As your Service provider, Posify Group Limited ("we ", "our " or "us ") respects your legal rights of privacy when collecting, storing, using and transmitting Personal Information (as defined below) and this Privacy Policy explains our privacy practices. It is our policy and obligation to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong). In doing so, we will ensure compliance by our staffs to the strictest standard of security and confidentiality.

Please read the following carefully to understand our policy and practices regarding how your Personal Information will be treated. This Privacy Policy applies to all registered and unregistered Users of the Sites and Service App and may from time to time be revised, or otherwise changed where necessary.

Words or terms used in this Privacy Policy which are not specifically defined in this Privacy Policy have the meaning given to them in the Agreement (as defined below).

By being one of our Users or visitors to our Sites and/or Service App you agree to be bound by all the terms and conditions set out in this Privacy Policy and THAT YOU GIVE US YOUR CONSENT to collect, use and disclose such Personal Information. If you do not accept the terms of this Privacy Policy or disagree with any subsequent amendments, changes, or updates we made, you MUST NOT access the Sites or the Service App and not use any Service provided by us. You hereby agree your only recourse in this case is to cease and desist from further use of the Service.

We strongly recommend you to read this Privacy Policy and if you have any questions, please don’t hesitate to send us an email at legal@posify.me.

If there is any inconsistency between the English and Chinese versions of this Privacy Policy (unless otherwise indicated), the English version shall prevail.

1. DEFINITIONS AND INTREPRETATIONS

1.1 The following shall have the meaning describe hereinbelow: -

(a) "Agreement" means the user agreement entered between us as the provider of the Service on the one part and you as the User on the other made effective upon your continued use of the Sites and/or Service.

(b) "Account" means an established relationship between the User and the network of information service provided by us including the username and password created by the User at his own initiative or provided by us and accepted by us for the purpose to enable the User to gain access to the Service provided by us.

(c) "Associates" means each and every one of our respective shareholders, subsidiaries, employees, advisers, contractors, agents, directors, officers, partners, insurers, and attorneys.

(d) "Internet" means a global computer network through which the almost-instant delivery of data or files occurs between connected computers.

(e) "Minor" means a person under the age of 18 (or the age that a person is permitted to enter into a contractual relationship under applicable law at your jurisdiction).

(f) "Non-Personal Information" means information that does not identify you as an individual as more stipulated in Clause 3.7.

(g) "Parent" or "Legal Guardian" means the person who has the legal authority (and the corresponding duty) to care for the person and property interest of a User who is a Minor.

(h) "Person" includes an individual, association, partnership, corporation, other body corporate, trust, and any form of legal organization or entity.

(i) "Personal Information" means information about an identifiable individual, business, organization or other entity, but does not include the name, title, business address, or telephone number of an employee and/or associate, partners of a business, organization or other entity.

(j) "Privacy Policy" means this policy.

(k) "Service" means any of the services, functions, or features offered on the Sites or by the Service App provided by us for online collaboration and/or management including but not limited to point-of-sales systems, office automation systems and human resources management systems.

(l) "Service App" means the software product(s) owned or licensed by us available at Apple App Store or Google Play to which we grant you access as part of the Service, including program documentation, and any program updates provided as part of the Service. The term "Service App" does not include Separately Licensed Third Party Technology.

(m) "Separately Licensed Third Party Technology" means third party technology that is licensed under separate terms and not under the terms of the Agreement.

(n) "Sites" means the website(s) including but not limited to ( http://www.posify.me ) or any other website(s) and sub-links owned and operated by us.

(o) "Users" means those individuals, employees, contractors and end users, as applicable, authorized by you or on your behalf to use the Service in accordance with the Agreement.

1.2 The headings and sub-headings in this Privacy Policy are for ease of reference only and are not to be taken into account in the construction or interpretation of any provision or provisions to which they refer.

1.3 Unless otherwise specified in this Privacy Policy, words importing the singular include the plural and vice versa and words importing gender include all genders.

2. OVERVIEW

2.1 This Privacy Policy applies to all our Sites, Service App and Service provided by us ( http://www.posify.me ).

2.2 You expressly give consent to our use and disclosure of your Personal Information in accordance with this Privacy Policy and applicable laws once you have accepted this Privacy Policy and the Agreement upon registration.

2.3 This Privacy Policy is part of the Agreement and the contents of this Privacy Policy are subject to the terms and conditions in the Agreement.

2.4 This Privacy Policy sets out the Personal Information which we may collect and receive from you and what may happen to your Personal Information.

3 COLLECTION OF PERSONAL INFORMATION

3.1 You may be asked to provide your Personal Information (including any Personal Information of your client (if any)) at any time you are in contact with us or the Associates. We and the Associates may share your Personal Information with each other and use it in accordance with this Privacy Policy. We may also combine your Personal Information with other information to provide and to improve our products, Service, contents, and any other area related to our products, Service and contents. You are not required to provide the Personal Information that we have requested, but, if you choose not to do so, in many cases we may not be able to provide you with the Service or respond to any queries you may have.

3.2 In order to use the Service, you must establish an Account by providing us with a valid email address for registration and choose a username or alias at your own initiative or provided by us and approved by us that can represent you on the Service. We may also require additional information such as, including but not limited to, your address, your contact number and/or your billing address when necessary.

