PRIVACY POLICY STATEMENT

1.
We, “Inspirit Studio Limited” and its subsidiaries and affiliates, are technology companies and developers of various mobile applications including BuddiGo Mobile Application (Buddi version and User version). The use of our mobile applications and websites by you and any other persons are governed by the Terms of Use for BuddiGo Mobile Application (Buddi Version and User Version) and other applicable terms and conditions from time to time adopted by us (collectively the “Terms and Conditions”). Unless otherwise specified, the words or definitions used herein shall have the same meaning as defined in the Terms and Conditions. For your easy reference, our aforesaid mobile applications and websites, together with the services, functions, contents and products we may from time to time offered through them, are collectively defined therein and referred to herein as the “Platform”.

2.
We respect personal data privacy and are committed to full implementation of and compliance with the data protection principles and all relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance (Cap.486) (“Ordinance”). We shall ensure that our staff handling personal data will comply with the legally required standards of security and confidentiality.

Personal Data Collection

3.
We shall at all times fully observe the Ordinance in collecting, maintaining and using your Personal Data (as defined in the Ordinance). In particular, we shall follow the following principles, unless otherwise required, permitted by law or agreed by you:
i.
Collection
a.
When you access or use the Platform or register an Account for such purposes, we will collect, store and use the following Personal Data from you:
i.
name, surname, phone number, and email;
ii.
the information shown on your identification documents, such as Hong Kong Identity Card number;
iii.
payment or banking information, such as bank account and/or credit card number, and other payment information;
iv.
location data (tracking via IP address, WIFI, GPS or the combination thereof);
v.
your IP address when you use our apps or visit our website; and
vi.
other information to be specifically collected by us and provided by you when you access or use the Platform.
b.
We will collect the Personal Data from you for lawful purposes relating to: 1) provision of the Platform or any related services; 2) internal improvement work including but not limited to R&D and quality control; 3) locating your position to facilitate our provision of the Platform; 4) facilitating your access and use of the Platform.
c.
We will collect the Personal Data from you directly through the Platform or by other means which are lawful and fair in the circumstances; and
d.
We will take practical steps to ensure that your Personal Data are and remain accurate, but your assistance will be required to enable us to know if there is any change.

ii.
Use
a.
Your Personal Data will be used for the purposes specified herein, including those set out in paragraph 3(i)(b) above and paragraph 7 below; and
b.
We will not be using your Personal Data for other purposes without your consent.

iii.
Storage
a.
We will take practical steps to ensure that your Personal Data will be destroyed immediately after the period specified in paragraph 12 and will not be kept longer than necessary; and
b.
We will take practical steps to ensure that your Personal Data will be protected against unauthorised or accidental access, processing or erasure.

iv.
Security
a.
We will take all practical steps to ensure that your Personal Data are protected against unauthorized and accidental access and loss.
b.
We may from time to time engage one or more data processors, whether within or outside Hong Kong, to process your Personal Data on our behalf, but we will take practical steps to ensure that your Personal Data will be protected against unauthorised or accidental access, processing or erasure.

v.
Access
a.
You have the right to access and correct your Personal Data held by us. Your request for access or correction will be dealt with in accordance with the Ordinance. You may contact us in the manner specified in paragraph 21 for such purpose.
b.
Your Personal Data is classified as confidential and can only be disclosed by us in the manner specified herein or where we are permitted by the Ordinance or otherwise legally compelled to do so.
c.
You are not obliged to provide the Personal Data that we have requested, but without your Personal Data we may be unable to respond to any queries you may have or to provide, and you may be unable to access, some of the services or features of or the information on the Platform.
d.
We may disclose or transfer your Personal Data to the Buddies or the Users for the provision of Buddi-Services or any other related services.

Collection of information

4.
The Platform and our servers may automatically collect data about your IP address when you visit our website. Like most applications and web servers, we store your IP address in a log file when you access the Platform or our servers. Your IP address is used to help identifying you and to gather demographic information about you, other users of the Platform or other relevant third parties as a whole. The Platform or our servers may also record the date, time and referring page and other details that linked you to us (e.g. another website or a search engine; the pages you have visited on the website; the website you have visited, if any, after the Platform); other information about the type of web browser, computer, related software and settings you are using; any search terms you have entered on the Platform or a referral site; and other web usage activities and data logged by our servers. We use this information for internal system administration, to help administer and diagnose problems with our Platform and servers.

5.
We may use cookies in some areas of the Platform. Cookies are small pieces of information that we store on your computer/mobile’s browser or hard drive. Such information does not contain your name or address information or any information that will enable us to contact you via telephone, e-mail or any other means. The information stored is to enable the Platform to function correctly and give you additional features and benefits such as automatic log in. Most browsers give you the option of preventing cookies from being stored on your computer, though doing so may cause you to be unable to access or use some of the services or features and lose some of the benefits of the Platform.

6.
When you install or run our apps in your mobile device, we may collect your location data with respect to your device’s GPS, WIFI, or IP address. The foregoing location data will be used to provide location tracking service for the provision of the Platform or other related services. Such data will be deleted if it is no longer useful to us.

Uses of information

7.
Your Personal Data may be used by us for obligatory and voluntary purposes:
i.
Obligatory purposes – if you do not want us to use your Personal Data for any of the purposes listed below (inclusive), you may not be able to access or use the Platform:
a.
provision of the Platform;
b.
locating your position to facilitate our provision of the Platform;
c.
facilitating your access to the Platform and the services, features and information thereof and thereon;
d.
processing any payment or financial transactions made through or otherwise related to the Platform;
e.
sharing, using and verifying your identity and location, which may involve disclosure of your Personal Data to other users of the Platform, namely the prospective Buddies or Users who are desirous to provide Buddi-Service to you, or engage your Buddi-Service;
f.
processing of your request to access or use the Platform and any related services;
g.
matching (as defined in the Ordinance) your Personal Data with other data collected for other purposes and from other sources including third parties in relation to the provision of the Platform;
h.
for administration, audit, research, development, quality control, or statistical analysis to improve the Platform;
i.
prevention, detection or investigation of crime;
j.
any disclosure as permitted or required by law; or
k.
any other purposes as may be agreed to between you and us, including the purposes set out in the Terms and Conditions.

ii.
Voluntary purposes – Your consent is required for us to use your Personal Data for any of the purposes listed below, and unless you consent to use your Personal Data for those purposes (through our website, mobile application or otherwise), we will not do so. A Consent Form is provided at the end of this statement for you to indicate your consent for us to use your Personal Data for the voluntary purposes listed below:
a.
Your name, surname, phone number, email and your record of using or accessing the Platform (collectively “Contact Data”) may be used for marketing and advertising (i) promoting events and activities organized by us; (ii) the products and services offered by us for any purposes; and (iii) the products and services offered by any of our partners, agents, contractors, or third-party suppliers. In addition to using your Contact Data by ourselves for marketing, we also provide and/or intend to provide your Contact Data to consultants (“Marketing Consultants”) both in and outside Hong Kong engaged to provide marketing and advertising services to us in relation to the Platform or to carry out the aforesaid marketing and advertising activities on our behalf; and.
b.
Sharing your Contact Data with our authorized person or entity such as service provider, partner, agent, contractor, consultant and lawyer for assisting or facilitating us to carry out the voluntary purposes as set forth in this Privacy Policy;

If you do not agree or want us to stop using your Personal Data for any of the voluntary purposes mentioned above, you may, without charge, exercise your opt-out right by notifying us. You should send an opt-out notice to the contact point set forth under paragraph 21 below by mail or email and allow ten (10) working days for the update and/or removal of your Personal Data in/from our relevant database.

8.
Your Personal Data may also be consolidated with other data and used in aggregate form for research and marketing purposes, and in such circumstances, individual data shall not be revealed in the aggregate form. Such data in aggregate form may be disclosed to and used by other persons or entities under contractual activities with us for the abovementioned purposes.

Disclosure and sharing of information

9.
Your Personal Data held by us will be kept confidential by all reasonable steps but we may, where such disclosure or transfer is necessary to satisfy the purpose, or directly related purpose, for which the data was collected, provide such information or copies to the following relevant parties:
a.
member companies within our group;
b.
our authorized personnel or entity including contractors, consultants and lawyers for performing various business functions or assisting/facilitating us to carry out the purposes as set forth herein;
c.
other users of the Platform, namely any Buddies who may provide you Buddi-Services or any Users who may engage your Buddi-Services;
d.
government bodies and other regulators as required under the law or pursuant to any regulatory arrangements between us and the relevant government body or regulator;
e.
any person under a duty of confidentiality to us and who has undertaken to keep such information confidential, provided that such person has a legitimate right to such information; or
f.
any person to whom we are required to make disclosure under any law applicable in Hong Kong.

10.
Your Personal Data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right or authority to access such information. In addition, your Personal Data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned Personal Data are exempted from the provisions of Data Protection Principle 3 of the Ordinance.

11.
We will do our best to ensure compliance with the Ordinance by providing guidelines to and/or monitoring compliance of the relevant parties listed above. However, we cannot guarantee how third parties will use your personal information and assume no responsibility for the privacy protection provided by such third parties.

Retention of information

12.
We will destroy any Personal Data we may hold in accordance with our internal policy. Generally speaking, our such internal policy covers the following principles:
a.
Personal Data will only be retained for as long as necessary to fulfil the original or directly related purposes for which it was collected, unless the Personal Data is also retained to satisfy any applicable statutory or contractual obligations; and
b.
Personal Data are purged from our electronic, manual and other filing systems in accordance with specific schedules based on the above criteria and our internal procedures.

Information security

13.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

14.
Physical records containing your Personal Data are securely stored in our designated areas and/or media when not in use.

15.
The Platform may support the use of [e.g. 128-bit Secure Socket Layer (SSL) encryption technology] or other industry standards for encryption over the Internet to protect data. When you provide sensitive information, such as credit card details, it will be automatically converted into codes before being securely dispatched over the Internet.

16.
Furthermore, our web servers are protected behind “firewalls” and our systems are monitored to prevent any unauthorized access.

17.
Practical steps will be taken to ensure that your Personal Data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of your Personal Data.

18.
You should, however, be aware that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Therefore we cannot guarantee absolutely the security of any information that you transmit to us or receive from us over the internet.

Transfer of information outside of Hong Kong

19.
At times it may be necessary and prudent for us to transfer certain Personal Data to places outside of Hong Kong in order to carry out the purposes, or directly related purposes, specified herein or for which the Personal Data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.

Contact us

20.
Under the Ordinance, individuals have the right to request access to and correction of their Personal Data. It is also our intention to keep your Personal Data on our records accurate and up-to-date.

21.
We could also delete certain Personal Data held by us should you wish us to do so but this may adversely affect your access or use of the Platform.

22.
Should you wish to access, correct or delete your Personal Data held by us or enquire about our Privacy Policy and practice, please contact us by email or post to:

Name: Sean Tam

Title: Chief Operating Officer

Address: 315-316, 3/F, Block 12W, No.5 Science Park West Avenue Hong Kong Science Park, Shatin, N.T.

Email: cs@buddigo.com

CONSENT FORM

Date:

To:

Inspirit Studio Limited and its subsidiaries and affiliates,



I hereby formally give you my consent that you may:


i.
Use my name, address, phone number and email address and the record of my using or accessing the Platform (collectively “Contact Data”) for marketing or advertising the events and activities organized by you, the product and services offered by you, the products and services offered by any of your partners, agents, contractors, or third-party suppliers, and provide the Contact Data to the your Marketing Consultants (as defined in your Privacy Policy) for such purposes; and
ii.
Share my Contact Data with your authorized person or entity such as service provider, partner, agent, contractor, consultant and lawyer for assisting or facilitating you to carry out the voluntary purposes as set forth in the Privacy Policy.


I agree that the instructions and consent above supersede and override all my previous instructions to you.

________________________


Title:

My full name:

My Username: