PRIVACY POLICY

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 info@smartware.hk 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.
4.2 Cookie 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 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

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