Privacy Policy And Personal Information Collection Statement

We, Smartware solutions and, where applicable, our subsidiary value your privacy of your personal information is extremely important to us. This policy sets out where and how we collect your personal information and how it will be used, as well as your rights over any personal information we hold about you. Our privacy policy applies to all clients with whom we have a relationship and is also extended to each of our former clients.

Please note that your personal information will be stored and processed on our computers in Hong Kong or elsewhere at our discretion. The laws on holding personal data in Hong Kong may be less stringent than the laws of your country. Yet, we will hold and transmit your personal information in a safe, confidential, and secure environment. By using our Website and/or our Services, you agree to your personal information being transferred or used as described in this Privacy Policy.

1. Our Pledge

1.1 We respect and are committed to protecting your privacy and will only process your personal information in accordance with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong under the laws of Hong Kong.

1.2 We are committed to protect your information given to us with care. We do not sell, rent, or loan any information that identifies you to any third party without your consent.

1.3 The personal information you give to us may be shared within our group of companies, our banks, our agents, couriers and other third parties who need your information to enable your order to be delivered or for providing/improving our services for you.

1.4 We may store your bank account information and payment information in our system. All remittance/payment processing are handled by the respective payment service provider such as banks. For more information on the privacy policy of the respective payment service providers (such as banks), please visit their respective websites.

1.5 We would like to share your information with any new businesses that we may develop in the future, either on our own or with others. Our Website will be updated from time to time should we develop joint ventures or companies going forward.

2. Collection Of Information About You

When you visit Our Website and/or use Our Services, we collect personal information about you in a number of ways.

2.1 Orders and registration information. We collect information from you when you conduct business with us or enroll in one of our services.

2.2 Transaction and experience information. Once you become our client, we collect and maintain personal information about your account activity, including your transactions, balances, and history. Personal information such as your name, contact details including address, telephone number, email address and information for verification of identity (e.g. copy of Hong Kong Identity Card, passport) as provided by you when you register, sign up for an event or place an order with us and enter your payment details and for the transactions conducted. This information allows us to administer your account and provide the services you have requested.

2.3 Our website usage. Information such as your computer’s IP address, operating system and anonymous information collected from cookies when you are browsing our Website to help us understand how to improve our Websites and services to you.

2.4 Third-party information providers. We may collect information about you from information services and consumer reporting agencies to verify your identity, or creditworthiness, or to better understand your commercial needs.

2.5 Supply of Personal Data to us is non-obligatory, but failure to do so may result in us being unable to process your order(s) or to provide services to you.

3. Purpose Of Collection And Use Of The Information

3.1 You agree that all the information provided by you to us may be used and retained by us for the following purposes and for other purposes as may be agreed between you and us or required by law from time to time:-

  1. Conducting business with you;
  2. Providing our services to you;
  3. Analyzing, verifying and/or checking of your credit, payment, or status in relation to the provision of our services to you;
  4. Processing of any payment instructions, direct debit facilities or credit facilities requested by you;
  5. Enabling the daily operation of your account or the collection of amounts outstanding in your account in relation to our services to you;
  6. Carrying out data sorting and analysis to enable us to better understand your characteristics and buying behaviour and to provide other services better tailored to your needs, and to assist us in selecting goods and services that are likely to be of interest to you;
  7. Providing you with regular communications from us with details of our services and the benefits;
  8. The normal management, operation, and maintenance of the performance of our services;
  9. Designing new, or improving existing services provided by us, our subsidiaries, or our affiliates to you;
  10. Investigation of complaints, suspects suspicious transactions, and research for service improvement;
  11. Prevention, detection, or investigation of crime;
  12. Disclosure as required by law;
  13. Aggregated behavioral analysis;
  14. Facilitating communication with you.

3.2 We will not use your personal data for direct marketing unless we have obtained your consent.

3.3 Information we collect will be used to process your orders, to provide services, allocate discount, offers, vouchers and so forth to you.

3.4 We may use your personal information for market research and statistical analysis, to enable us to send you information about products and services that may interest you, potentially send you vouchers or other offers and to help us to develop Our Website and services to make your browsing easier in the future, including the personalizing of Our Website. The information we communicate to you may be sent by email, our internal message system, post, fax or via telephone unless you have refused us doing so.

3.5 We may send you marketing information by email, our internal message system, post, fax or phone, or use information about your browsing preferences to give you vouchers or other offers.

3.6 You have the right to:-

  1. Check whether we hold any of your personal data;
  2. Access your personal data held by us;
  3. Require us to correct any personal data which is inaccurate;
  4. Ascertain our policies and practices from time to time in relation to personal data and the types of personal data held by us; and
  5. Opt out from receiving marketing materials (including direct marketing) from us at any time.

In accordance with the Personal Data (Privacy) Ordinance (Cap. 486), we have the right to charge you a reasonable fee for the processing of any personal data access request.

3.7 If you wish to amend your marketing preferences with us or amend your decision regarding receipt of information from us, you can do so by emailing our Customer Service Officer at or by amending your preference within Our Website. Remember if you take this step, we may not be able to send you information about special offers, promotions, vouchers or newsletter.

3.8 We will, of course, continue to let you have information on the operation of your account including confirmation and delivery details.

3.9 We may use your mobile phone number or email address to send you a confirmation or reminder of your confirmed order.

4. Cookies

4.1 By using Our Website, you agree that we can store and access cookies, Internet Protocol (IP) addresses and use other methods in order to collect website usage data and improve your on-line experience.

4.1 By using Our Website, you agree that we can store and access cookies, Internet Protocol (IP) addresses and use other methods in order to collect website usage data and improve your on-line experience.

4.2Cookie allows us to recognize our Website users. We send a “session cookie” to your computer if and when you log in to your account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you do not need to re-enter your password multiple times.

4.3 You may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you deactivate the setting of cookies in the Internet browser used, not all functions of our Website may be entirely usable.

5. Cookies

5.1 We are committed to protect your personal information we hold with care. Payment details are stored on system in an encrypted format and can only be accessed by us.

5.2 If we contact you, we will never ask for your password. We advise you never to enter your password into an email or after following a link from an email. Contact us if you are in doubt.

5.3 In order to provide a safe, secure browsing environment for all our clients, access to Our Website from certain IP location may be blocked.

5.4 However, please note that “perfect security” does not exist. Accordingly, We do not represent or warrant that there will not be, and hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, use or disclosure of any information held or maintained by us.

5.5 Our Website may link to other websites. However, once you have used those links to leave our Website, you should note that we do not have any control over such other website. We are not responsible for the protection and privacy of any information which you may provide whilst visiting such sites and such sites are not governed by this Policy. You should exercise extra caution and look at the privacy policy and personal data collection statement applicable to those websites.

6. Data Retention

6.1 All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.

6.2 Personal Data about you may be transferred to a place outside Hong Kong.

6.3 Pseudonymous is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. Pseudonymisation of Personal Data about you may be conducted by us.

7. Policy Changes

7.1 Please note that this Policy may be amended from time to time without prior notice. You are advised to check this Policy (together with our Standard Terms and Conditions) on a regular basis.

7.2 If, you continue to use Our Website and/or Our services after the date on which the changes to this Policy come into effect, You will be deemed to have accepted those changes.

8. Provision Of Personal Data

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Your Obligation to provide the personal data; possible consequences of failure to provide such data

8.1 We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that you provide us with your personal data, which must subsequently be processed by us. You are, for example, obliged to provide us with your personal data when we enter into a contract with you. The non-provision of your personal data would have the consequence that your contract could not be concluded. Before personal data is provided by you, you may contact us to clarifies whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non- provision of the personal data.

9. Prevailing Language

9.1 This Policy is written in English language and may be translated into other languages. In the event of any discrepancy in the translation of this Policy, the English version shall prevail.

10. Enquiries

10.1Should you have any enquiry concerning this Policy, please contact our Customer Service Officer via Our officer acts as a Controller for the purposes of the General Data Protection Regulation (GDPR)