Please remember that if you navigate to a Website through our Website, our policy will no longer be in effect and that Website’s policy will take effect. This includes our advertisers and vendors who may contact you directly. These advertisers include the vendors which you have asked to contact you or a vendor who has additional products and services to offer you.
SECTION 1 - INFORMATION YOU PROVIDE AND WE COLLECT
a. “Personal information.” We collect personal information that can identify you as an individual. Such information may include your name, address, telephone number, mobile number, credit or debit card number, social security or driver’s license number.
b. “Demographic information” We also collect information that by itself cannot identify you as it not unique to you. This includes, but is not limited to, zip code, mobile phone carrier, age, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests. Although this information is not Personal Information it may be linked to Personal Information through the use of a cryptographic hash of an email address. In such a case, your identity is not specifically provided.
c. “Behavioral information” We automatically collect information as to how you use our Website, the areas of our Website that you visit, what services you access, and information about your computer hardware and software, including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet, and other websites you have visited.
d. “Third party information” A third party may provide us information about you including personal, demographic, behavioral and indirect information. This collection may include, but is not limited to, first party cookies, third party cookies, anonymous cookies, persistent identifiers, email opt in and search engine keywords. We have no access or control over these cookies and other tracking devices used by third party advertisers and networks. We have no responsibility or liability for the policies and practices of these parties.
e. No Sensitive Health Information is Collected. We do not collect information about past, present or potential future medical conditions or treatments.
SECTION 2 - HOW WE COLLECT PERSONAL INFORMATION
a. Registration on Our Website. We collect Personal Information from you when you register on our Website or when you contact us directly for information or request services directly from us. Third parties may also provide us Personal Information you provided to them.
b. Social Media. Social Media Platforms such as Facebook, Twitter, LinkedIn or Google may also provide us with Personal Information. Social Media registration features may collect basic account information such as name, age, photo and other details you choose to share according to your social media account settings. Social Media features and widgets are hosted by a third party or may be hosted by us. You can unlink your Social Media accounts or control what they share from their privacy controls in the dashboard. We may associate the Personal Information you provided with Personal Information from third party sources.
SECTION 3 - INFORMATION COLLECTED THROUGH AUTOMATED TECHNOLOGY
a. General Collection. We as well as our third-party service vendors and supporting advertisers may automatically collect information from you. We use technologies such as cookies, web beacons, pixel tags, log files, local storage and similar mechanism to automatically collect information when you visit and use our Website. These technologies collect internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is used to analyze trends, administer our Website, track a user’s movements through our Website and gather demographic information about our entire user base. We also use these tools to measure the effectiveness of email communications and other marketing tools and to pay service vendors. We may prepare or receive reports based on these technologies on an individual or aggregated basis including the links to cookies to Personal Information you have provided us.
e. IP ADDRESSES. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). Your IP Address is identified and logged automatically in our server log files whenever you visit our Website. At the same time, we log the time of the visit and pages you viewed. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses to calculate the number of unique visits to our Website, to diagnose website or server problems, mapping and other administrative functions. We may use and disclose IP Addresses for the same purposes for which we use and disclose Personal Information.
SECTION 4 - WHAT DO WE DO WITH YOUR INFORMATION?
We collect your Personal Data in a number of ways and for various purposes, including:
When you browse our Site, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
a. Providing Services and Products. We use the information we gather on our Website to provide you with the services you have requested. This may include passing your information on to a third party to provide such services or products. We do not control the privacy practices of these third parties. If you have any questions or wish to remove your information from the third-party databases, you will need to contact that party directly. When you’ve submitted your Personal Information to us, with such submission, you have understood and agreed to allow us and all identified third parties to contact you or allow our vendors to contact you via telephone for a limited period even if the telephone number you submitted appears on any state and/or federal Do Not Call list, because your inquiry serves as an exception to state and/or federal Do Not Call laws.
b. Improving Our Website. We use the information we gather to respond to any inquires you make, operate and improve the functionality of our Website. Our services include the display of personalized products, content, and advertising, relating to your experience and interests. In addition, we use this information to comply with all legal obligations and resolve any disputes or concerns you may have.
c. Marketing. We also use the information you provide to us to send you advertisements, promotions and content by third parties that we think will be of interest to you. To provide this service we may anonymize and aggregate information for different purposes which include traffic flow, analysis usage, product development, market analysis, reports and other insights.
Email marketing (if applicable and when legally allowed): With your permission and provided it is legal in your jurisdiction, we may, within time limits allowed by law, send you emails about our Site, new products and services, and other updates. By “permission” we mean express and provable permission granted by you. A permission to send commercial or marketing emails may be through any of the following instances which we deem as existing business relationship with or inquiry from you:
- Entering your email address on our Site with no indication that you would not like to be emailed.
- Entering your email address as part of participation in any contest, event or survey conducted by us and we have informed you that we will be sending you marketing emails.
- Subscribing to an email newsletter by filling-out a form on our Site.
- Any instance where in completing a form, you have checked an opt-in checkbox indicating your willingness to be contacted through email provided the checkbox is unchecked by default and we have informed you that the nature of the emails will be commercial.
All marketing emails shall conspicuously contain a notice that at no cost to you, you can opt out of receiving more marketing emails from us. All marketing emails shall prominently display a one-click unsubscribe or opt-out option. Once you have opted out or unsubscribed, we shall immediately refrain from sending marketing emails to you.
We may use your personal information, including but not limited to your name, address, telephone, email address and other relevant data, to conduct our business, improve our Sites, develop new services, provide information and support, to better understand your needs and interests, personalize communications and advertising, meet contractual obligations, and generally promote a quality experience for you. For example, we may use your personal information, including your email address, to:
- Communicate, interact and build our relationship with you;
- Customize the content and services that are offered to you;
- Contact you with information about us and affiliated third-parties;
- Process, fulfill and follow up on transactions and requests for services, support, and information;
- Verify your authority to enter and use our services;
- Engage in market research and analysis;
- Measure, analyze and improve our services, the effectiveness of our Websites, and our advertising and marketing;
- Comply with legal requirements;
- Provide targeting advertising, including the use of re-targeting technology;
- Send you marketing materials, for example, via email, including our newsletter, and to notify you about products and services that we believe would be of interest to you;
- Deter, detect, and prevent fraud and other prohibited or illegal activities; or
You may manage your receipt of marketing and non-transactional emails by clicking on the “unsubscribe” link located on the bottom of our marketing and non-transactional emails. If at any point you choose not to receive our emails or newsletters, you can also opt-out or unsubscribe by emailing firstname.lastname@example.org, by following the opt-out instructions in the email or newsletter, or by sending mail to our Customer Service Team with address at Think Tech Sales Limited, Rm 709B, 7/F, Opulent Building, 402-406 Hennessy Road, Wan Chai, Hong Kong.
Telemarketing (if applicable and when legally allowed): Regardless of the fact that your telephone and/or cell number may be listed with the Federal Do-Not-Call Registry or your local State Do-Not-Call list, by providing us your telephone and/or cell number you are providing express written consent to receive future information (including telemarketing) about products and services from our affiliates, and you hereby agree and consent to our contacting you using the information you have provided and will provide to us. This means that within the time limits allowed by law, we may contact you by e-mail, phone and/or cell number (including use of automated dialing equipment and/or pre-recorded calls), text (SMS) message, social networks or any other means of communication that your wireless or other telecommunications device may be capable of receiving (i.e. video, etc.). You further acknowledge that you are not required to agree directly or indirectly or enter into an agreement regarding our telemarketing efforts as a condition of purchasing any goods or services from our affiliates. If you do not want to receive marketing calls, please let us know via phone call. You can also opt out by sending email to email@example.com or by sending mail to our Customer Service Team with address at Think Tech Sales Limited, Rm 709B, 7/F, Opulent Building, 402-406 Hennessy Road, Wan Chai, Hong Kong.
If you do not want us to share your Personal Information going-forward with unaffiliated third parties for their marketing purposes, you may opt-out by by sending email to firstname.lastname@example.org or by sending mail to our Customer Service Team with address at Think Tech Sales Limited, Rm 709B, 7/F, Opulent Building, 402-406 Hennessy Road, Wan Chai, Hong Kong and requesting that we opt you out of any sharing of your Personal Information going-forward. Please note that if you opt-out of such sharing, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). If you wish to cease receiving marketing-related e-mails from these third parties, please contact them directly or utilize any opt-out mechanisms in their privacy policies or marketing-related e-mails.
The request to opt-out from the mailing list shall be honored immediately. While we offer you some control over marketing communication, certain transactional, relationship, and legally required communications will not be affected by the choices you have made about marketing communications.
We reserve the right to release and disclose any personal information relative or provided by you to law enforcement or other governmental officials as we, in our sole and absolute discretion, deem necessary to comply with any applicable law or at the request of any governmental entity or agency.
Any information stored in our Site is treated as confidential. All information is stored securely and is accessed by authorized personnel only. We implement and maintain appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
SECTION 5 – CONSENT AS BASIS
How do you get my consent?
When you provide us with personal information, you consent to our collecting your personal information and using it for a specific reason only.
If we ask for your personal information for a secondary reason, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, at any time, by contacting us at email address email@example.com, by following the opt-out instructions in the email or newsletter, or by sending mail to our Customer Service Team with address at Think Tech Sales Limited, Rm 709B, 7/F, Opulent Building, 402-406 Hennessy Road, Wan Chai, Hong Kong. Certain transactional, relationship, and legally required communications will not be affected by the choices you have made about information sharing. Depending on the service, collection and use of your Personal Data may be required for the services to work.
- For the performance of our contractual obligations to you;
- To meet legal obligations or compliance with laws, regulations, court orders, or other legal obligations or to assist in an investigation; or
- For Legitimate Interests or to operate our business and provide the services, other than in performing our contractual obligations to you for our company’s "legitimate interests" for the purposes of applicable law - except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.
You can, at any time, request to edit, update, access or delete your information by emailing us at firstname.lastname@example.org. We shall, promptly following receipt of notice, delete Personal Data from our records and, upon completion of all transactions, comply with all reasonable instructions with respect to the deletion of any remaining Personal Data. We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. You may request for a copy of your Personal Data, free of charge and in an electronic format. You may request for all Personal Data to be provided in a commonly used and machine-readable format and once obtained, you have the right to take the same to another company.
SECTION 6 - DISCLOSURE
- To Affiliates and Partners: With companies or ventures that are owned or controlled by us, and internally within our company, in order to provide and improve services, for marketing purposes, and for advertising.
- To Service Providers and Vendors: With third party service providers who provide services such as contact information verification, payment processing, order fulfillment, customer service, Website hosting, data analysis, infrastructure provision, IT services, email delivery services, auditing services and other similar services to enable them to provide services. This may include third party credit bureaus to verify your identity and obtain a credit report or score. When you seek insurance quotes, to the appropriate Department of Motor Vehicles to verify your driving record, previous claims history, vehicles and VIN.
- For Advertising and Marketing: With advertising and marketing partners for advertising and marketing purposes, with your consent, on our behalf and on behalf of third parties, including social network providers, if any.
- For Website Functionality: With companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our Website, analyze our data, provide marketing assistance, process credit card payments, and provide customer service.
- For Certain Analytics and Improvement: With certain companies for purposes of analytics and improvement of our services.
SECTION 7 - THIRD-PARTY SERVICES
The following method of collection and use is undertaken by third parties:
(i) Advertisers. Advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own cookies, Web beacons, and other technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you.
(ii) Hyperlinks. Our Website and email messages sometimes contain hypertext links to websites owned by third parties. We are not responsible for the privacy practices or the content of such other websites. These links are provided for your convenience and reference only. We do not operate or control any information, software, products or services, available on these third-party websites. The inclusion of a link on our Website does not imply any endorsement of the services, products or website, or its sponsoring organization.
SECTION 8 – ELECTRONIC COMMUNICATIONS, TELEMARKETING AND TEXT MESSAGES
By providing your prior express consent/opt-in in accordance with applicable law, you consent to receive communications from us electronically. Although we may choose to communicate with you by other means, we may also choose to solely communicate with you electronically by e-mail or by posting notices on the Site. You agree that all agreements, notices, disclosures, and other communications that we send to you electronically satisfy any legal requirement that such communications be in writing.
