1.1. In order to provide a better service to you, develop new services, and obtain additional customers for our services we may collect and process the following data about you:

information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our site, posting material, or requesting further services. We may also ask you for information at other times, for example in connection with a promotion or when you report a problem with our site;

if you contact us, we may keep a record of that correspondence; we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them; details of your visits to our site and the resources that you access;

1.2. Requests to subscribe to mailing lists or other offerings, Cookies and similar technologies. Like many online services, we sometimes use the following technologies:

Cookies, or text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.

Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

1.3. We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:

• Web hosting: N/A
• Survey: N/A
• Email Collection & Retention Software: Insightly, Mailchimp
• Other providers include: IT and software development, Online advertising management, Accountants

2.1.

The purposes for which information may be used by us in and outside the Hong Kong Special Administrative Region include:

• ensuring that content from our site is presented in the most effective manner for you and for your computer;
• providing you with alerts, newsletter, education materials or information that you requested or signed up to receive;
• carrying out our obligations arising from any contracts entered into between you and us;
• allowing you to participate in interactive features of our service, when you choose to do so;
• designing and conducting surveys/questionnaires;

complying with laws and regulations applicable to us or any of our affiliates in or outside the Hong Kong Special Administrative Region;

• legal proceedings, including collecting overdue amounts and seeking professional advices;
• researching, designing and launching services or products including seminars/events/forums;
• promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in clause 2 below);
• purposes directly related or incidental to the above; or
• purposes not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.

2.2. By using our site, you consent to direct marketing utilizing the following information, should you provide it: your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data. We utilize this information for the following types of direct marketing:

• Services and products related to our site and/or our affiliates (including marketing affiliates programs we are a part of);
• reward, loyalty or privileges programmes, promotional offers and related services; and
• invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
• We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
• Third Parties and Information we receive from other sources We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
• Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
  
  

2.3. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.4. Under GDPR, if you are an EU citizen we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

1. You have given consent to the processing of your personal data for one or more specific purposes;
2. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are subject;
4. Details of your visits to our site and the resources you use
5. Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers
6. processing is necessary to protect the vital interests of you or of another natural person;
7. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
8. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

3.1  We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection: personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services; our overseas offices, affiliates, business partners and counterparts (if any); persons under a duty of confidentiality to us; persons to whom we are required to make disclosure under applicable laws and regulations in or outside the Hong Kong Special Administrative Region; acquirers and other parties to business transactions involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of Quantifeed or our affiliates; or actual or proposed transferees or participants of our services in or outside the Hong Kong Special Administrative Region.

3.2  If you voluntarily provide your personal information to third parties or the public on or through our services, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

4.1. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

4.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

4.3. We employ technical, organizational and physical safeguards designed to protect the personal information we collect.

4.4. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

4.5. Unfortunately, the transmission of information via the internet is not completely secure. Although we employ industry standard tools to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We retain personal data for so long as it is necessary to achieve a purpose listed above. Data may be archived for as long as the purpose for which the data was used still exists.

Any changes we may make to our privacy policy in the future will be posted on this page and, in certain instances, we will update you on the changes of our privacy policy via other means.

7.1. We may hold your data on servers based in Hong Kong, Singapore and any other territories as we see fit. We may also transfer your data to our overseas offices or in accordance with the “Disclosure of your information” section above, who may be located in or outside of the Hong Kong Special Administrative Region.

7.2. We may transfer your collected data to storage outside the European Economic Area (EEA). If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the EEA if it is necessary for us to do so.

7.3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.

8.1.  By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.

8.2.  Under the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”), individuals have the right: to check whether we hold personal data about you and to access such data; to require us to correct as soon as reasonably practicable any data relating to you which is inaccurate; to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.

8.3. If you wish to object to the use of your personal data for direct marketing purposes, access your data, correct your data, or obtain information regarding Quantifeed’s data policies and practices, utilize the contact information provided below.

8.4. In accordance with the terms of the Ordinance, we have the right to and may charge a reasonable fee for processing any data access request.

8.5. In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

8.6. The right described in section 8.5 does not apply in the following circumstances:

a) the decision is necessary for the entry into, or performance of, a contract between you and us;
b) the decision is authorised by law; or
c) you have given you explicit consent.

8.7. Where we use your personal data for profiling purposes, the following shall apply:

a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

Nothing in this Privacy Policy shall limit the rights of the data subject under the Ordinance. This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region. You agree to submit to the exclusive jurisdiction of the Hong Kong courts.

The Site is not intended for use by children under 18 years of age.

Any other questions or comments should be directed to:
Support Team Units 120, 29/F, Tower 5, The Gateway,
Harbour City, 15 Canton Road, Tsim Sha Tsui, Kowloon Hong Kong
+852 3105 9610
[email protected]