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Privacy Policy

Notice under the Personal Data (Privacy) Ordinance (the “Ordinance”) in relation to the use of [link] and any related mobile applications of the Company (collectively called the “Website”)

This Privacy Policy forms part of our Terms of Service ([link]) (the “Terms of Service”) for the use of the Website. The terms used herein have the same meaning as the terms defined in the Terms of Service unless otherwise stated.

The Company is committed to protecting the privacy of Users of the Website. Collection of the Personal Information of Users is essential for the Company to be able to provide the Services offered on the Website and as such the use of the Website is subject to this Privacy Policy.

 Collection and use of Personal Information

1.1  All Users are required to register according to the Terms of Service and requisite procedures on the Website in order to use the Website. When registering, and in the course of using the Website, Users shall be asked to provide certain personal information, including, but not limited to:  

	a. Name;
        b. Date of birth; 
	c. Contact details; and
	d. As for Coupon Users, their location
(collectively “Personal Information”).

1.2	 Personal Information collected by the Company in the course of providing services offered via the Website will be used for a range of normal commercial and marketing purposes including but not limited to: 

processing, investigating and verifying the validity of Personal Information;
displaying the Personal Information on the Website and any other websites as approved by the User (such as Facebook);
processing payments made by Users or to be made on behalf of Users;
direct promotional messages or information to be sent from the Company to Users;
meeting the disclosure requirements of any local or foreign law, regulations, codes or guidelines binding on the Company and conduct matching procedures  where necessary;   
reporting on the usage of Coupons by individuals to Merchants, the Company and affiliates of the Companies; and
facilitating the provision of services by the Company’s authorised service providers to the Company and/or Users for the above purposes.

1.3  Please note that the Website is neither intended for, nor directed to, children under the age of 18.

Cookies

2.1	  During the normal course of managing browsing activities on the Website, the Company may store some information on the computer with which the Website is viewed. Such information will be in the form of a “Cookie” or similar file type.  Such Cookies will enable the company to better tailor the website to match the interest and preferences of the User.  With most Internet Browsers, Cookies can be blocked, erased, or otherwise manipulated by the Users on their own computers.

2.2 The Company may also collect other network information, such as Internet Protocol Address (IP Address), from browsers of the Website.

Disclosure of Personal Information

3.1  Personal Information of Users may be displayed on the Website with the consent of that User. Users are deemed to have given their consent to the Company by registering as a User which involves the User agreeing to be bound by the Terms of Service.

3.2  In addition, Users are deemed to have granted permission to the Company to disclose any Personal Information to the following specified parties, within or outside of Hong Kong:

any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to the Company in connection with the operation of its business;
third party service providers including legal advisors, accountants, investigators, specialists, and data processors;
any person to whom the Company is under an obligation to make disclosure under the requirements of any law binding on the Company or any of its associated companies and for the purposes of any regulations, codes or guidelines issued by governmental, regulatory or other authorities with which the Company or any of its associated companies are expected to comply;
any person pursuant to any order of a court of competent jurisdiction; and
any actual or proposed assignee of the Company or transferee of the Company’s rights in respect of the Users.

Direct Marketing

4.1  The Company may use Personal Information including the name and contact details of a User for the purposes of:

marketing the services provided by the Company, including new features of the Website or programs offered by the Company, its subsidiaries and affiliates;
marketing-related services of business partners, including services or events offered by companies which establish campaigns  on the Website;
performing user analysis, profiling and segmentation; and
conducting market research and surveys for the Company’s development of services.

4.2  Personal Information of Users may be used for the purposes of paragraph 4.1 only with the consent of the User. Consent is deemed provided to the Company at the time Personal Information is provided to the Company by the User. Such consent may be withdrawn by the Users at any time by giving notice to the Company via email.

4.3  The Company shall not provide your Personal Information to any non-affiliated third party for the purposes of direct marketing.

Company’s Promotional Messages and Campaigns

The Company shall have the right to use Users’ materials for the promotional campaigns of the Company, its subsidiaries and affiliates.

Right to Access Personal Information by Users

6.1 All Users shall have the right to access, correct or change any of their own Personal Information held by the Company. Users can access their own Personal Information through their account on the Website and are expected to ensure their information is kept up to date. 

6.2  In accordance with the Ordinance, the Company has the right to charge a reasonable fee for processing any data access request.

Information Security

The Company shall take all reasonable steps to protect all Personal Information held by it from misuse, loss, unauthorised access, modification or disclosure. 

Changes

From time to time the Company may make changes to this Policy without notice to you and any such changes will be effective immediately upon the revised policy being published on the Website. By continuing to use the Website following any changes, you will be deemed to have agreed to those changes. If you do not agree with the terms of this Policy you must cease to use the Website.