Introduction
The following is the privacy policy (“Privacy Policy”) of QFun Global INC (collectively, “QFun Global INC.,” “we,” “us,” or “our”). QFun Global INC recognizes the importance of your privacy rights and is committed to protecting the Personal Information (defined below) that QFun Global INC collects, uses, and discloses from users of this website (the “Website”) and our applications, other websites such as https://swiftshopmart.com , or offline services, in each case that link to or expressly reference this Privacy Policy (collectively, the “Website/Services”).
This Privacy Policy governs how we use your personal information: what we collect, how we collect it, how we use it, why we use it, with whom we share it, and what rights you may have under the Personal Data (Privacy) Ordinance of Hong Kong Special Administrative Region. We recommend that you read this Privacy Policy in its entirety, including the jurisdiction-specific provisions in this Privacy Policy that apply to users in certain jurisdictions.
This Privacy Policy is designed to be reasonably accessible to people with disabilities. If you have any difficulty accessing the information in this Privacy Policy, please send an email to [email protected]
If you are located in the United Kingdom, Switzerland, or the European Economic Area, our collection, use, and disclosure of your information is governed by the Privacy Policy available here, not this Privacy Policy.
If you are located in the United States, our collection, use, and disclosure of your information is governed by the Privacy Policy available here, not this Privacy Policy. Please note that the “Notice at the Time of Collection; Categories of Personal Information We Collect and Use” section of our U.S. Privacy Policy describes our practices for collecting and using information through the Site/Services and also serves as the Notice at the Time of Collection we provide to California residents pursuant to the California Consumer Privacy Act (“CCPA”).
Notice at the Time of Collection; Categories of Personal Information We Collect and Use
Advertising, Marketing, and Analytics Activities
Retention of Personal Information
Sources of Personal Information
Disclosure of Personal Information
Transfers of Data
Cookies, Web Beacons, Tags, and Other Similar Technologies
Your Rights and Choices
A. Privacy Rights
B. Cookies and Interest-Based Advertising
C. Unsolicited Communications
Third-Party Links
Privacy Governance and Security
Children’s Privacy
Changes to This Privacy Policy
How to Contact Us
Notice at the Time of Collection; Categories of Personal Information We Collect and Use
We collect certain types of personal information from or about you during our interactions with you and from other sources in compliance with the Personal Data (Privacy) Ordinance of Hong Kong.
“Personal Information” means any information that:
identifies or can be used to identify you or your family;
that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your or household;
that can be used to authenticate you or provide access to an account;
Personal Information does not include aggregated, de-identified, or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you. We will maintain and use de-identified information in de-identified form and will not attempt to re-identify such information, except to make sure the information is truly de-identified in accordance with Hong Kong privacy laws.
Over at least the last 12 months, we have collected, used, and disclosed the categories of Personal Information listed in the table below for the purposes and activities we have listed in the table below. In addition, we sell and share the following categories of Personal Information for cross-context behavioral and targeted advertising: personal identifiers, demographic information, commercial information, device, internet and network activity information, online identifiers, general location information, and inferences drawn from the above categories, subject to Hong Kong regulatory requirements.
Personal Information may also be processed if it is necessary:
on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim under Hong Kong laws;
to address or prevent a policy or terms violation;
to enforce our rights under Hong Kong jurisdiction;
to enforce our agreements;
to protect against unauthorized access to our systems or other inappropriate use of our Sites/Services; and
to provide you with a service or experience at your request.
We will not delete Personal Information if relevant to an investigation or dispute under Hong Kong legal procedures. It will continue to be stored until those issues are fully resolved in accordance with Hong Kong legal requirements.
We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our products to you based on fraud detection and creditworthiness checks. This will be informed by verification of Personal Information (including by vendors engaged by us). Depending on the outcome of these checks, a decision will be reached automatically as to whether we are able to provide products to you, complying with fair processing principles under the Hong Kong Personal Data (Privacy) Ordinance.
Where we need to collect your Personal Information 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 with you (for example to provide our products to you), subject to Hong Kong contract and privacy laws.
ADVERTISING, MARKETING, AND ANALYTICS ACTIVITIES
Email marketing communications – our email marketing will include press releases and information about us, our website, our products and services, any events we may hold and the offers and promotions we offer from time to time. Our marketing communications will include personalised and non-personalised marketing in compliance with Hong Kong direct promotion regulations. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you. In accordance with the Hong Kong Personal Data (Privacy) Ordinance, you have the right to opt out of all direct marketing communications free of charge at any time.
Online behavioural advertising – we and our third party partners may use your personal data that we have collected and other data that is collected through your interactions with third party websites and services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the “social media retargeting” section below). By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our website or which you otherwise might be interested in based on your browsing habits, although our third- party partners may use the data that is collected to show personalised ads for products and services offered by third parties. All such activities are regulated under Hong Kong personal data protection laws.
These vendors may collect information about your visits to our website, and your interactions with our products and services. Such vendors may place and access their own cookies, tags, web beacons or similar technologies on your computer or device used to access the website to serve you ads or other content personalized to your interests (“Interest-based Advertising”). In addition to the information about your visits to our website, these vendors may also use the information about your visits to other websites to target advertisements for products and services available from QFun Global INC.
As described in more detail in the “Cookies and Interest-Based Advertising” section below, you may be able to set your browser to reject cookies later. In that case, you may still receive online advertising, but it may be less personalized, consistent with Hong Kong user privacy protection rules.
Social media retargeting – If we advertise to you on social media and other platforms we share your email address (usually in an encrypted or ‘hashed’ form) with third-party ad partners or providers of social media platforms and other services, such as Facebook and Google and other similar platforms (“Social Platforms”), so that the third party providers can try to “match” your data with the data of their registered users of their Social Platforms. This is done by us providing a list of hashed email addresses to Social Platforms or incorporating a pixel from Social Platforms into our own Sites/Services, and the Social Platforms matching common factors between our data and their data collected via cookies or pixels. For instance, we may incorporate the Facebook pixel on our Sites/Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g., on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service. Some of the advertising that you see may be personalised to you. For more information about the cookies used by these Social Platforms and our partners, please see the Cookies section. All social media marketing activities comply with Hong Kong Personal Data (Privacy) Ordinance requirements for personal data processing and cross-platform promotion.
If we advertise to other people who share similar interests and characteristics to you, we will also provide your personal data to Social Platforms. If you are a user of those Social Platforms, we may ask the Social Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users. This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you.
Please note that such activity is also subject to the privacy choices you have elected to make on such third-party services and must comply with Hong Kong personal data protection regulations.
The relevant Social Platform act as our service provided and in other contexts may also be a controller in respect of the personal data that is collected via your use of our social media pages and may independently use that personal data for additional purposes. For details of how the relevant Social Platform uses your personal data as well as how to request a deletion of personal information collected by these Social Platforms, please see the privacy policy of the relevant Social Platform.