Scope and Policy

Waffo Hong Kong Limited will only gather and handle your personal information when it is essential or relevant to our interactions with you. This Privacy Policy outlines our procedures for handling your Personal Data, encompassing its collection, processing, utilization, disclosure, transfer, retention, storage, and disposal when we deliver our services.

By accepting this Policy, you consent to the collection, processing, utilization, disclosure, transfer, retention, storage, and disposal of your Personal Data as described below.

"Personal Data" refers to information about you as an individual, whether accurate or not, that can identify you on its own or when combined with other information we have or may obtain access to. The Personal Data we gather and handle may include:

1. Your first and last names;
2. Email address;
3. Mobile phone number;
4. IP address;
5. Cookies and/or statistical/analytical data, such as your browsing behavior, to the extent that it may be used to identify you;
6. Your social media links or public profiles, along with any personal information visible there, which you may provide during customer support interactions;
7. Account passwords you create;
8. Any other personal information you provide while using our services.

This Policy only applies to Personal Data which is in our possession or under our control.

We collect and process your Personal Data to enable you to make purchases through us, your mobile network operator, the relevant third-party payment channel operator (the "Payment Channels"), or a publisher of digital products (the "Publishers") via our platform.

We retain the discretion to modify this Policy periodically without providing prior notice to you. Any changes will be posted and made accessible on our Platform, becoming effective as of the specified date below. You can ascertain whether any revisions have occurred by referencing the last update date for this Policy, indicated below. We advise you to periodically review this Policy to stay informed of the most recent version. Your continued utilization of the services following an amendment signifies your acknowledgment and acceptance of those modifications.

Collection of Personal Data

We collect your Personal Data when you use the services or communicate with us. In these instances, you may provide your Personal Data to us directly, or it may be shared with us by our affiliates or subsidiaries, the Payment Channels, or the Publishers, pursuant to your consent given to these third parties.

You may also submit Personal Data to us via other methods, including:

1. in response to our communications;
2. through social media or online forums;
3. through participation in an offer, program or promotion conducted by us;

We also gather transaction details, including the purchase amount, purchase date, and information pertaining to the digital content, products, and/or services you acquire ("Transaction Data"). We do this to advance our legitimate interests and fulfill our contractual obligation of granting you access to services of our Platform. Generally, these details are not categorized as Personal Data since they do not reveal your identity. However, should it be possible to identify you from the Transaction Data, we will treat and handle them as Personal Data according to this Policy. By using our Platform's services, you consent to the collection of such Transaction Data from you.

You must provide us with information which is accurate and not misleading. In this connection, we reserve the right to request for documentation to verify the information that you provide to us.

Use and Disclosure of Personal Data

Your data shall be processed for the following purposes:

1. Transaction processing and content delivery;
2. Other permitted uses and disclosures.

Transaction Processing and Content Delivery

In our capacity as a digital content service provider, online distributor of digital content, and supplier of associated services, we will utilize your Personal Data and may disclose it to third parties, which may include our affiliated companies or subsidiaries, payment channels, and publishers. This is done with the aim of delivering the services to you or when it is an essential aspect of conducting business with you.

In particular, your Personal Data may be processed for the following:

1. Facilitating your use of our services;
2. Processing and verifying your online transactions and payments on our Platform;
3. Resolving any disputes in relation to your transaction;
4. Mitigating fraud;
5. Protecting our legitimate interests;
6. Enforcing our contractual rights;

Other Permitted Uses and Disclosures

You accept that we may also use your Personal Data for the following purposes:

1. Maintaining and securing any user accounts that you may have;
2. Notifying you of matters relating to your account or your transactions that may require your attention;
3. Processing service requests, resolving concerns, and responding to queries or feedback that you may communicate to us;
4. Managing or complying with our internal security or risk management mechanisms;
5. Conducting statistical analysis or market and customer research, including surveys to ensure customer satisfaction. Please note that we may share your Personal Data with our third party service providers for such purposes;
6. Improving your experiences with our customer care services;

You understand and accept that we may also disclose your Personal Data to our affiliates or subsidiaries, Publishers, Payment Channels, or other parties as permitted or required by applicable law, such as government authorities or regulators, or other necessary persons, for the following purposes:

1. For or in connection with the negotiation of any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business;
2. If we believe that disclosure is reasonably necessary to (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) assist in any investigations or proceedings; and (ii) protect the security or integrity of the our services, us, or any of our users or the public from harm or illegal activities.

Your choices, rights and exceptions

You possess the right to request the removal of your Personal Data or withdraw your consent for its processing, particularly when we are processing your Personal Data solely based on your consent. If you desire the removal of your Personal Data or prefer not to have it utilized or processed for the mentioned purposes, please get in touch with us. Nonetheless, please be aware that if your Personal Data is deleted or you withdraw consent for any of the purposes mentioned above, depending on the nature of your request, it may impact our ability to continue providing the services to you or to process and complete the transactions you intend to carry out on our Platform.

You possess the right to access, update, or request the correction of the Personal Data you've furnished to us at any point. Should you wish to access the Personal Data we have on record for you or request updates or corrections to your Personal Data, please feel free to reach out to us. Depending on the nature of your request, there may be a reasonable administration fee, the details of which we will promptly communicate to you.

Retention and Disposal of Data

We will retain your Personal Data for as long as it is required to fulfill the initial purpose for which it was gathered and until it is no longer necessary for any additional legal or business objectives. Following that, we will securely dispose of your Personal Data to prevent any further access or processing, which may involve actions such as deletion or irreversible anonymization.

Security

We exert diligent efforts to ensure the security of your Personal Data, aiming to guard against loss, misuse, unauthorized access, alteration, accidental disclosure, or destruction. Nevertheless, it's important to note that complete security cannot be guaranteed for data transmission or storage over the Internet. However, we have implemented and consistently uphold a range of security measures, including but not limited to the following, to protect your Personal Data to the best of our reasonable capabilities:

1. Limiting Personal Data access to authorized and/or necessary personnel;
2. Implementing technical solutions to ensure information security;
3. Continuous monitoring and review of Personal Data protection measures;
4. Other security measures, as may be required by the laws and regulations applicable in the country where you are located.

Collection of Statistical Data

We gather statistical information related to your website usage and online interactions with our Platform, and we also permit third parties (including but not limited to Amazon Web Services, Facebook, and Google) to collect such data using "cookies" and similar technologies. This statistical information is anonymized and does not reveal your identity; it encompasses metrics like page visits, access timestamps, dates, and browser types. We collect this data for analysis and assessment purposes, aiding us in enhancing our Platform.

"Cookies" are a functionality within your internet browser that stores minimal data on your computer when you visit a website. They enable us to identify a specific device or browser, enabling us to tailor and customize content according to your preferences, thereby enhancing the usefulness of our services and Platform for you. "Cookies" do not reveal your identity unless you willingly provide us with personally identifiable information. You may have the option to control and remove "cookies" by choosing specific settings in your browser.

We may share your statistical data with our third-party partners in the following contexts:

1. Partners with whom we engage in advertising.
2. Partners who assist us in delivering or enhancing our services.
3. Partners seeking to promote their products or services that may align with your interests.
4. Partners looking to enhance their products or services provided to you.

Contact Us

To get in touch with us regarding any aspect of this Policy or your Personal Data, including but not limited to actions such as withdrawing consent, opting out of receiving gifts and prizes, requesting access to your Personal Data, seeking updates or corrections to your Personal Data, or exercising any of your rights as stipulated in this Policy or relevant data protection laws, please feel free to contact us.