PRIVACY POLICY
Version No. 3
This document was last updated on December 19, 2023.
Privacy Statement
This Privacy policy (the "Policy") sets out how Smart Glocal Services Limited (the "Company," "we," "our") applies to any personal data or information (“Data”) that we may collect from or about you (the "User," "you," "your") while using the Company's software and services, collectively referred to as the "Services."
PLEASE READ THIS PRIVACY POLICY. BY USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND FULLY AGREE TO ALL THE TERMS OF THIS POLICY. YOU MAY NOT USE THE SERVICES IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY.
By using our Services, you agree that you have read, understand and unconditionally accept all the terms of this Policy. If you do not agree to any provision of this Policy, or you believe that any provision of this Policy infringes on your rights, or in any other way puts you at a disadvantage, then you must immediately stop any use of our Services.
Protecting Your Privacy
The relationship related to the collection, storage, processing, and protection of information provided by Users is governed by this Policy and the laws of Hong Kong.
This Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal Data you have provided to us, as well as to help you to make an informed decision before providing us with your personal Data.
However, we are committed to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, in particular and where applicable, this Policy, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal Data and on the free movement of such Data (the “GDPR”) where applicable.
For the purpose of the GDPR, Smart Glocal Services Limited, whose address is at Suite A, 11/F, Arthur Commercial Building, 33 Arthur Street, Yaumatei, Kowloon, Hong Kong, is the controller who determine the purposes and means of processing of your personal Data collected through websites owned and/or operated by us or on our behalf (including https://smart-glocal.com/) (collectively, “Our Website(s)”) or other channels described in paragraph 2 of this Privacy Policy.
We constantly strive to improve our Services by providing you with new features and capabilities, so we may make changes to this Policy from time to time. If we make changes, we will notify you in any way we can. At the same time, we recommend that you periodically check the date of the last update of this Policy, indicated at its top, and, if it is updated, get acquainted with the new version of the Policy.
Personal Data We May Collect From Or About You
When you use the Services, we may collect and process the following information from or about you:
(a) Personal information
This is information that identifies a specific person. When you use the Services, we may ask you to provide us with certain information about yourself that will help us identify you among our Users and properly provide you with Services. This may include information that you provide to us when registering or using the Services, information that you provide when communicating with us (for example, when contacting support), or information that we may receive from other Users. This information may include your name, gender, nationality, address, date and place of birth, identification document details, email address, mobile phone number, your photo and videos, and other registration information, financial information such as your bank card number or account details and any other information that you may provide to us on your own or upon our request or via other forms of interactions with us.
(b) Cookies
These are small pieces of information stored by your browser on your device at the request of the Services. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. This information helps us to build a profile of our users and is used for:
• identifying you when you visit our Services and when you navigate through it;
• determining your status when logging in to the Services;
• storing information about your preferences and personalize the Services for you;
• protecting our Users ' accounts, including preventing fraudulent use of their credentials and to protect the Services as a whole;
• analysis of the use and effectiveness of our Services;
• saving your preferences regarding the use of cookies in a more general way.
Most browsers automatically accept cookies. You can, however, modify your browser settings to disable cookies. If you choose to do so, some of the functionality of our websites may be impaired.
We may also use cookies from third parties to help us provide you and others with social plugins and other customized content and experiences.
Some cookies will not collect information that personally identifies you. They will collect more general information such as how users arrive at and use our websites, or a user’s general location. However, some other cookies can identify you and may contain or collect personal Data. The type of information we collect because of a cookie is specific to your computer and may include, without limitation, the Internet Protocol (IP) address and the date and time you accessed our websites. The data stored on a "cookie" can be retrieved by us when you visit Our Website(s).
When you visit our website(s), you will see a pop-up seeking your consent to the placing and use of cookies on your device. You may either give such consent or reject the placing and use of cookies. You can also remove existing cookies from your device using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies see aboutcookies.org, which contains comprehensive information about how to restrict or block cookies on a wide variety of browsers.
(c) Information about your device
Using the Services, our servers automatically record certain information about your device. This information may include information such as the web request, date and time of the request, IP address, your registration information, browser type, operating system type and version, time zone setting, device and model information, unique device ID (such as IMEI number, MAC address, mobile phone number), mobile network information, and so on.
(d) Information about your location
We use GPS technology and your IP address to determine your location while using the Services. We do this to prevent fraud (for example, when your location and device type differ from the one you normally use).
(e) Information about you from third-party services
If you provide your account information from third-party services (Facebook, Google, etc.), we may receive Data about you from these services. By entering your account information in third-party services, you give us your consent to receive Data about you from these services and use them in accordance with the terms of this Policy.
