Privacy Policy

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:

  • visitors to our website (;
  • users who register for an account and gain access to our platform via our login portal (;
  • users who make use of the Services and Third Party Offerings,
  • users who provide us with Business Information and Supporting Materials; and
  • users who engage or interact with us through email, in-app messaging such as LinkedIn, Facebook, WhatsApp, WeChat, Instagram and/or other social media channels.

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. 

1. What information do we collect?

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:

  1. register for an account on the Site;
  2. correspond with us by email or otherwise;
  3. interact with us through the Choco-up social media channels;
  4. sign up for any Choco-up alerts, newsletters or updates;
  5. complete any survey or questionnaire we send you;
  6. use the Services or Third Party Offerings on the Site;
  7. provide us with Business Information and Supporting Materials through the Site;
  8. apply for any revenue-based financing;
  9. request any technical support from us; or
  10. report any problem to us.

(b) Information we collect through your use of the Site – information is automatically collected when you visit or login into the Site, for example:

  1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, mobile device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  2. information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Site (including date and time), content and Services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and which areas of our Site are the most popular and other statistics.

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. 

2. How may we use your Personal Information?

We may use your Personal Information for the following purposes:

  1. communicating with you by phone, email, in-app messaging such as LinkedIn, Facebook, WhatsApp, WeChat, Instagram and/or other social media channels, including contacting you regarding your enquiries;
  2. processing your request for services and/or providing Services to you;
  3. performing any functions and activities related to Services provided by us;
  4. administering any of the Site and the Services or managing our relationship;
  5. improving and developing the Site and the Services;
  6. researching, designing and launching new features or products or services;
  7. presenting content and information on the Site and the Services in the most effective manner for you and for the device you use;
  8. providing you with alerts, newsletters, updates, materials or information about the Site and the Services or other types of information that you requested or signed up to;
  9. exercising our contractual rights including collecting outstanding amounts (if any);
  10. complying with laws and regulations applicable to us;
  11. making disclosure when required by law, regulation, or court order of any jurisdiction and/or as requested by any government, regulatory or law enforcement authority or administrative organization, which may be within or outside Hong Kong;
  12. responding or taking part in legal proceedings, including seeking professional advice;
  13. for direct marketing purposes (please see further details in Section 2.2 below); 
  14. enabling an actual or proposed assignee, trustee or participant of all or substantial part of our rights and business to evaluate the transaction intended to be the subject of the assignment, transfer or participation; and
  15. purposes directly related or incidental to the above.

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:

  1. the Personal Information that may be used in direct marketing are those that you provide to us, or we collect from you under Section 1.1 above;
  2. the relevant information may be sent to you by email, in-app messaging such as LinkedIn, Facebook, WhatsApp, WeChat, Instagram and/or other social media channels;
  3. you may opt out any time by emailing us at We will cease to send you marketing information without charge.

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: 

  1. our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (for example, to provide you with the Services, to provide you with our customer assistance and technical support), or 
  2. our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or 
  3. our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve the Site and the Services by identifying user trends and the effectiveness of our promotional campaigns and identifying technical issues), provided it is conducted in a way that is proportionate, and that respects your privacy rights. 

3. How we share, transfer or process your Personal Information

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.

4. How long do we retain your Personal Information?

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. 

5. Use of Cookies and Similar Technologies

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: 

  1. Strictly necessary cookies are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas of the Site, use a shopping cart or make use of e-billing services.
  2. Analytical/performance cookies allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
  3. Functional cookies are cookies used to remember choices users make to improve their experience.
  4. Marketing cookies are used to collect information about the impact of our marketing campaigns performed in other websites on users and non-users. 

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. 

6. Third-party sites

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. 

7. Security 

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. 

8. Your rights in relation to your Personal Information

You have the right to:

  1. check whether we hold Personal Information about you;
  2. access and receive a copy of any Personal Information we hold about you;
  3. require us to update, amend, delete, or limit the use of (such as cease using your Personal Information for direct marketing purpose) your Personal Information that we hold about you, subject to our rights to retain Personal Information under Section 4; and
  4. to check our policies and practices in relation to Personal Information.

We reserve the right to charge a fee where permitted by law, to meet our cost in processing your request.

9. Changes or updates to our Privacy Policy

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.

10. Contact us

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: