A. Our Commitment to the Protection of Your Personal Data
We are committed to protecting the personal data (hereinafter “Personal Data”) in our possession and your privacy. In order to ensure that you make an informed and assured decision in providing your Personal Data, we provide the details on our collection and use of your Personal Data herein. We will also explain the choices you have before consenting to our collection and use of your Personal Data.
B. Types of Personal Data that We Collect
It is necessary to our business operation (including but not limited to the verification of your identity, the activation and management of your account, the handling of security or technical issues, and to respond to your expectations on our products and services) (hereinafter “services”) that we collect, use and retain certain Personal Data.
We collect different types of Personal Data in accordance with your requests or in furtherance of the services and products that we provide. These types of Personal Data may include:
- Contact Information, such as name, alias, address, phone number, social media user ID, email address, and similar contact data.
- Organization and contacts Information, such as your employer or organisations that you are a member of, information about your colleagues or those within your organisation, your status with an organisation, and similar data.
- Account Information, such as security-related information (including usernames and passwords, authentication methods, and roles), service-related information (including purchase history and account profiles), billing-related information (including payment, shipping, and billing information), and similar data.
- User content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our services (including information in alerts, folders, notes, and shares of content), and similar data.
- Device & Browser Information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
- Usage Information and Browsing History, such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, API calls, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, purchases or next steps you may make after seeing an advertisement, and marketing preferences), and similar data.
- Location Data, such as the location of your device, your household, and similar location data.
- Demographic Information, such as country, preferred language, age and date of birth, marriage status, gender, physical characteristics, personal or household/familial financial status and metrics, military status, and similar data.
- Your Image, such as still pictures, video, voice, and other similar data.
- Identity Information, such as government-issued identification information, tax identifiers, social security numbers, other government-issued identifiers, and similar data.
- Financial Information, such as billing address, credit card information, billing contact details, and similar data.
- Social media and online content, such as information in social media and online profiles, online posts, and similar data.
- Career, education, and employment related information, such as job preferences or interests, work performance and history, salary history, status as a veteran, nationality and immigration status, demographic data, disability-related information, application information, professional licensure information and related compliance activities, accreditations and other accolades, education history (including schools attended, academic degrees or areas of study, academic performance, and rankings), and similar data.
Some Personal Data are necessary for the provision of certain services. If you are not able to provide such Personal Data for these certain services, we may not be able to provide the said products and services to you. If you provide your Personal data to us, you are deemed to have done so on a fair and reasonable basis.
You agree and warrant the registration information and other required data that you provide are truthful and accurate; and you shall maintain the accuracy of the said data.
C. Purposes of the Collection and Use of Personal Data
We may collect and use your Personal Data for any one or more of the following purposes (hereinafter “Purposes”):
- Provide, deliver, analyze, and administer our services (including in connection with the performance of a contract).
- For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our current services.
- Process transactions related to our services and administer accounts or profiles related to you or your organization (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).
- Personalize and make recommendations related to our services and other offerings.
- Contact and communicate with you in connection with our services or other notifications, programs, events, or updates that you may have registered for.
- Send you offers, advertising, and marketing materials, including to provide personalized advertising to you.
- Conduct and communicate with you regarding recruiting and human resources administration.
- Comply with your instructions or to fulfill other, specified purposes for which you have given your consent.
- Detect and prevent fraud and abuse to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our Service or to identify and authenticate you before we provide you with certain information.
- Exercise our rights and to protect our and others’ rights and/or property, including to take action against those that seek to violate or abuse our services.
- Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or authority, as well as to fulfill our contractual obligations with our customers when they arrange access to our services for you.
- Effectuate the sale, merger, acquisition, or other disposition of our business (including in connection with any bankruptcy or similar proceedings).
Without first seeking your prior consent, we shall not knowingly or intentionally use, share or sell your Personal Data for any purpose not related to the foregoing, or use the same for purposes not relevant to the purposes stated in the Collection of Personal Data Declaration as provided to you at the time of the collection of Personal Data.
D. Disclosure and Transfer of Personal Data
In furtherance to the Purposes stated under the foregoing paragraph headed “C. Purposes of the Collection and Use of Personal Data,” we may transfer or disclose your Personal Data to third parties within or outside of Hong Kong, or share it with third party or authorize the third party to review the same. Your Personal Data may be transferred within or outside of Hong Kong. The said third party may include:
- Nibanme and its affiliates, associates, holding company, subsidiary and related entities. We may share your personal information amongst the companies within the NIBANME group of companies/entities.
- Your Organization and Contacts. We may share your personal information with your organization and others with whom you have a relationship in order to fulfill or perform a contract or other legal obligation, including with our customer that arranges access to our Services for you and pays us in connection with your access. We may also share your personal information with your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s).
- Business Partners. We may share your personal information with our business partners to jointly offer, provide, deliver, analyze, administer, improve, and personalize products or services or to host events. We may also pass certain requests from you or your organization to these business providers.
- Third Party Content Providers. We may share your personal information with our third party content providers to perform tasks on our behalf and to assist us in providing, delivering, analyzing, administering, improving, and personalizing content that are delivered as part of our Services. We may also pass certain requests from you or your organization to these content providers.
- Social Media Services. We may work with certain third party social media providers to offer you their social networking services through our services. These social networking services may be able to collect information about you, including your activity on our services. These third party social networking services also may notify your friends, both on our services and on the social networking services themselves, that you are a user of our services or about your use of our Services, in accordance with applicable law and their own privacy policies.
- Third Party Service Providers. We may share your personal information with our third party service providers to perform tasks on our behalf and to assist us in offering, providing, delivering, analyzing, administering, improving, and personalizing our services. For example, service providers who assist us in performing, delivering, or enhancing certain products and services related to our delivery and operation of our services, who provide technical and/or customer support on our behalf, who provide application or software development and quality assurance, who provide tracking and reporting functions, research on user demographics, interests, and behavior, and other products or services. These third party service providers may also collect personal information about or from you in performing their services and/or functions on our services. We may also pass certain requests from you or your organization to these third party service providers.
- Advertisers. We may share your personal information with advertisers, advertising exchanges, and marketing agencies that we engage for advertising services, to deliver advertising on some of our services, and to assist us in advertising our brand and products and services. Those advertising services may also target advertisements on third party websites based on cookies or other information indicating previous interaction with us and/or our services.
- Users. For some of our services, we aggregate information from public records, phone books, social networks, marketing surveys, business websites, and other sources made available to us to create listings and profiles that become a part of our content in these services, such as attorney and legal professional directories. These listings and profiles may be made available to all users of these services. As described above, we may also share your personal information with other users who are your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s). Additionally, if you choose to include your personal information in any reviews, comments, or other posts that you create, then that personal information may be displayed other users as part of your posting.
- Other Disclosures. We may disclose your personal information to third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request, to enforce our terms and conditions or other rights (including investigations of potential violations of our rights), to detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of NIBANME, our users, or the public.
The Personal Data that you provide may be received from or transferred to other jurisdictions outside of Hong Kong for the above Purposes.
E. [Introduction and Declaration of Automatic Renewal services
If you use App Store to confirm the purchase of subscription plans, any subscription fee shall be deducted directly from your Apple ID. If you do not disable the automatic renewal option within the 24 hours before the end of the subscription period, automatic renewal shall apply to your account. You may disable the automatic renewal option in the account setting of App Store at any time.]
Cookies will only save the data that you provide or of the choices you made when you visit our website. For example, unless you choose to enter your email address, the website is not able to identify your email. Permitting a given website or smartphone mobile app to develop cookies does not mean permitting the said website, any other website or smartphone mobile app to read the other parts of your computer or mobile phone. Only the cookies developed by the said website can read the relevant cookies. As long as any of the Purposes for which you have agreed to allow us to use your Personal Data remain valid, we will preserve the data collected from your computer, installed hardware or smartphone mobile app via the cookies and/or action tags (also known as single pixel GIF or web beacon). We may also work with a third party to assess the effectiveness of our advertisements or to investigate the usage and activities of any of our website or smartphone mobile app. These third parties may read, retrieve and use the said cookies and/or action tags (also known as single pixel GIF or web beacon). The data collected by the cookies and action tags by the said third party remain anonymous.
We may also collect data on your IP address, browser type, website address and the time of access. These types of data are used for internal research. Because these types of data are not personal, they will be processed separately from your Personal Data. In certain special circumstances, the IP address may assist us in deterring and/or preventing abusive behaviors or unlawful activities on the website or smartphone mobile app.
If you interact with us on social media (for example, clicking “like” or “comment” on our mobile app, Facebook or Instagram pages), we may interact with you, and to send messages to you through these platforms. We will interact with you in accordance with the rules of the relevant social media platforms. However, we shall not be liable to the way in which the operators of these platforms collect and process your Personal Data, nor shall we be held responsible for any posts of third party and any other users on our social media account.
G. Direct Marketing
We shall not use your Personal Data to send you our advertisers’ promotional material. The promotional material of our advertisers on our smartphone mobile app is not sent or shown for your viewing with reference to any of your preferences. They are applicable on a general basis and shown to all users of the services.
H. Data Storage
Subject to the provisions under applicable laws, statutes, regulations or accountancy requirements, we shall store the Personal Data that you provide to us with appropriate means. The time of storage shall not exceed the time necessary to effectuate the Purposes as stated in the foregoing. All such relevant data shall be deleted when the said Purposes have been fulfilled
I. Data Security
In order to ensure the proper use and the accuracy of the collected Personal Data, and to prevent unauthorized or accidental access, processing, deletion or other uses of the Personal Data, we have implemented a number of internal policies (including physical measures, electronic safeguards and management guidelines) to protect the safety of Personal Data. However, we are unable to guarantee the complete confidentiality of the communication between us. Please protect your password, credit card, debit card and charge card information adequately to prevent unauthorized access to the same.
In order to meet your needs, our smartphone mobile app may contain hyperlinks to third party websites, and the said websites follow different privacy protection practices or policy.
K. Your Rights and Our Contact
You have the right to access or modify your Personal Data in our possession. You may also:
- Request to omit or delete your Personal Data;
- Object to the opening of your Personal Data file.
Should you wish to exercise any of the above rights, or to obtain a copy of any of your Personal Data, or if you believe that your Personal Data in our collection and retention contain inaccuracies, or to obtain information about our personal data policy and practice and the types of Personal Data in our possession, please contact us as follows:
(Data Protection Officer)
We are committed to providing the appropriate technical measures to enable you to access, update and rectify your Personal Data. When you access, update, rectify and/or delete your Personal Data, we may ask for a verification of your identity as a safeguard of the security of your Personal Data.
Within the permitted extent of applicable laws and regulations, we have the right to reject unreasonable requests (such as requests that will violate the privacy of another). Within the permitted extent of applicable laws and regulations, we have the right to collect reasonable, at-cost fees in handling requests of access to Personal Data.
M. Cancellation of Subscription to Direct Marketing Information
You may elect not to accept any marketing and promotional information from NIBANME. There is no cost in cancelling this option.