(d) Impersonal information.
This is information that does not identify you as a specific person (i.e. non-personal data). This information may include information such as the unified resource index (url) of the website that you visited before and after visiting our Services, information received about you from search engines, web beacons, etc. This information itself does not identify you as a specific person, although it may be unique and/or contain information that you may consider personal.
Ways To Use Information
We may use the information we have about you to provide you with the Service, improve the Service and analyze its use, and conduct marketing and advertising campaigns. We may also use the information we have to resolve problems with the Service, resolve conflicts and disputes, perform administrative tasks, contact you, ensure compliance with our policies and applicable laws, and cooperate with law enforcement agencies.
For the Service to function properly, we may share information about you with payment method providers with whom we have agreements. Before such transfer, we undertake ensuring that the chosen payment method provider processes the information received from us with the same care that we provide for our Users.
We may disclose the information we hold about you to third parties as part of assignment or novation of your rights and obligations under the User Agreement.
For the proper functioning of the Service and/or in the event of novation or assignment of the User Agreement as described above, we may transfer your data to our partners outside of Hong Kong (cross-border data transfer). By using our Services, you give us explicit and unambiguous consent to the transfer, processing, and storage of your data outside of Hong Kong.
We may disclose the information we hold about you to third parties when such disclosure is necessary to comply with our obligations under Hong Kong law, protect your legitimate interests, or the interests of our other Users or third parties in administrative, judicial, or criminal proceedings.
Purpose Of Information Processing
The Company collects and processes Data from or about you in order to properly fulfill its obligations in providing the Services (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, and the billing and charging of our Services), to provide you with the opportunity to use personalized features of the Services, and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies. We will indicate to you the personal Data without which we will not be able to provide you the Services. As mentioned above, you may decline to provide us with the requested personal Data, but in such case, we may not be able to provide the Services to you.
Depending on your relationship with us, your personal Data may be collected, used, disclosed and/or processed for one or more of the following purposes and, where you are a data subject in the EEA, on the following legal bases recognized under the GDPR:
Purposes of processing
Legal bases for processing
(a)
For editorial purposes
- consent
- legitimate interests (to allow us to prepare and enhance our Services)
(b)
To provide our Services to you (e.g international bot of the Company)
- consent
- contract performance
- legitimate interests (to allow us to provide our Services)
(c)
To send you promotions as well as marketing and advertising materials (including direct marketing – see “Direct Marketing” section below)
- consent
(d)
To conduct market research, profiling and statistical analysis and other development activities
- consent
- legitimate interests (to allow us to provide an improve our Services)
(e)
To verify your payments
- contract performance
- legitimate interests (to ensure payments have been properly made)
(f)
To send you information about any administrative changes, updates and/or amendments to our policies, terms and conditions
- consent
- contract performance
- legitimate interests (to keep you informed about changes that may affect you)
(g)
To respond to or follow up on your queries, requests and/or complaints
- legitimate interests (to allow us to respond to you)
(h)
To protect and enforce our contractual and legal rights and obligations
- legal claims
(i)
To comply with any applicable laws and regulations or to assist in law enforcement and/or investigations by any governmental authority, public agency, statutory board or similar authority
- legal obligation
- legal claims
- legitimate interests (to prevent unlawful activities)
Legal Bases
Where you are a data subject in the EEA, the legal bases for our processing and use of your personal data are set out above and further elaborated as follows:
(a) Consent
Where you have consented to our use of your personal Data. You may withdraw your consent to the use of your personal Data by contacting us.
(b) Contract performance
Where processing of your personal Data is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract with us;
(c) Legal obligation
Where we need to use your personal Data to comply with our legal obligations;
(d) Legitimate interests
Where our use of your personal Data is necessary for our legitimate interests. We will only rely on this basis if we consider that such legitimate interests are not overridden by any interests or fundamental rights and freedoms that you may have, or any prejudice that you may suffer, from the relevant use of your personal Data; and
(e) Legal claims
Where your personal Data is necessary for us to establish, exercise or defend any legal claims.
Disclosure Of Your Personal Data
We have a legitimate interest in properly administering the Services. In addition, our use of your Data may be necessary for the performance of the Services that you have requested. In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organizations or parties outside the Company (which may be within or outside of Hong Kong) (collectively, “Organizations”). Your Data is disclosed to these Organizations for the strict purpose of enabling us to supply our Services to you.
We take the required steps to ensure that these Organizations are bound by appropriate confidentiality and privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing – see “Direct Marketing” section below).
For the Services to function properly, we may share information about you with payment method providers with whom we have agreements. Before such transfer, we undertake ensuring that the chosen payment method provider processes the information received from us with the same care that we provide for our Users.
For the proper functioning of the Services, we may transfer your Data to our partners outside of Hong Kong (cross-border data transfer). By using our Services, you give us explicit and unambiguous consent to the transfer, processing, and storage of your Data outside of Hong Kong. In the event that we do transfer your Data outside of Hong Kong, we will do so in compliance with the prevailing requirements of the Ordinance and the GDPR where applicable.
We may disclose information we hold about you to third parties when such disclosure is necessary to comply with our obligations under Hong Kong law, protect your legitimate interests, or the interests of our other Users or third parties in administrative, judicial, or criminal proceedings.
In addition, we may disclose your Data:
• to your authorized representatives and/or your legal advisers when requested by you to do so;
• for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties:
- credit-reporting and fraud-checking agencies;
- to financial institutions, charge or credit card issuing companies, credit providers, credit bureau, collection agencies or security agencies;
- our affiliates, overseas offices, assignees, transferees and representatives; and/or
- our professional advisers, including our accountants, auditors, lawyers and insurers.
• to government and regulatory authorities and other organisations, as required or authorised by law;
• to organisations who manage our business and corporate strategies, including those involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our corporate risk and funding functions (e.g. securitisation); and/or
• to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business.
In situations in which the above third parties receive your personal Data from us, we will require the third parties to exercise reasonable care in protecting your personal Data so that it is in compliance with the PDPO and (where applicable) the GDPR.
Direct Marketing
We may, in compliance with applicable laws, rules, regulations and license requirements, use your Data (including without limitation name, contact information, phone number, residential/office address and email address and information about the Services you have engaged the Company to provide), for us (including the Company and its respective subsidiaries, affiliates and associated companies) and our respective dealers, suppliers, licensors, providers and/or business partners (collectively, “Service Providers”)) to provide you with direct marketing content (pursuant to which we may or may not receive remuneration in return), including sending to you notices and/or updates about gifts, discounts, privileged offers, benefits and promotions related to Services offered by us and/or the Service Providers.
We will use and provide your personal Data for direct marketing purpose only in accordance with the PDPO.
You may indicate your consent to the intended use and provision of your personal Data for direct marketing purposes above by ticking the box(es) indicating your consent when providing us with your personal Data through our websites or through our prescribed forms.
We will honor each individual's request to not use his/her Data for the purposes of direct marketing. If you prefer not to receive any direct marketing communications from us or our business partners, please refer to the section below on how to opt out of our direct marketing communications.
Retention Of Your Data
We record, organize, accumulate, store, refine (update, change), and extract information about you using databases located in Hong Kong.
Your Data will only be retained for as long as is necessary to fulfill the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
Your Data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.
When destroying personal Data, we will take commercially reasonable and technically feasible measures to make the Data irrecoverable or irreproducible, as may be required by applicable law.
Information Security
We will take all reasonable precautions to protect your information. We use technical, contractual, administrative, and physical security measures to protect the information we hold. Security measures, such as restricted access and use of passwords and encryption, have been taken to protect your information from loss or theft, as well as from unauthorized access, disclosure, copying, use, or alteration.
All information we hold about you is stored on our secure servers in accordance with our data protection policy. In order to provide the highest quality services and due to the technical features of performing certain functions of the Service, some information, such as email, may be stored on our servers in an open data warehouse, but using the same security standards that we use for secure servers.
Please note that data transmission over the Internet or via email is not completely secure. We cannot guarantee That you will be protected from interception, misappropriation, misuse, or alteration, or that your information will not be disclosed as a result of illegal actions of third parties. We cannot guarantee the security of your information at the time it is transmitted. You should not send confidential information unless your email is encrypted or your browser indicates that access to our Service is secure.
Your Legal Rights
In this section, we have summarized your rights under the applicable laws of Hong Kong. We do not claim that this list is exclusive or complete. You should read the relevant laws and regulations yourself to fully understand your rights.
(a) Right to access
You have the right to confirm whether or not we process your Data. Upon your request, we will provide you with a list of your personal Data that we have. The first copy will be provided free of charge, but additional copies may incur a reasonable fee. You can access your personal Data through the Services or through the details stated in the “Contact us” section below.
(b) Right to rectification
You have the Right to correct any inaccuracies in the Data about you and, taking into account the purposes of processing, to fill in any incomplete Data about you.
(c) Right to deletion
You have the right to delete your Data without undue delay and no later than one month after receiving your valid request. We may continue to process your Data in order to establish, enforce, or defend legal claims.
