How We Protect Your Privacy
We do not provide services or sell products to children. However, we may sell products to adults for use by children. Regardless of the intended end user of our products, only adults should purchase anything from our website. If a product we offer is legal only for adults to use or possess, no adult should purchase the product for illegal use or possession by a minor.
If you are less than 18 years old, you may use our website only with the permission, active involvement, and supervision of an adult parent or legal guardian. If you are a minor, please do not provide us or other website visitors with any personal information.
This Policy Is Part Of Our Terms And Conditions Of Use
This Policy and Customer Agreements
If you are our customer, any customer agreement between us supersedes this policy to the extent there is any conflict with the terms and conditions of the customer agreement.
The type of information we collect from you and interest-based advertising.
Like most places on the Internet, simply by visiting our website you automatically tell us certain information. This includes basic information such as your IP address, when you visited, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer’s operating system, and the type of web browser that you are using. Our website automatically records this basic information about you.
If you are using one of the common Internet Web browsers, you can set up your browser to either (a) let you know when you are being tracked by us or to (b) deny us tracking access to your computer or electronic mobile device. The manufacturer of the browser you use has instructions on how to modify tracking settings. You may find these instructions in the “Help” section of your browser or by contacting the browser’s manufacturer.
If you download or use mobile software applications (“Mobile Apps”) from our website, we may know your location. In addition, your smart phone, computer tablet, or other electronic device using our Mobile Apps may provide us information about the device, including its unique identifier, make and model, operating system, mobile network carrier, and your telephone number. Your mobile device may have the ability to disable location services as well as deny us access to other information described in this paragraph. To learn more, check your mobile device’s user manual and/or contact your mobile device’s manufacturer or service carrier.
We may also collect any data that you provide us by posting it at our website or by sending to us via email. You can always choose not to provide us with information. However, if you do withhold information, we may deny you access to some or all of our website’s services and features.
Some transactions between you and our website may involve payment by credit card, debit card, checks, money orders, and/or third party online payment services. In such transactions, we will collect information related to the transaction as part of the course of doing business with you, including your billing address, telephone number, and other information related to the transaction.
What We Do With Your Information
We use your information to operate our website’s business activities. For example, we may use this data to contact you about changes to our website, direct marketing (e.g. new products and services, special offers, etc.), resolve disputes, troubleshoot issues, and enforce our website’s terms and conditions.
If you download or use Mobile Apps from our website, the information we learn about you may be used by us to give you personalized content based upon your location and other data you share. If you do not want to share your location via Mobile Apps, check the instruction manual for your electronic device or contact your device’s manufacturer to see if you can turn off the locator feature.
As a general rule, we will not give your data to third parties without your permission. However, there are some important exceptions to this rule that are described in the following paragraphs.
We may, in our sole discretion, provide information about you to law enforcement or other government officials for purposes of fraud investigations, alleged intellectual property infringement, or any other suspected illegal activity or matters that may expose us to legal liability.
Some government intelligence agencies have the technological ability to access data from our website without our cooperation, knowledge, or consent. Even if we were to learn of such access, we may not be able to tell you because of national security laws. Please take this risk into account before supplying information to us or any other website owner.
Although we do not disclose individually identifiable information, we may disclose aggregate data about our website’s visitors to advertisers or other third parties for marketing and promotional purposes.
From time to time, we may use third party suppliers to provide services on our website. If a supplier wants to collect information about you, you will be notified. However, you will never be required to give information to a third party supplier. We restrict the way third party suppliers can use your information. They are not allowed to sell or give your information to others.
If we sell our website, we may transfer your information to the purchaser of the site. Upon completion of such a transfer, we will no longer possess or control the data received by the purchaser.
Do-Not-Track, Interest-Based Advertising, Remarketing, and Dynamic Ad Serving
We try to honor any Do-Not-Track signals you send through your web browser when visiting our website. However, please read the following important information about “Interest-Based Advertising,” “Remarketing,” and “Dynamic Ad Serving” so that you understand the type of tracking that may be done by third party vendors when you visit our site and how you can opt out of such tracking.
When you visit our website, you may view advertisements posted on the site by Google or other companies. These advertising companies may collect information about you while you are visiting this website and other websites. They may use this data to show you advertisements on this website and elsewhere on the Internet about products and services you might like.
This website does not collect the information or control the content of the advertisements that you will see. You may be able to opt out of such advertising.
If you are in the United States, you may opt out of some advertising via the Digital Advertising Alliance at http://www.aboutads.info/choices/
If you are in Canada, you may opt out of some advertising via the Digital Advertising Alliance of Canada at http://youradchoices.ca/
If you are in the Europe Union or the United Kingdom, you may opt out of some advertising via the European Interactive Digital Advertising Alliance at http://www.youronlinechoices.com/
To find out more about Google privacy policies and its DoubleClick DART cookie used to generate interest-based advertising, go to https://policies.google.com/technologies/ads .
Protect My Choices
If you are using Internet Explorer, Mozilla Firefox, or Google Chrome browsers, you may wish to install the “Protect My Choices” browser extensions that are designed to help you protect your opt-out preferences. To learn more, go to http://www.aboutads.info/PMC.
Dynamic Ad Serving
Our website may use Google’s Dynamic Ad Serving feature. To opt out of interest-based ads by Google, follow Google’s opt-out instructions located at https://support.google.com/ads/answer/2662922?hl=en .
DoubleClick Remarketing Pixels
Your use of this website without opting out means that you understand and agree to data collection to provide you with interest-based advertising.
User Names And Passwords
Your access to parts of our website may be protected by a user name and a password. Do not give your password to anyone. If you enter a section of our website that requires a password, you should log out when you leave. As a safety precaution, you should also close out of your web browser completely and re-open it before viewing other parts of the Internet.
Use Of Information And Unsolicited Commercial Email
If you obtain personally identifiable information about another website user, you are not allowed to disclose this information to anyone else without the consent of the user and our consent too. If you communicate with other website users via our website (or by other means), such third parties may have copies of your communications even if you delete your own copies of such communications on our website and your electronic devices.
We hate junk email (spam). Information you obtain from our website about us or other site users cannot be used by you or others to send unsolicited commercial email or to send unsolicited commercial communications via our website’s posting or other communication systems.
Your Voluntary Disclosure Of Information To Third Parties Who Are Not Our Suppliers
You may choose to provide personal information to website visitors or other third parties who are not our suppliers. Please use caution when doing so. The privacy policies and customs of these third parties determine what is done with your information.
We may use autoresponders to communicate with you by email. To protect your privacy, we use a verified opt-in system for such communications and you can always opt-out of such communications using the links contained in each autoresponder message. If you have difficulties opting out, you may contact us by sending an email to sean.ring[at]finlingo.com, or sending us mail to the address listed below.
We try to keep your information secure. If we become aware of a data vulnerability, where economically feasible, we will attempt to promptly fix it in order to keep your data safe. However, with governments spying online using sophisticated technology and hackers data mining sites, no website owner can guarantee your information will be completely safe from unauthorized access by others. Please take these security risks into account before giving information to us or any other website owner.
We will keep your data for as long as we need it to provide you with products and services, comply with applicable law, resolve any disputes between us or with third parties, and to enforce any contracts between us.
California, European Union & Brazilian Privacy Rights
If you are a California resident and our customer, Cal. Civ. Code § 1798.83 permits you to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To request this information, please send an email to sean.ring[at]finlingo.com or write us at the following address:
903 Dannies House
20 Luard Road
Wan Chai, Hong Kong Island 000000
Hong Kong SAR
If you reside in the State of California, you may have certain privacy rights under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 to § 1798.199 (“CaCPA”). However, the CaCPA does not apply to us for one or more of the following reasons: (1) we are a small or medium-sized enterprise (“SME”) that is not a “business” as such term is defined in Subsection 1798.140(c) of the CaCPA; and (2) other laws apply to us that conflict with and/or supersede the CaCPA.
Even though we do not have a legal obligation to do so, we may respond to your requests made per the CaCPA. However, these voluntary responses are not a waiver of our legal rights and obligations under the laws of Hong Kong Island and Hong Kong SAR or the arbitration provisions found within our website’s Terms and Conditions of Use.
European Union Residents
If you reside in the European Union, you may have certain privacy rights under Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), to the extent the GDPR does not conflict with the laws of Hong Kong Island and Hong Kong SAR. Even if we do not have a legal obligation to do so, we may respond to your requests made per the GDPR. However, voluntary responses are not a waiver of our legal rights and obligations under the laws of Hong Kong Island and Hong Kong SAR or the arbitration provisions found within our website’s Terms and Conditions of Use.
Small Or Medium-Sized Enterprise Status
We are a small or medium-sized enterprise (“SME”). This means that because of the size of our business, to the extent (if any) the GDPR governs our relationship with you, some of GDPR’s obligations do not apply because we are an SME.
If you reside in the Federative Republic of Brazil, you may have certain privacy rights under Brazil’s General Law on Protection of Personal Data, Lei Geral de Proteção de Dados Pessoais, Law No. 13,709/2018 (“LGPD”), to the extent the LGPD does not conflict with the laws of Hong Kong Island and Hong Kong SAR. Even if we do not have a legal obligation to do so, we may respond to your requests made per the LGPD. However, voluntary responses are not a waiver of our legal rights and obligations under the laws of Hong Kong Island and Hong Kong SAR or the arbitration provisions found within our website’s Terms and Conditions of Use.
How To Make A Request
To make a request under the CaCPA (California residents), GDPR (European Union residents), or LGPD (Brazil residents), please send an email to sean.ring[at]finlingo.com or write us at the following address:
903 Dannies House
20 Luard Road
Wan Chai, Hong Kong Island 000000
Hong Kong SAR
We will respond within thirty (30) days of receipt of your request.
Requests to Access Personal Data
If we grant your request to access personal data, we will: (1) confirm whether or not we are processing your personal data; (2) provide you with a copy of any of your personal data that we possess; and (3) provide you with information about how we process such data (e.g. purposes, categories, recipients, etc.).
Requests to Delete Data
If you request that we delete your personal data that we possess, we will do so unless: (1) the data is needed to exercise the right of freedom of expression; (2) we have a legal obligation to keep the data; (3) we must keep the data for reasons of public interest; or (4) the data has been processed so that it is anonymized.
Any personal data we processed unlawfully will be deleted. If you were a minor when we collected the personal data, we will delete the data upon request.
If we believe any third parties have acquired your personal data through us, we will take reasonable steps to inform them that you have requested erasure of such data.
Objections to Processing Of Personal Data
If your request is an objection to the processing of your personal data for directing marketing purposes, we will cease using your data for such purposes.
As a general rule, we will comply with objections to processing personal data except: (1) where it is not technically or commercially feasible to do so; or (2) we have a legal obligation that overrides your individual rights and freedoms.
If we collected personal data from you because of a contract between us or based on your consent, and we processed that data by automated means (in structured machine-readable format), you can request that data be transmitted by us to another company or organization.
We will provide such data to the recipient third party in a commonly used open format electronic file (e.g. CSV, JSON, XML, etc.).
If we reject your request, we will provide you with the reason(s) for doing so. You may then choose to file a complaint with the Data Protection Authority and request a judicial remedy to the extent such a request is not in conflict with the laws of laws of Hong Kong Island and Hong Kong SAR or the arbitration provisions of our website’s Terms and Conditions of Use).
As a general rule, there is no fee for processing yourrequest. However, we reserve the right to refuse your request or charge a reasonable fee for processing it if the request is manifestly unfounded or excessive. For example, it would be excessive to make a repetitive second request to access your personal data one month after we provided you with the data from a prior request.
We may make decisions through automated processing (e.g. algorithms) of personal data that are legally binding or significantly affect you.
Any such automated decision-making is done per your express consent or because it is necessary for reasons of substantial public interest under applicable law.
Such an automated decision may be made based on relevant law. However, if the decision is made for other reasons, we will inform you of the process’ logic and potential consequences of the decision. To the extent that the laws where you reside do not conflict with the laws of Hong Kong Island and Hong Kong SAR or the arbitration provisions found within our website’s Terms and Conditions of Use, you may also have a right to obtain human intervention and contest the automated decision.
We, our principals, employees, and agents shall not be liable for failure to perform any of our obligations under this policy during any period in which we cannot perform due to fire, earthquake, flood, or other natural disaster, epidemic, pandemic, explosion, casualty, war, terrorism, embargo, riot, civil disturbance, act of public enemy, act of God, or the intervention of any government authority, or similar cause beyond our control.
Questions or Concerns
You may also mail your concerns to us at the following address:
903 Dannies House
20 Luard Road
Wan Chai, Hong Kong Island 000000
Hong Kong SAR
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