Privacy Policy and Personal Information Collection Statement (PICS)

1. Our Commitment to Your Privacy

AirPurchase (Hong Kong) Limited ("we", "us", "our") is committed to protecting the privacy and security of the personal data we handle. This Privacy Policy and Personal Information Collection Statement ("Policy") explains how we collect, use, disclose, transfer, and store your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the laws of the Hong Kong Special Administrative Region ("PDPO").

This Policy applies to personal data we collect in the course of providing our services (the "Services"), through our website, and in other interactions with you.

2. Purposes of Collection and Use of Personal Data

The personal data we collect will be used for the following purposes:

• Provision of Services: To provide, manage, and deliver the Services you have contracted for.
• Account Administration: To set up and manage your client account, verify your identity, and manage your access to our platforms.
• Billing and Financial Management: To process payments, issue invoices, manage financial transactions, and conduct credit checks if necessary.
• Client Communication: To communicate with you regarding your account, respond to your enquiries and support requests, and send important service-related notices (e.g., technical updates, security alerts, and changes to our terms or policies).
• Service Improvement and Analytics: To understand how our Services are used, to conduct data analysis for research and development, and to improve the functionality, quality, and user experience of our offerings. This may involve the use of aggregated and anonymized data.
• Legal and Security Compliance: To enforce our terms of service, prevent fraud or illegal activities, protect the security of our systems and Services, and comply with applicable laws, regulations, court orders, or requests from governmental authorities.
• Direct Marketing: To provide you with information about our products, services, and promotional offers, subject to your explicit consent (see Section 5).

3. Types of Personal Data We Collect

We may collect and process the following types of personal data:

• Identity and Contact Data: Full name, company name, job title, email address, telephone number, and business address.
• Account Data: Username, password (stored in an encrypted format), and user preferences.
• Financial and Transaction Data: Billing information, transaction records, and payment card details (typically processed directly by our third-party payment gateway and not stored on our servers).
• Technical and Usage Data: IP address, browser type and version, operating system, device information, website usage logs, and data collected through cookies and similar technologies.

4. Disclosure and Transfer of Personal Data

We maintain a strict confidentiality policy for all personal data. However, we may disclose or transfer your data to the following parties for the purposes outlined in Section 2:

• Third-Party Service Providers (Sub-processors): Cloud hosting (e.g., AWS, Google Cloud), payment processing, data analytics, and customer support. These parties are bound by confidentiality and data protection obligations.
• Professional Advisors: Lawyers, auditors, and insurers, where necessary.
• Legal Authorities: Government bodies, regulatory authorities, or courts where required by law or in response to a valid legal process.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets.

Your personal data may be transferred to, and processed in, countries outside Hong Kong. We will ensure that any such transfer is protected to a standard comparable to that under the PDPO.

5. Direct Marketing

We will not use your personal data for direct marketing without your express voluntary consent. If you have provided consent, we may use your name and email address to send marketing communications.

You may opt-out at any time by clicking "unsubscribe" in our emails or contacting our Data Protection Officer.

6. Use of Cookies

Our website uses cookies and similar technologies to:

• Provide a better user experience
• Operate our Services securely
• Improve website performance

You can manage your cookie preferences via your browser settings.

7. Data Security

We implement commercially reasonable technical and organizational measures to protect personal data from unauthorized access, loss, or destruction. Measures include:

• Access controls
• Encryption
• Regular security assessments

8. Data Retention

We will retain personal data only as long as necessary for the purposes collected or to comply with legal, accounting, or reporting obligations. When data is no longer needed, we will securely erase or anonymize it.

9. Your Data Protection Rights

Under the PDPO, you have the right to:

• Request Access to the personal data we hold about you
• Request Correction of any inaccurate personal data

Requests must be made in writing to our Data Protection Officer. A reasonable fee may apply for access requests.

10. Changes to This Privacy Policy

We may update this Policy from time to time. If material changes are made, we will update the "Last Updated" date and post the revised Policy on our website.

11. Contact Us

If you have any questions about this Policy or wish to exercise your rights:

Company: AirPurchase (Hong Kong) Limited
Address: Shop 3, 1/F, Central Pier 7, Central, Hong Kong
Email: admin@airpurchase.com

Last Update: 19 September, 2024