

R3A Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy.

Sharing Personal Information from R3A subsidiaries and affiliated companies in the European Union and Switzerland to R3A’s United States subsidiary will be only when the relevant Model Standard Contractual Clauses are in place.

 

4.5.

In connection with a change in corporate control: In addition, should R3A or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.

 

4.6.

Upon Your Further Direction: The R3A Services enable you, through different techniques, to engage and procure various third party services, products and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the R3A Website, eCommerce payment providers, third party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites. For example:

a) Framed Pages: our Services may enable you to integrate Third Party Services directly into your web or mobile sites, such as via page framing techniques to serve content to or from Third Party Services  or other parties (“Frames”). In these circumstances, the Third Party Services may collect Personal Information from your Users-of-Users.

 

b) Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into your web or mobile sites. These Social Media Features may collect certain Personal Information from your Users-of-Users such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services.

 

Please note that in the examples listed above in this Section 4.6, R3A merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, R3A acts as a service provider to you, disclosing information to the Third Party Services on your behalf. R3A will share your Users-of-Users’ Personal Information with Third Parties Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto.

 

R3A does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services.

 

To the extent that we may need to transfer personal data outside of Hong Kong, whether to the parties set out in Section 4 or simply to data storage facilities, we shall do so in accordance with the Personal Data Privacy Ordinance (“PDPO”).

 

 

5. Where do we store your ‘Personal Information’?

Users’ and Users-of-Users’ Personal Information may be stored in data centers located in the Singapore. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

6. Users-of-users’ ‘Personal Information’

R3A may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with R3A, on the User’s behalf. R3A also uses visitor behavior data for the sole purpose of improving our Machine Learning algorithms.

For such purposes, R3A serves and shall be considered as a “Processor” and not as the “User” (as both such capitalized terms are defined in the Personal Data Privacy Ordinance (“PDPO”) of Hong Kong) of such Users-of-Users Information.

The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.

The Processing of the Users-of-users’ Personal Information shall take place within the territory of the Hong Kong SAR, China. For the sake of clarity, “Processing” should be understood as per the definition provided in the PDPO.

 

As we are a Hong Kong registered company, this Privacy Policy has been prepared solely in accordance with the requirements of the relevant laws of Hong Kong. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Privacy Policy as such.

You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.

R3A cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.

​ 

If you are a visitor, user or customer of any of our Users, please read the following: R3A has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by R3A on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If R3A is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information.

 

7. Use of cookies and other third-party technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in  order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

 

A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier. If you wish to reject our cookie, you can configure your browser to do so. However, in a few cases some of our website features may not function if you remove cookies from your browser.​

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

 

8. Communications from R3A

8.1. Promotional messages

We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from R3A or our partners (acting on R3A’s behalf) through such means.

If you do not wish to receive such promotional messages or calls, you may notify R3A at any time or follow the “unsubscribe”.

 

Use and Transfer of Personal Data in Direct Marketing

We also intend to use your name, email address, address or phone number to send you marketing, advertising and promotional materials about banking, investment, credit and/or financial products and/or services of R3A and/ or of any other companies belonging to the R3A Group. We may share your personal data with any other companies within the R3A Group or our business partners who provide the same products and services for direct marketing purposes. Your consent is required before we do so.

 

8.2. Service and billing messages

R3A may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.

It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a R3A User (which can be done by deactivating your account).

 

9. Your rights in relation to your ‘Personal Information’

R3A agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, R3A is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

If you are a R3A User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), you can also mail your request to R3A Group Limited, Unit 1603, 16th Floor, The L. Plaza, 367-375 Queen's Road Central, Sheung Wan, Hong Kong. We will make reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.

Please note that permanently deleting your R3A account erases all of your Personal Information from R3A's databases. After completing this process, you can no longer use any of your R3A Services, your account and all its data will be removed permanently, and R3A will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.

 

Disclosure of Personal Data

We may disclose your personal data to other companies of the R3A Group, business partners, third party service providers (including those providing administrative, telecommunications, computer, financial intermediary, payment or securities clearing or other services to R3A in connection with the operation of its business), financial institutions with which you have or propose to have dealings, any actual or proposed assignee of R3A or participant or sub-participant or transferee of R3A’s rights in respect of the customer, any potential investor in or purchaser of any interest in any Group company or in its business in connection with any potential reorganisation, merger or disposal, credit reference agencies, debt collection agencies, charity or charitable organisation, our professional advisers and agents and legal, regulatory, governmental, tax, law enforcement or other authorities (which may be located within or outside Hong Kong) for the purposes stated above. In addition, there are certain circumstances under applicable laws where we are permitted to collect, use and disclose your personal data without your consent. You may obtain more information by contacting us. We will not sell, rent or otherwise disclose your personal data to any third party not referred to above without your consent except in the following circumstances: we may share non-personal, non-individual information in aggregate form with third parties for business purposes, for example, we may tell our business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

 

10. Questions and complaints

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.

Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.  

You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

 

11. Data retention

We may retain your Personal Information (as well as your Users-of-Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.

We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

We maintain a data retention policy which we apply to Personal Information in our care.

 

 

12. Security

R3A has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

Regardless of the measures and efforts taken by R3A, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with R3A or anyone else. We encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.

Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.

We have put in place adequate security procedures and technical and organisational measures to safeguard your personal data. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.

 

13. Third-party websites

Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third party websites and services.

 

14. R3A jobs applications

R3A welcomes all qualified Applicants to apply to any of the open positions, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.

We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Personal Information  private and use it solely for R3A’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).

If you previously submitted your Applicants Personal Information to R3A, and now wish to access it, update it or have it deleted from R3A’s systems, please contact us at hr@r3atech.com

 

15. Public forums and user content

Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us here. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform. 

In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.

If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.

We have put adequate security measures in place to protect your Personal Information.  However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.

 

16. Updates and interpretation

We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you (using one of the notification methods set forth in Section 15.3 of the Terms of Use) prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you and your Users-of-Users, with respect to our Website, R3A Apps, Mobile Apps and other Services. 

 

We keep our Privacy Policy under regular review. If we change our Privacy Policy, we will post the changes on our website. Such changes to our Privacy Policy shall apply from the time that we post the same on this website. We will seek your fresh consent if we wish to use or disclose your personal data for new purposes

 

17. Contacting us

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Sections 9 or 10 please refer to those sections or contact the Data Protection Officer team. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.

You may also contact us by mail at:

  • • Unit 1603, 16th Floor, The L. Plaza, 367-375 Queen's Road Central, Sheung Wan, Hong Kong

 

Points from Clay

Disclosure of Personal Data

We may disclose your personal data to other companies of the R3A Group, business partners, third party service providers (including those providing administrative, telecommunications, computer, financial intermediary, payment or securities clearing or other services to R3A in connection with the operation of its business), financial institutions with which you have or propose to have dealings, any actual or proposed assignee of R3A or participant or sub-participant or transferee of R3A’s rights in respect of the customer, any potential investor in or purchaser of any interest in any Group company or in its business in connection with any potential reorganisation, merger or disposal, credit reference agencies, debt collection agencies, charity or charitable organisation, our professional advisers and agents and legal, regulatory, governmental, tax, law enforcement or other authorities (which may be located within or outside Hong Kong) for the purposes stated above. In addition, there are certain circumstances under applicable laws where we are permitted to collect, use and disclose your personal data without your consent. You may obtain more information by contacting us. We will not sell, rent or otherwise disclose your personal data to any third party not referred to above without your consent except in the following circumstances: we may share non-personal, non-individual information in aggregate form with third parties for business purposes, for example, we may tell our business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

 

Transfer Of Personal Data Overseas

To the extent that we may need to transfer personal data outside of Hong Kong, whether to the parties set out in Section 4 or simply to data storage facilities, we shall do so in accordance with the Personal Data Privacy Ordinance (“PDPO”).

 

Consent

In some circumstances and as required by applicable laws, we will seek your express consent when collecting your personal data. For example, we will seek your consent where there are new purposes for the use of your personal data or where we use and transfer your personal data for direct marketing purposes. In addition, you are able to withdraw your consent at any time by contacting us.

 

Use and Transfer of Personal Data in Direct Marketing

We also intend to use your name, email address, address or phone number to send you marketing, advertising and promotional materials about banking, investment, credit and/or financial products and/or services of R3A and/ or of any other companies belonging to the R3A Group. We may share your personal data with any other companies within the R3A Group or our business partners who provide the same products and services for direct marketing purposes. Your consent is required before we do so.

 

Access And Correction

You are entitled to certain access and correction rights to your personal data under the PDPO. We may charge a reasonable administrative fee for this service. In exceptional circumstances, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.

 

Accuracy

In order to ensure that your personal data is current, complete and accurate, please update us by contacting us (see Section 15).

 

Security Safeguards

We have put in place adequate security procedures and technical and organisational measures to safeguard your personal data. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.

 

Updates To The Privacy Policy

We keep our Privacy Policy under regular review. If we change our Privacy Policy, we will post the changes on our website. Such changes to our Privacy Policy shall apply from the time that we post the same on this website. We will seek your fresh consent if we wish to use or disclose your personal data for new purposes.

 

Cookies

A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier. If you wish to reject our cookie, you can configure your browser to do so. However, in a few cases some of our website features may not function if you remove cookies from your browser.

 

Governing Law

As we are a Hong Kong registered company, this Privacy Policy has been prepared solely in accordance with the requirements of the relevant laws of Hong Kong. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Privacy Policy as such.