(d) Right to restrict processing
You have the right to restrict the processing of your personal Data in the following cases: you dispute the accuracy of personal Data; the processing is illegal, but you are against deletion; we no longer need your Data for the purposes of our processing, but you need personal Data to create, execute, or defend legal claims; and you objected to the processing pending verification of this objection.
(e) Right to object to processing
You have the right to object to our processing of your Data on grounds related to your specific situation. If you make such an objection, we will stop processing your information, except in cases where the continued processing of your information is necessary to establish, exercise, or protect the rights and legitimate interests of third parties.
(f) Right to object to direct marketing
You have the right to object to direct marketing (including any profiling for such purposes) at any time. For details of direct marketing please see the relevant section above.
(g) Right to complain
If you believe that the processing of your information violates applicable laws, you have the right to file a complaint with the relevant supervisory authority responsible for data protection. We will also implement and maintain a complaints process whereby you will be able to contact us. We will work with you to bring the complaint to a satisfactory conclusion for both parties.
(h) Right to withdraw consent
If the legal basis for our processing of your personal information is only consent, you have the right to withdraw this consent at any time. Revoking consent to the processing of your Data does not affect the legality of our processing of your data until such time as we receive such revocation.
(i) Right to erasure (right to be forgotten)
Where we process personal Data it is normally because there is a statutory basis for the processing. Where we receive a request from you looking to exercise your right of erasure then we will carry out an assessment of whether the Data can be erased without affecting our ability to provide future services to you or fulfil statutory obligations.
(j) Right to Data portability
We process personal Data we collect because there is normally a statutory basis for the processing. Where the Company has collected personal Data from or about you by consent or by contract then you have a right to receive the Data in electronic format to give to another data controller.
(k) Right not to be subject to automated decision making
You have the right not to be subject to a decision based solely on automated processing, where such decisions would have a legal or significant effect concerning you.
If you wish to access or amend any of your Data we hold, or request that we delete (only applicable where the rights to erasure is required by law) any of your information that is no longer necessary for the provision of our Services, or exercise any of the above rights, you may contact us in the manner as set forth under the “Contact Us” section.
If you are a user of our Services, you may exercise your right of access and correction by logging on to your account where you will be able to view and correct the Data held by us about you. If you are not a user of our Services, you may write to us at the details stated in the “Contact us” section below.
We may apply an administrative charge for providing you with access to your Data in response to such request. However, where you are a data subject in the EEA, we will not charge a fee when we deal with your requests to exercise the rights (a) to (f), (h) to (i) above.
Again, you may decline to share Data with us and/or withdraw any consents which you may have provided, in which case, we may not be able to provide you with some of our Services.
At any time, you may object to us holding or processing your Data, on legitimate grounds, save and except as otherwise permitted by the applicable law.
Opt-Out
If you do not wish to receive any further information from us regarding our Services, offers, promotions or events via email, you may unsubscribe by clicking the unsubscribe link included in our email correspondence.
If you do not wish to be contacted via voice call, text message and/or fax message regarding our Services, offers, promotions or events, you may inform us via email or letter. Please refer to our contact details stated in the “Contact us” section below.
If you do not want your personal Data to be provided to us (including the Company and its respective subsidiaries, affiliates and associated companies) and or Service Providers for their use in direct marketing, you may opt-out of such provision by contacting us via email or letter. Please refer to our contact details stated in the “Contact us” section below.
Please note that if you withdraw your consent for a limited purpose, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such personal Data may still be shared, as permitted under the PDPO, (where applicable) GDPR and other applicable law.
Automated Decision Making And Profiling
In connection with our business, we will use your personal Data to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to determine what marketing offers are most likely to be of interest, to ensure security of our systems, to detect fraud or to profile you or assign you to a particular segment. Some of these decisions may be taken on an automated basis including by matching your personal Data against other information in our possession or against data models created for us. If you are assigned to a segment, we may use the segment information to tailor our marketing communications (if permitted under applicable laws) to include offers and content that are more relevant to you. You will not be subject to automated decisions that produce legal effects concerning you or similarly significantly affect you, unless we have a lawful basis for doing so.
Links To Other Websites
Our website may contain links to other websites run by other organizations. This privacy notice applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our website.
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
Contact Us
For all issues and enquiries regarding our compliance with our obligations under the Ordinance and the GDPR where applicable, and any request for access to, correction or deletion of your Data, please contact us in writing at:
Smart Glocal Services Limited
Registration number: 2952290
Address: Room B2, Unit C, 1/F, Freder Centre, 68 Sung Wong Toi Road, Kowloon, Hong Kong SAR
or via email to: hello@smart-glocal.com
To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.
Version No. 3
This document was last updated on December 19, 2023.
Privacy Statement
This Privacy policy (the "Policy") sets out how Smart Glocal Services Limited (the "Company," "we," "our") applies to any personal data or information (“Data”) that we may collect from or about you (the "User," "you," "your") while using the Company's software and services, collectively referred to as the "Services."
PLEASE READ THIS PRIVACY POLICY. BY USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND FULLY AGREE TO ALL THE TERMS OF THIS POLICY. YOU MAY NOT USE THE SERVICES IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY.
By using our Services, you agree that you have read, understand and unconditionally accept all the terms of this Policy. If you do not agree to any provision of this Policy, or you believe that any provision of this Policy infringes on your rights, or in any other way puts you at a disadvantage, then you must immediately stop any use of our Services.
Protecting Your Privacy
The relationship related to the collection, storage, processing, and protection of information provided by Users is governed by this Policy and the laws of Hong Kong.
This Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal Data you have provided to us, as well as to help you to make an informed decision before providing us with your personal Data.
However, we are committed to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, in particular and where applicable, this Policy, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal Data and on the free movement of such Data (the “GDPR”) where applicable.
For the purpose of the GDPR, Smart Glocal Services Limited, whose address is at Suite A, 11/F, Arthur Commercial Building, 33 Arthur Street, Yaumatei, Kowloon, Hong Kong, is the controller who determine the purposes and means of processing of your personal Data collected through websites owned and/or operated by us or on our behalf (including https://smart-glocal.com/) (collectively, “Our Website(s)”) or other channels described in paragraph 2 of this Privacy Policy.
We constantly strive to improve our Services by providing you with new features and capabilities, so we may make changes to this Policy from time to time. If we make changes, we will notify you in any way we can. At the same time, we recommend that you periodically check the date of the last update of this Policy, indicated at its top, and, if it is updated, get acquainted with the new version of the Policy.
Personal Data We May Collect From Or About You
When you use the Services, we may collect and process the following information from or about you:
(a) Personal information
This is information that identifies a specific person. When you use the Services, we may ask you to provide us with certain information about yourself that will help us identify you among our Users and properly provide you with Services. This may include information that you provide to us when registering or using the Services, information that you provide when communicating with us (for example, when contacting support), or information that we may receive from other Users. This information may include your name, gender, nationality, address, date and place of birth, identification document details, email address, mobile phone number, your photo and videos, and other registration information, financial information such as your bank card number or account details and any other information that you may provide to us on your own or upon our request or via other forms of interactions with us.
(b) Cookies
These are small pieces of information stored by your browser on your device at the request of the Services. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. This information helps us to build a profile of our users and is used for:
• identifying you when you visit our Services and when you navigate through it;
• determining your status when logging in to the Services;
• storing information about your preferences and personalize the Services for you;
• protecting our Users ' accounts, including preventing fraudulent use of their credentials and to protect the Services as a whole;
• analysis of the use and effectiveness of our Services;
• saving your preferences regarding the use of cookies in a more general way.
Most browsers automatically accept cookies. You can, however, modify your browser settings to disable cookies. If you choose to do so, some of the functionality of our websites may be impaired.
We may also use cookies from third parties to help us provide you and others with social plugins and other customized content and experiences.
Some cookies will not collect information that personally identifies you. They will collect more general information such as how users arrive at and use our websites, or a user’s general location. However, some other cookies can identify you and may contain or collect personal Data. The type of information we collect because of a cookie is specific to your computer and may include, without limitation, the Internet Protocol (IP) address and the date and time you accessed our websites. The data stored on a "cookie" can be retrieved by us when you visit Our Website(s).
When you visit our website(s), you will see a pop-up seeking your consent to the placing and use of cookies on your device. You may either give such consent or reject the placing and use of cookies. You can also remove existing cookies from your device using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies see aboutcookies.org, which contains comprehensive information about how to restrict or block cookies on a wide variety of browsers.
(c) Information about your device
Using the Services, our servers automatically record certain information about your device. This information may include information such as the web request, date and time of the request, IP address, your registration information, browser type, operating system type and version, time zone setting, device and model information, unique device ID (such as IMEI number, MAC address, mobile phone number), mobile network information, and so on.
(d) Information about your location
We use GPS technology and your IP address to determine your location while using the Services. We do this to prevent fraud (for example, when your location and device type differ from the one you normally use).
(e) Information about you from third-party services
If you provide your account information from third-party services (Facebook, Google, etc.), we may receive Data about you from these services. By entering your account information in third-party services, you give us your consent to receive Data about you from these services and use them in accordance with the terms of this Policy.
(d) Impersonal information.
This is information that does not identify you as a specific person (i.e. non-personal data). This information may include information such as the unified resource index (url) of the website that you visited before and after visiting our Services, information received about you from search engines, web beacons, etc. This information itself does not identify you as a specific person, although it may be unique and/or contain information that you may consider personal.
Ways To Use Information
We may use the information we have about you to provide you with the Service, improve the Service and analyze its use, and conduct marketing and advertising campaigns. We may also use the information we have to resolve problems with the Service, resolve conflicts and disputes, perform administrative tasks, contact you, ensure compliance with our policies and applicable laws, and cooperate with law enforcement agencies.
For the Service to function properly, we may share information about you with payment method providers with whom we have agreements. Before such transfer, we undertake ensuring that the chosen payment method provider processes the information received from us with the same care that we provide for our Users.
We may disclose the information we hold about you to third parties as part of assignment or novation of your rights and obligations under the User Agreement.
For the proper functioning of the Service and/or in the event of novation or assignment of the User Agreement as described above, we may transfer your data to our partners outside of Hong Kong (cross-border data transfer). By using our Services, you give us explicit and unambiguous consent to the transfer, processing, and storage of your data outside of Hong Kong.
We may disclose the information we hold about you to third parties when such disclosure is necessary to comply with our obligations under Hong Kong law, protect your legitimate interests, or the interests of our other Users or third parties in administrative, judicial, or criminal proceedings.
Purpose Of Information Processing
The Company collects and processes Data from or about you in order to properly fulfill its obligations in providing the Services (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, and the billing and charging of our Services), to provide you with the opportunity to use personalized features of the Services, and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies. We will indicate to you the personal Data without which we will not be able to provide you the Services. As mentioned above, you may decline to provide us with the requested personal Data, but in such case, we may not be able to provide the Services to you.
Depending on your relationship with us, your personal Data may be collected, used, disclosed and/or processed for one or more of the following purposes and, where you are a data subject in the EEA, on the following legal bases recognized under the GDPR:
Purposes of processing
Legal bases for processing
(a)
For editorial purposes
- consent
- legitimate interests (to allow us to prepare and enhance our Services)
(b)
To provide our Services to you (e.g international bot of the Company)
- consent
- contract performance
- legitimate interests (to allow us to provide our Services)
(c)
To send you promotions as well as marketing and advertising materials (including direct marketing – see “Direct Marketing” section below)
- consent
(d)
To conduct market research, profiling and statistical analysis and other development activities
- consent
- legitimate interests (to allow us to provide an improve our Services)
(e)
To verify your payments
- contract performance
- legitimate interests (to ensure payments have been properly made)
(f)
To send you information about any administrative changes, updates and/or amendments to our policies, terms and conditions
- consent
- contract performance
- legitimate interests (to keep you informed about changes that may affect you)
(g)
To respond to or follow up on your queries, requests and/or complaints
- legitimate interests (to allow us to respond to you)
(h)
To protect and enforce our contractual and legal rights and obligations
- legal claims
(i)
To comply with any applicable laws and regulations or to assist in law enforcement and/or investigations by any governmental authority, public agency, statutory board or similar authority
- legal obligation
- legal claims
- legitimate interests (to prevent unlawful activities)
Legal Bases
Where you are a data subject in the EEA, the legal bases for our processing and use of your personal data are set out above and further elaborated as follows:
(a) Consent
Where you have consented to our use of your personal Data. You may withdraw your consent to the use of your personal Data by contacting us.
(b) Contract performance
Where processing of your personal Data is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract with us;
(c) Legal obligation
Where we need to use your personal Data to comply with our legal obligations;
(d) Legitimate interests
Where our use of your personal Data is necessary for our legitimate interests. We will only rely on this basis if we consider that such legitimate interests are not overridden by any interests or fundamental rights and freedoms that you may have, or any prejudice that you may suffer, from the relevant use of your personal Data; and
(e) Legal claims
Where your personal Data is necessary for us to establish, exercise or defend any legal claims.
Disclosure Of Your Personal Data
We have a legitimate interest in properly administering the Services. In addition, our use of your Data may be necessary for the performance of the Services that you have requested. In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organizations or parties outside the Company (which may be within or outside of Hong Kong) (collectively, “Organizations”). Your Data is disclosed to these Organizations for the strict purpose of enabling us to supply our Services to you.
We take the required steps to ensure that these Organizations are bound by appropriate confidentiality and privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing – see “Direct Marketing” section below).
For the Services to function properly, we may share information about you with payment method providers with whom we have agreements. Before such transfer, we undertake ensuring that the chosen payment method provider processes the information received from us with the same care that we provide for our Users.
For the proper functioning of the Services, we may transfer your Data to our partners outside of Hong Kong (cross-border data transfer). By using our Services, you give us explicit and unambiguous consent to the transfer, processing, and storage of your Data outside of Hong Kong. In the event that we do transfer your Data outside of Hong Kong, we will do so in compliance with the prevailing requirements of the Ordinance and the GDPR where applicable.
We may disclose information we hold about you to third parties when such disclosure is necessary to comply with our obligations under Hong Kong law, protect your legitimate interests, or the interests of our other Users or third parties in administrative, judicial, or criminal proceedings.
In addition, we may disclose your Data:
• to your authorized representatives and/or your legal advisers when requested by you to do so;
• for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties:
- credit-reporting and fraud-checking agencies;
- to financial institutions, charge or credit card issuing companies, credit providers, credit bureau, collection agencies or security agencies;
- our affiliates, overseas offices, assignees, transferees and representatives; and/or
- our professional advisers, including our accountants, auditors, lawyers and insurers.
• to government and regulatory authorities and other organisations, as required or authorised by law;
• to organisations who manage our business and corporate strategies, including those involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our corporate risk and funding functions (e.g. securitisation); and/or
• to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business.
In situations in which the above third parties receive your personal Data from us, we will require the third parties to exercise reasonable care in protecting your personal Data so that it is in compliance with the PDPO and (where applicable) the GDPR.
Direct Marketing
We may, in compliance with applicable laws, rules, regulations and license requirements, use your Data (including without limitation name, contact information, phone number, residential/office address and email address and information about the Services you have engaged the Company to provide), for us (including the Company and its respective subsidiaries, affiliates and associated companies) and our respective dealers, suppliers, licensors, providers and/or business partners (collectively, “Service Providers”)) to provide you with direct marketing content (pursuant to which we may or may not receive remuneration in return), including sending to you notices and/or updates about gifts, discounts, privileged offers, benefits and promotions related to Services offered by us and/or the Service Providers.
We will use and provide your personal Data for direct marketing purpose only in accordance with the PDPO.
You may indicate your consent to the intended use and provision of your personal Data for direct marketing purposes above by ticking the box(es) indicating your consent when providing us with your personal Data through our websites or through our prescribed forms.
We will honor each individual's request to not use his/her Data for the purposes of direct marketing. If you prefer not to receive any direct marketing communications from us or our business partners, please refer to the section below on how to opt out of our direct marketing communications.
Retention Of Your Data
We record, organize, accumulate, store, refine (update, change), and extract information about you using databases located in Hong Kong.
Your Data will only be retained for as long as is necessary to fulfill the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
Your Data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.
When destroying personal Data, we will take commercially reasonable and technically feasible measures to make the Data irrecoverable or irreproducible, as may be required by applicable law.
Information Security
We will take all reasonable precautions to protect your information. We use technical, contractual, administrative, and physical security measures to protect the information we hold. Security measures, such as restricted access and use of passwords and encryption, have been taken to protect your information from loss or theft, as well as from unauthorized access, disclosure, copying, use, or alteration.
All information we hold about you is stored on our secure servers in accordance with our data protection policy. In order to provide the highest quality services and due to the technical features of performing certain functions of the Service, some information, such as email, may be stored on our servers in an open data warehouse, but using the same security standards that we use for secure servers.
Please note that data transmission over the Internet or via email is not completely secure. We cannot guarantee That you will be protected from interception, misappropriation, misuse, or alteration, or that your information will not be disclosed as a result of illegal actions of third parties. We cannot guarantee the security of your information at the time it is transmitted. You should not send confidential information unless your email is encrypted or your browser indicates that access to our Service is secure.
Your Legal Rights
In this section, we have summarized your rights under the applicable laws of Hong Kong. We do not claim that this list is exclusive or complete. You should read the relevant laws and regulations yourself to fully understand your rights.
(a) Right to access
You have the right to confirm whether or not we process your Data. Upon your request, we will provide you with a list of your personal Data that we have. The first copy will be provided free of charge, but additional copies may incur a reasonable fee. You can access your personal Data through the Services or through the details stated in the “Contact us” section below.
(b) Right to rectification
You have the Right to correct any inaccuracies in the Data about you and, taking into account the purposes of processing, to fill in any incomplete Data about you.
(c) Right to deletion
You have the right to delete your Data without undue delay and no later than one month after receiving your valid request. We may continue to process your Data in order to establish, enforce, or defend legal claims.
(d) Right to restrict processing
You have the right to restrict the processing of your personal Data in the following cases: you dispute the accuracy of personal Data; the processing is illegal, but you are against deletion; we no longer need your Data for the purposes of our processing, but you need personal Data to create, execute, or defend legal claims; and you objected to the processing pending verification of this objection.
(e) Right to object to processing
You have the right to object to our processing of your Data on grounds related to your specific situation. If you make such an objection, we will stop processing your information, except in cases where the continued processing of your information is necessary to establish, exercise, or protect the rights and legitimate interests of third parties.
(f) Right to object to direct marketing
You have the right to object to direct marketing (including any profiling for such purposes) at any time. For details of direct marketing please see the relevant section above.
(g) Right to complain
If you believe that the processing of your information violates applicable laws, you have the right to file a complaint with the relevant supervisory authority responsible for data protection. We will also implement and maintain a complaints process whereby you will be able to contact us. We will work with you to bring the complaint to a satisfactory conclusion for both parties.
(h) Right to withdraw consent
If the legal basis for our processing of your personal information is only consent, you have the right to withdraw this consent at any time. Revoking consent to the processing of your Data does not affect the legality of our processing of your data until such time as we receive such revocation.
(i) Right to erasure (right to be forgotten)
Where we process personal Data it is normally because there is a statutory basis for the processing. Where we receive a request from you looking to exercise your right of erasure then we will carry out an assessment of whether the Data can be erased without affecting our ability to provide future services to you or fulfil statutory obligations.
(j) Right to Data portability
We process personal Data we collect because there is normally a statutory basis for the processing. Where the Company has collected personal Data from or about you by consent or by contract then you have a right to receive the Data in electronic format to give to another data controller.
(k) Right not to be subject to automated decision making
You have the right not to be subject to a decision based solely on automated processing, where such decisions would have a legal or significant effect concerning you.
If you wish to access or amend any of your Data we hold, or request that we delete (only applicable where the rights to erasure is required by law) any of your information that is no longer necessary for the provision of our Services, or exercise any of the above rights, you may contact us in the manner as set forth under the “Contact Us” section.
If you are a user of our Services, you may exercise your right of access and correction by logging on to your account where you will be able to view and correct the Data held by us about you. If you are not a user of our Services, you may write to us at the details stated in the “Contact us” section below.
We may apply an administrative charge for providing you with access to your Data in response to such request. However, where you are a data subject in the EEA, we will not charge a fee when we deal with your requests to exercise the rights (a) to (f), (h) to (i) above.
Again, you may decline to share Data with us and/or withdraw any consents which you may have provided, in which case, we may not be able to provide you with some of our Services.
At any time, you may object to us holding or processing your Data, on legitimate grounds, save and except as otherwise permitted by the applicable law.
Opt-Out
If you do not wish to receive any further information from us regarding our Services, offers, promotions or events via email, you may unsubscribe by clicking the unsubscribe link included in our email correspondence.
If you do not wish to be contacted via voice call, text message and/or fax message regarding our Services, offers, promotions or events, you may inform us via email or letter. Please refer to our contact details stated in the “Contact us” section below.
If you do not want your personal Data to be provided to us (including the Company and its respective subsidiaries, affiliates and associated companies) and or Service Providers for their use in direct marketing, you may opt-out of such provision by contacting us via email or letter. Please refer to our contact details stated in the “Contact us” section below.
Please note that if you withdraw your consent for a limited purpose, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such personal Data may still be shared, as permitted under the PDPO, (where applicable) GDPR and other applicable law.
Automated Decision Making And Profiling
In connection with our business, we will use your personal Data to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to determine what marketing offers are most likely to be of interest, to ensure security of our systems, to detect fraud or to profile you or assign you to a particular segment. Some of these decisions may be taken on an automated basis including by matching your personal Data against other information in our possession or against data models created for us. If you are assigned to a segment, we may use the segment information to tailor our marketing communications (if permitted under applicable laws) to include offers and content that are more relevant to you. You will not be subject to automated decisions that produce legal effects concerning you or similarly significantly affect you, unless we have a lawful basis for doing so.
Links To Other Websites
Our website may contain links to other websites run by other organizations. This privacy notice applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our website.
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
Contact Us
For all issues and enquiries regarding our compliance with our obligations under the Ordinance and the GDPR where applicable, and any request for access to, correction or deletion of your Data, please contact us in writing at:
Smart Glocal Services Limited
Registration number: 2952290
Address: Room B2, Unit C, 1/F, Freder Centre, 68 Sung Wong Toi Road, Kowloon, Hong Kong SAR
or via email to: hello@smart-glocal.com
To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.