PRIVACY POLICY
This
policy sets out the basis on which Nowsnapp of 21/F On Hing
Building, 1 On Hing Terrace, Central, Hong Kong (Company
Number 67853339) (together with our subsidiaries, our holding company,
subsidiaries of our holding company from time to time, collectively called
“Nowsnapp Limited” or “we”) collects
personal data from you and how we process such data.
By visiting our
website www.nowsnapp.com (our “Site”)
or using Nowsnapp or any other applications or software we provide
from time to time (collectively our “App”),
you accept and consent to the practices set out below.
1
Collection of information
1.1
For the purposes outlined in
Clause 2, we may collect and process the following information about you:
(a)
Information you give us – information
that you provide us (which may include your name, address, email address,
telephone number, credit card information and other personal description) by
filling in forms on our Site or our App, or by corresponding with us (by phone,
email or otherwise), for example:
(i)
when you register for an
account with us in our App;
(ii)
when you report any problem to
us;
(iii)
when you use certain features
on our Site or our App;
(iv)
when you request any support
from us; or
(v)
when you complete any survey or
questionnaire we send you.
(b)
Information we collect about you –
information automatically collected when you visit our Site or use our App, for
example:
(i)
technical information,
including the Internet protocol (IP) address used to connect your computer to
the Internet and your log-in information, browser type and version, time zone
setting, browser plug-in types and versions, operating system and platform;
(ii)
information about your visit,
including the full Uniform Resource Locators (URLs), clickstream to, through
and from our site (including date and time), products you viewed or searched
for, page response times, download errors, length of visits to certain pages,
page interaction information (such as scrolling, clicks, and mouse-overs),
methods used to browse away from the page, and any phone number used to call
our customer service number.
1.2
We only retain personal data
for so long as it is necessary. Data may be archived as long as the purpose for
which the data was used still exists.
2
Uses made of the information
2.1
We use information held about
you for the following purposes:
(a)
providing, improving and
developing our services;
(b)
researching, designing and
launching new features or products;
(c)
presenting content and
information in our Site and our App in the most effective manner for you and
for the device you use;
(d)
providing you with alerts,
updates, materials or information about our services or other types of
information that you requested or signed up to;
(e)
collecting overdue amounts;
(f)
responding or taking part in
legal proceedings, including seeking professional advice;
(g)
for direct marketing purposes
(please see further details in Clause 2.2 below);
(h)
communicating with you and
responding to your questions or requests; and
(i)
purposes directly related or
incidental to the above.
2.2
We intend to use your personal
data in direct marketing (i.e. offering or advertising products or services by
sending the relevant information directly to you). We require your consent
specifically for this purpose and you
may opt out any time. For the purpose of this clause:
(a)
the personal data that may be
used in direct marketing are those that you provide to us or we collect from
you under Clause 1.1 above;
(b)
the type of services or
products that may be offered or advertised will be our marketplace
platform, and services requested through the platform by our users;
(c)
the relevant information may be
sent to you by email and in-app message;
(d)
you may opt out any time
by emailing us at support@nowsnapp.com. We will cease to send you
marketing information without charge.
3
Disclosure of your information
We will keep your personal data we hold confidential but you agree
we may provide information to:
(a)
any member of our group, which
means our subsidiaries, our ultimate holding company and its subsidiaries, as
defined in Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the
Law of Hong Kong;
(b)
personnel, agents, advisers,
auditors, contractors, financial institutions, and service providers in
connection with our operations or services (for example staff engaged in the
fulfilment of your order, the processing of your payment and the provision of
support services);
(c)
our overseas offices,
affiliates, business partners and counterparts (on a need-to-know basis only);
(d)
persons under a duty of
confidentiality to us;
(e)
persons to whom we are required
to make disclosure under applicable laws and regulations in any part of the
world; or
(f)
actual or proposed transferees
of our operations (or a substantial part thereof) in any part of the world.
4
Cookies
4.1
Our Site uses cookies to
distinguish you from other users of the Site. This helps us to provide you with
a good experience when you browse our Site and also allows us to improve our
Site.
4.2
A cookie is a small file of
letters and numbers that we store on your browser or the hard drive of your
computer if you agree to the use of cookies. Cookies contain information that
is transferred to your computer’s hard drive.
4.3
We use persistent cookies and
session cookies. A persistent cookie stays in your browser and will be read by
us when you return to our Site or a partner site that uses our services.
Session cookies only last for as long as the session (usually the current visit
to a website or a browser session).
4.4
We use the following
cookies:
(a)
Strictly necessary cookies –
These are cookies that are required for the operation of our Site. They
include, for example, cookies that enable you to log into secure areas of our
website, use a shopping cart or make use of e-billing services.
(b)
Analytical/performance cookies
– They allow us to recognise and count the number of visitors and to see how
visitors move around our Site when they are using it. This helps us to improve
the way our Site works, for example, by ensuring that users are finding what
they are looking for easily.
(c)
Functionality cookies – These
are used to recognise you when you return to our Site. This enables us to
personalise our content for you, greet you by name and remember your
preferences (for example, your choice of language or region).
4.5
You can block cookies by
activating the setting on your browser that allows you to refuse the setting of
all or some cookies. However, if you do so, you may not be able to access all
or parts of our Site.
4.6
We may use third-party web
services on our Site. The service providers that administer these services use
technologies such as cookies (which are likely to be analytical/performance
cookies or targeting cookies), web server logs and web beacons to help us analyse
how visitors use our Site and make the information displayed on it more
relevant to your interests. The information collected through these means
(including IP addresses) is disclosed to these service providers. These
analytics services may use the data collected to contextualise and personalise
the marketing materials of their own advertising network.
5
Third-party sites
Our Site, our App or our communication with you may from time to
time contain links to third-party websites over which we have no control. If
you follow a link to any of these websites, please note that they have their
own practices and policies. We encourage you to read the privacy policies or
statements of these websites understand your rights. We accept no
responsibility or liability for any practices of third-party websites.
6
Security
6.1
All information you provide to
us is stored on our secure servers.
6.2
Any payment transactions will
be encrypted using TLS/SSL technology.
6.3
Where we have given you (or
where you have chosen) a password that enables you to access certain parts of
the Site, you are responsible for keeping this password confidential. We ask
you not to share a password with anyone.
6.4
We restrict access to personal
information to our employees, service providers and contractors on a strictly
need-to-know basis and ensure that those persons are subject to contractual
confidentiality obligations.
6.5
We review our information
collection, storage and processing practices from time to time to guard against
unauthorised access, processing or use.
6.6
Please note, however, the
transmission of information via the Internet is not completely secure. Although
we will do our best to protect your personal data, we cannot guarantee the
security of your data transmitted to our Site; any transmission is at your own
risk.
7
Data transfer
7.1
The data that we collect from
you may be transferred to, and stored at, a destination outside Hong Kong. It
may also be processed by persons referred to in Clause 3 above who operate
outside Hong Kong.
7.2
By submitting your personal
data you agree to this transfer, storing or processing of data outside Hong
Kong. We will take all steps reasonably necessary to ensure that your data is
treated securely in accordance with this privacy policy.
8
Your rights
8.1
You have the right to:
(a)
check whether we hold personal
data about you;
(b)
access any personal data we
hold about you; and
(c)
require us to correct any
inaccuracy or error in any personal data we hold about you.
8.2
Any request under
Clause 8.1 may be subject to a small administrative fee to meet our
cost in processing your request.
9
Changes to our privacy policy
We may amend this policy from time to time by posting the updated
policy on our Site. By continuing to use our Site and our App after the changes
come into effect means that you agree to be bound by the revised policy.
10
Contact us
If you have any questions, comments or requests regarding personal
data, please address them to:
Nowsnapp
Customer Happiness
support@nowsnapp.com
+852 3971 9160
Last
updated: 1 April 2018