Where you provide “prior express written consent” within the meaning of the Telephone Consumer Protection Act (“TCPA”) or any applicable law, you consent to receive telephone calls, including artificial voice calls, pre-recorded messages and/or calls delivered via automated technology and text and SMS messages to the telephone number(s) that you provided from us listed in and hyperlinked to the consent. Message Frequency Varies. The mobile carriers are not liable for delayed or undelivered Messages. Consumers may request up to a maximum of ten (10) messages per month, with no more than three (3) text messages in one day.
You understand that the text messages we send may be seen by anyone with access to your phone. Accordingly, you should take steps to safeguard your phone and your text messages if you want them to remain private.
If you wish to stop receiving text messages from us, reply to any text message we have sent you and simply text “STOP”, “END” or “QUIT”. You may also request to stop receiving text messages by calling us or emailing us using the following information: email@example.com. If at any time you need our contact information or information on how to stop text messages, reply to any text message we have sent you and simply text HELP or click here for support. Message and Data Rates May Apply to any text/SMS communication.
SECTION 9 - LINKS
SECTION 10 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with sensitive information, such as login credentials, then such information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we use generally acceptable commercially standards to protect your personal information.
SECTION 11 – BREACH
Unless otherwise prohibited by applicable law, we shall notify you, as soon as it is reasonably possible under the circumstances but in any event no later than within 72 hours after becoming aware, of any accidental, unauthorized, or unlawful destruction, loss, alteration, or disclosure of, or access to, Personal Data ("Security Breach") likely to result in a high risk of adversely affecting individuals’ rights and freedom. Such notification shall include: (a) a detailed description of the Security Breach, and (b) the type of data that was the subject of the Security Breach and we shall communicate (i) the name and contact details of our data protection officer or other point of contact where more information can be obtained; (ii) a description of the likely consequences of the Security Breach; (iii) a description of the measures taken or proposed to be taken by us to address the Security Breach, including, where appropriate, measures to mitigate its possible adverse effects; and (iv) additionally in such notification or thereafter as soon as such information can be collected or otherwise becomes available, any other information you may reasonably request relating to the Security Breach.
We shall take prompt action to investigate the Security Breach and shall use industry standard, commercially reasonable, efforts to mitigate the effects of any such Security Breach in accordance with its obligations hereunder and, subject to your prior written agreement, to carry out any recovery or other action necessary to remedy the Security Breach. Unless required to do so under applicable Privacy Law, we shall not release or publish any filing, communication, notice, press release, or report concerning any Security Breach. We shall also report such Security Breach as may be required by law to relevant supervisory authority within 72 hours of becoming aware, where feasible.
SECTION 12 – GEOGRAPHIC LOCATION
Our Website, and all associated information technology systems, are housed on servers in a number of countries. Please be aware that if you access the Website in your country of residence, generally the information we collect (including cookies and device data) will be processed and stored in a server located in that country. If you access the Service outside of your country of residence, the information we collect (including cookies and device data) may be transferred to, processed, and/or stored in the country you access the Service from, rather than your country of residence.
Where personal data originating in the European Economic Area is processed outside the European Economic Area, in a territory that has not been designated by the European Commission as ensuring an adequate level of protection pursuant to applicable Privacy Law, we agree that the transfer shall be undertaken pursuant to the immediately preceding paragraph, which we shall maintain in full force and effect.
We have data processing agreements in place to ensure compliance with all relevant Directives. All processing is performed in accordance with the highest security regulations.
SECTION 13 - AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
If our Company is acquired or merged with another company, we may disclose your Personal Data with our prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
Residents of the European Economic Area: Our disclosure is limited to situations where we are permitted to do so under applicable European and national data protection laws and regulations.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, contact us at firstname.lastname@example.org.
We have a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:
Think Tech Sales Limited, Rm 709B, 7/F, Opulent Building, 402-406 Hennessy Road, Wan Chai, Hong Kong