This Privacy Policy describes the information Happy CP Company Limited. (“Company”, “we”, “us” and/or “our”) collects about you, how we use and share that information, and the privacy choices we offer. This Privacy Policy also describes the choices available to you regarding our use of your personal information and how you can access and update such information. This policy applies to information (including personally identifiable data such as contact information and IP addresses (“Personal Data”)) we collect when you register, apply for advances, access or use our website, mobile applications, products, and services, or when you otherwise interact with us (collectively, the “Services”). As used in this Privacy Policy, the term “Site” includes: all websites and all devices or applications operated by the Company that collect personal information from you; pages within each such website, device, or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application; and pages that are associated with each such website, device, or application. A portion of the Personal Data we collect, use, share, and store may be sensitive in nature.
Your access to and use of the Services is also subject to the CONTRACT FOR THE SALE AND PURCHASE OF FUTURE RECEIVABLES, as applicable (the “Business Agreement”), when executed, and Terms of Service at www.choco-up.com/terms-conditions. If there is any contradiction between Privacy Policy and another executed agreement you enter into applicable to specific aspects of the Service, the other agreement shall take precedence in relation to the specific aspects of the Service to which it applies.
As used in this Privacy Policy, the words “you” and “your” refer to you, the user of the Company’s website, device, or applications, as the party agreeing to the Privacy Policy. By visiting and using the Site, you accept the practices described in the Privacy Policy. The use of the word “including” in this Privacy Policy to refer to specific examples will be construed to mean “including, without limitation” or “including but not limited to” and will not be construed to mean that the examples given are an exclusive list of the topics covered.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SITE OR THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THE PRIVACY POLICY. IF YOU ARE ENTERING INTO THE PRIVACY POLICY ON BEHALF OF A COMPANY, BUSINESS OR OTHER LEGAL ENTITY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH ENTITY AND AFFILIATES TO THE PRIVACY POLICY, IN WHICH CASE THE TERMS “YOU” OR “YOUR” SHALL REFER TO SUCH ENTITY AND ITS AFFILIATES. IF YOU DO NOT HAVE SUCH AUTHORITY, OR IF YOU DO NOT AGREE TO BE BOUND BY THE PRIVACY POLICY, YOU MAY NOT ACCESS OR USE THE SITE OR THE SERVICES.
The Company may collect personal information (including Personal Data) and other information about you, including but not limited to the following:
Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.
We take reasonable steps designed to ensure that your Personal Data that we process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy. We do not seek to collect or process Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, or sexual life. Nor do we collect any information about criminal convictions and offences. Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide our client with Services). In this case, we may have to cancel a product or service but we will notify you if this is the case at the time.
We may use, save and analyze the information you provide about yourself and about your Third-Party Sites (together “Data Processing”). Such Data Processing is necessary to perform our Services to you, including in connection with advancing and collecting funds under (or in anticipation of entering) the Business Agreement and Terms of Service, pursuant to our legal obligations (e.g. “Know Your Client” and fraud protection) and our legitimate business interests, including:
If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.
We will not reuse your Personal Data for a new purpose other than the original one(s) for which it was collected, unless one or more of the following apply:
By providing us with your information (including Personal Data and any data that may be subject a privacy regime of any jurisdictions), you are explicitly consenting to our use, collection, monitoring and processing of it in accordance with this Privacy Policy. You acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of the Company and the authorized third parties referred to herein located in the United States and Canada.
This Privacy Policy does not apply to any personal information collected by the Company other than personal information collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to the Company through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and not personal information and the Company shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
This Privacy Policy applies only to the Services. The Services may contain links to other web sites and services not operated or controlled by the Company (the “Linked Sites”). The policies and procedures we described here do not apply to the Linked Sites. The links from the Services do not imply that the Company endorses or has reviewed the Linked Sites, we are not responsible for actions of these Linked Sites. We suggest contacting those sites directly for information on their privacy policies.
In an ongoing effort to better understand and serve the users of the Services and improve data analytics, research and analysis may be compiled and analyzed on an anonymized basis, and the Company may share this anonymized data with its affiliates, agents and business or financing partners. This aggregate information does not identify you personally.
Some of our pages utilize framing or white-labeling techniques to serve content from our partners while preserving the look and feel of our Site. Please be aware that in these instances you may be providing your personal information to these third parties and not to the Company.
We may share personal information about you as follows and you hereby consent to such sharing:
The Company may use th ird parties to gather user’s data from financial institutions. By using our service, you grant our third-party providers the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to terms of our third-party provider’s privacy policy.
We may display personal testimonials of customers on our Site. We may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us by email at support@choco-up.com.
You have the right to ask us not to process your personal information for marketing purposes. You can do this at any time by updating your email preferences in your account or by clicking on the “unsubscribe” link in any marketing email we send you. You can also opt out of marketing by emailing support@choco-up.com .
Data protection law may give you the right to access your personal information, to object to the use of your personal information for certain purposes, and the right to erase or restrict your personal information. Further, you may request the transfer of your personal data to you, or (if technically feasible) to a third party in a machine-readable format. Note that these rights only apply to personal data which you initially provided us. You can make any such requests by emailing support@choco-up.com or via your user account. Certain personal information will need to be retained for administrative, legal, security or other legitimate business purposes.
You can easily access personal information that you have submitted to us and request the correction of any inaccurate information you have submitted to us, via your user account. Alternatively, you can send an email that includes your contact information to support@choco-up.com to request any corrections, or access, to your personal information.
We will handle your requests and rights in accordance with the law. This means there may be legal reasons why we cannot fulfil all requests. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You may have the right to lodge complaints with a data protection authority regarding the processing of your Personal Data, we would, however, appreciate the chance to deal with your concerns beforehand, so please contact us in the first instance.
Retention:
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, administrative, security, compliance, accounting, or reporting requirements. We will need to retain your information for as long as your account is active and for legitimate business interests (including if any amounts, including Specified Amounts (as defined in a Business Agreement) are outstanding). We will retain and use your information as necessary to comply with (and demonstrate compliance with) our legal obligations, resolve disputes, collect on amounts owing and enforce our agreements. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We take reasonable measures, including firewall barriers, SSL encryption techniques, and authentication procedures, to help protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to the Company via the Internet. If you have any questions regarding the security of your personal information, you can contact us by email at support@choco-up.com .
We may provide our registered customers with summaries of their account information and email alerts. We may also allow users to subscribe to email newsletters and from time to time may transmit emails promoting the Company or third-party goods or services.
You have the ability to opt out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails or by contacting us by email at support@choco-up.com . Opting out in this manner will not end transmission of service-related emails, such as email alerts.
We reserve the right, at our discretion, to make changes to this Privacy Policy from time to time without notice, so please review it frequently. You may review updates to our Terms of Service and Privacy Policy at any time via links on www.choco-up.com . You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on www.choco-up.com and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy. Changes take effect immediately upon posting. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
The Company does not knowingly collect Personal Data from persons under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a person under the age of 18 has provided Personal Data to the Company through the Services, please contact us, and we will endeavor to delete that information from our databases.
The laws and regulations in different countries may impose different (and even lower or conflicting) requirements on the Internet and data protection. The servers that make the Site available are located in the Singapore and Hong Kong. Please note that any information you provide may be transferred to Singapore and Hong Kong, and by using the Site or providing the Company personal information (including Personal Data), you authorize this transfer.
If you have questions or concerns regarding this Policy, or if you have any questions or suggestions, please contact support@choco-up.com .
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