Last updated: 2 March 2023
Choco Up respects your privacy and is fully committed to protecting your Personal Information and to use it properly and in compliance with Hong Kong data privacy laws.
This Privacy Policy governs how we at Happy CP Company Limited trading as “Choco Up” and our affiliated companies (collectively, “Choco Up”, “we”, “our”, or “us”) collect, use, and process Personal Information (as defined herein) collected from:
Our website and login portal are collectively called the “Site”. All capitalised terms used here in this Privacy Policy shall have the same meanings and definitions as used in the Terms of Service.
Please take a few moments to read this Privacy Policy before you access or use the Site and Services. By continuing to use or access the Site and Services, you acknowledge that you have read and fully understood this Privacy Policy and its applicability to you. If you do not read or if you do not agree to any of the terms herein, then please do not continue to use the Site or Services. This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.
For the purposes outlined in this Privacy Policy and to allow you access and use of the Site, we may collect and process the following Personal Information about you:
(a) Information that you give us – information that you provide us which may include personal information of an identified or identifiable natural person, including but not limited to your name, email address, mailing address, telephone number, date of birth, social security number, national identification number, citizenship, job title and if you are an authorized signatory of your business, credit card information, bank account information including account value and other information of a sensitive nature or personal description. Such information may be given to us when you:
(b) Information we collect through your use of the Site – information is automatically collected when you visit or login into the Site, for example:
If you use a mobile device to access the Site, we also collect certain information that your mobile device sends when you use the Site, including user settings, the operating system, as well as information about your use of the Site and the Services. We use this information to administer the Services and we (or third parties engaged by us) analyze this information to further develop, improve and enhance the Site and the Services by expanding their features and functionality and tailoring them to your or other users’ needs and preferences, and to make recommendations.
(c) Information we receive from other sources or third parties – we work with third parties and we may receive information about you from them, for example, business partners, advertising and marketing partners and networks, analytics providers, or search information providers.
We may use your Personal Information for the following purposes:
Only with your consent or indication of no objection, we may use your Personal Information in direct marketing (meaning we may offer or advertise new or additional Services by sending the relevant information directly to you), and you may opt out any time. For the purposes of this Section 2.2:
We will not disclose Personal Information relating to you, to third parties for them to use for their own direct marketing purpose without your consent. We will only use your Personal Information for the purposes set out in Section 2 where you give us your consent, indicate no objection of usage and/or we are satisfied that:
We will keep your Personal Information confidential but you agree we may share your information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
a) Third Party Service Providers or Third-Party Offerings: We may share Personal Information as well as aggregated information that we collect with third party service providers whose services and solutions are provided through the Site and/or which complement, facilitate and enhance our own. These include but are not limited to hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, industry analysis, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimisation and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Services”); provided further that we may share information with Third Party Services for a business purpose such as identifiers, commercial information and other categories as listed in Section 1.
b) Information Disclosed for Our Protection and the Protection of Others. Where permitted by local data protection laws, we will disclose Information when required by law or under the good-faith belief that such disclosure is necessary in order to conform to applicable law, comply with court orders or legal process served on us, to establish or exercise our legal rights or defend against legal claims, and to protect our property or interests, agents and employees, personal safety, or the public. Under these circumstances, we may be prohibited by law, court order or other legal process from providing notice of the disclosure, and we reserve the right under those conditions not to provide notice in our sole discretion.
c) Parent Companies, Subsidiaries and Affiliated Companies. We may share Personal Information internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should we, or any of our affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
d) Our Representatives (on a need-to-know basis only). We may share Personal Information with our employees, officers, directors, personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the provision of the Site and the Services to you, and the provision of support services).
For the avoidance of doubt, we may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so.
The Personal Information that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons referred to in this Section who operate outside Hong Kong.
By submitting your Personal Information, you agree to this transfer, storing or processing of data outside Hong Kong. We will take steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy Policy.
We only retain Personal Information for so long as it is necessary, as indicated in this Privacy Policy or as otherwise needed to provide you with use and access to the Site and the Services. We may continue to retain such Personal Information even after we cease to provide you with the Site and the Services, as reasonably necessary to comply with our legal obligations, to resolve any disputes, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests. Where your Personal Information is no longer required, we will take steps reasonably necessary to ensure it is securely deleted.
A cookie is a small file of letters and numbers downloaded on to your computer when you access certain websites. In general, cookies allow a website to recognize a user’s computer. The most important thing to know about cookies placed by us is that they intend to make the Site more user-friendly, for example, by remembering site preferences and language settings or to distinguish you from other users of the Site. This helps us to provide you with a better experience when you browse the Site and also allows us to improve the Site.
Depending on their function, cookies may have different durations. We use persistent cookies and session cookies.
a) Persistent cookies stay in your browser and will be read by us when you return to the Site.
b) Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
We also use, or may in the future use, the following cookies on the Site:
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site. Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of the Site and the Services or may otherwise negatively affect your user experience.
Our Services may contain links to other websites or services, in particular links to any social media channels and the Third-Party Offerings. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave the Site and to read the privacy statements of each and every website and service you visit before providing your information. This Privacy Policy does not apply to such linked third-party websites and services which are subject only to the third party policies.
All information you provide to us is stored on our secure servers. We have implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways for further enhancing the security of the Site and the Services and protection of our visitors’, clients’ and users’ privacy.
We restrict access to Personal Information to our Representatives and Third-Party Service Providers on a need-to-know basis and will take reasonably necessary steps to ensure that those persons are subject to confidentiality obligations.
We may review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
Please note, however, regardless of the measures and efforts taken by us, transmission of Personal Information via the Internet is not completely secure, and we cannot and do not guarantee the absolute protection and security of your Personal Information. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Site and the Services or shared with us through email, in-app messaging such as LinkedIn, Facebook, WhatsApp, WeChat, Instagram and/or other social media channels; any transmission is at your own risk.
You have the right to:
We reserve the right to charge a fee where permitted by law, to meet our cost in processing your request.
We may update this Privacy Policy as required by applicable law, and to reflect changes to our information collection, usage and storage practices. In relation to any updated Privacy Policy, we will, where required by applicable law, notify you, seek your consent and/or take any other measures. However, we encourage you to periodically review this page for the latest information on our privacy practices. By continuing to use the Site and the Services after the changes come into effect means you agree to be bound by the revised policy.
If you have questions about this Privacy Policy or our policies or wish to exercise any of your rights as described, please contact us at: support@choco-up.com
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