Privacy Policy
1. Definitions
In this Privacy Policy:
1.1 “SmartGini”, “we”, “us”, “our” refer to SmartGini Limited.
1.2 “Website” refers to the website operated by us, www.smartgini.com
1.3 “You”, “Your” or “User” means any person who accesses and uses our Website
2. Acceptance of this Privacy Policy
2.1 SmartGini respects the privacy of its users and will protect that privacy as vigorously as possible, complying with the Personal Data (Privacy) Ordinance.
2.2 SmartGini will not collect information that personally identifies individuals except when such specific information is provided on a voluntary basis. Upon submitting your personal information to us, you acknowledge that you have read and understood this privacy policy and you are consenting to our collection and use of information in association with all purposes described in this policy.
2.3 SmartGini will not share your personal information, including your name and contact details, to any third party for direct marketing without your expressed consent.
3. Purposes for Collection and Use of Data
SmartGini collects information and data for purposes including but not limited to:
3.1 Operating the Website;
3.2 Verifying the identity of users;
3.3 Handling enquiries, requests and complaints;
3.4 Contacting users regarding administrative notices and communications relevant to their account or service with SmartGini;
3.5 Performing statistical analyses of user behaviour and characteristics at aggregated level to measure interest in and use of the various sections of the Website for design and content improvement; and
3.6 Sending information or promotional materials to you.
SmartGini shall not release any such data and/or personal information collected to third parties except for the purposes listed in this section and under the circumstances listed in Section 5.
4. Information We Collect and Receive
The type of information we collect will depend on the type of services provided to or requested by you, including but not limited to:
4.1 First and last name, nickname, gender, birthday, and family profiles;
4.2 Contact information such as phone numbers and email addresses; and
4.3 Non-personal identifying information such as usage behaviour, preference and online activities.
5. Disclosure of Data
Other than the purposes stated in Section 3, we may disclose the data for:
5.1 Transferring to service providers on confidential terms for further processing in accordance with the purposes for which the data was originally collected, such as service delivery and data management;
5.2 Compliance with any applicable rules, laws, regulations, codes of practice by any legal or regulatory bodies which are binding on SmartGini; and
5.3 Other legal purposes, including but not limited to cooperating with law enforcement and resolving disputes.
6. Personal Data Security
6.1 Any personal data maintained by SmartGini will be kept strictly confidential in accordance with this privacy statement. All reasonable and practicable efforts will be made to ensure that any personal data held by us is stored in a safe and secure location, only to be accessed by authorised staff members or authorised third-party service providers. However, SmartGini does not guarantee the security of any data storage or transmission.
6.2 SmartGini will not be responsible for any breach of security due to unauthorised access to data.
7. External Links
In order to best serve our users, our Website may contain links to sites that are not operated by SmartGini. SmartGini will not be held responsible for the policies and practices of other sites and companies. Any information you submit to those companies is subject to their privacy policies.
8. Enquiries and Right to Access
8.1 Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to review, access and amend any personal information you provide to us. Should you wish to access your personal data or have any enquiries or comments relating to our Privacy Statement, you may contact us by:
8.2 We reserve the right to amend or update this privacy statement from time to time. In accordance with the terms of the Personal Data (Privacy) Ordinance (Cap. 486), we reserve the right to charge a reasonable fee for the processing or correction of any data access request.