3.3 You may connect to or register the Account via external third party applications and/or webpages and we may receive your Personal Information from such applications and/or webpages. You may choose whether to connect the Account to such applications and/or webpages.

3.4 The types of information collected by us include Personal Information and Non-Personal Information.

3.5 We may also receive, collect and store any Personal Information including but not limited to personal and financial information you provide to us when you or your business:

(a) enquire of or make an application for Service;

(b) register to use and/or use any Service;

(c) upload and/or store information with us using the Service; or

(d) when you communicate with us through email, SMS, a website or portal, or the telephone or other electronic means.

3.6 Such personal and financial information may include but not limited to your or your client’s: -

(a) name (including first name and family name), date of birth, email address, billing address, username, password and/or photograph, address, nationality and country of residence;

(b) card primary account number, card expiry date, CVC details, bank and/or issuer details;

(c) IP addresses or similar identifiers; and

(d) information relating to any items purchased, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase.

3.7 We may also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose Non-Personal Information for any purpose, including but not limited to the following: -

(a) information such as occupation, language, area code, unique device identifier, URL, location, and the time zone where our product is used so that we can better understand your behavior and improve our products, Service, and advertising;

(b) information collected by cookies and other technologies;

(c) information regarding your activities on our Sites, and from our other products and Service. This information is aggregated and used to help us to provide more useful information to you and other customers of us and to understand which parts of the Sites, products, and Service are of most interest. Aggregated data is considered as Non‑Personal Information for the purposes of this Privacy Policy;

(d) details of how you use the Service, including search queries. This information may be used to improve the relevancy of results provided by the Service except in limited instances to ensure quality of the Service over the Internet, such information will not be associated with your IP address; and

(e) with your consent, we may collect data about how you use your device and the Service App in order to help us and our app developers improving and/or developing the Service App.

3.8 The Non-Personal Information will not be protected under this Privacy Policy. However, if we do combine Non-Personal Information with Personal Information (whether coincidentally or not), such combined information will be treated as Personal Information so long as it remains combined.

3.9 From time to time, we may offer you the opportunity to participate in promotions such as sweepstakes, contests, offers, and/or surveys ("Special Promotions") through the Service. A Special Promotion may be governed by a privacy policy and/or terms and conditions that are additional to, or separate from, this Privacy Policy and the Agreement. If the provisions of the Special Promotion’s privacy policy or terms and conditions conflict with this Privacy Policy or the Agreement, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including Personal Information. That additional information may be combined with other Account information and may be used and shared as described in this Privacy Policy.

4 PERSONS UNDER THE LEGAL AGE

4.1 Service will only be available to individuals who are:-

(a) aged 18 or older; or

(b) of legal age at their jurisdiction; or

(c) Minors with the supervision by their Legal Guardian or Parent,

provided that you or your Legal Guardian or Parent (if you are a Minor) have read and agreed to comply with the Agreement and this Privacy Policy.

5 YOUR PERSONAL INFORMATION

5.1 You are free to decide whether to provide, edit or remove your Personal Information disclosed in the Service. Except your username, you are free to amend your Personal Information which have been submitted to us and the profile information of the Account so long as those Personal Information are true and accurate. The action can be performed directly on your profile in the Sites or the Service App.

5.2 You may opt out of receiving direct marking materials from us by following the instructions provided in those direct marketing materials. Should you decide to opt out from receiving such materials, we may still send you non-promotional communications, such as those about the Account, previous purchases, our ongoing business relations or change in operation, etc.

5.3 In accordance with the statutory requirements, we will honor your request not to use your Personal Information for the purposes of direct marketing.

6 USE OF PERSONAL INFORMATION

6.1 We collect Personal Information that you and your employees, your affiliates or your contractors provide directly to us.

6.2 The ways of which we may use your Personal Information, once collected, may include but not limited to the followings: -

(a) to keep you posted on our latest product announcements, software updates, and upcoming events.

(b) to help us create, develop, operate, deliver, and improve our products, Service, contents and advertisements, and for loss prevention and anti-fraud purposes.

(c) to verify identity, assist with identification of Users, and to determine appropriate Service.

(d) to send important notices, such as communications about purchases and changes to our terms, conditions and policies.

(e) for our internal purposes, such as auditing, data analysis, and research to improve our products, Service, and customer communications.

(f) to administer any lottery, contest or similar promotional activities we and/or the Associates may hold from time to time.

6.3 We may allow others to provide analytics on our behalf via the Service which are aggregated or de-identified information with third parties, which cannot reasonably be used to identify you. These entities may use cookies, web beacons and other technologies to collect information about your use of the Service and other websites, including but not limited to your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, providing a better user experience and customer assistance in the Service, Site and Service App (i.e. knowing your first name to let us welcome you the next time you visit the Sites or automatically changing the language to your country/ computer’s default language), understand your online activity and facilitate and measure the effectiveness of advertisements and web searches.

6.4 We may review the Personal Information from time to time to identify problems and solve disputes, and to identify Users who use multiple user identifications or aliases. We may compare and review your Personal Information for errors, omissions and accuracy.

7 DISCLOSURE OF INFORMATION

7.1 At times we may make certain Personal Information available to strategic partners that work with us to provide products and services, or that help us market to customers. The Account will be governed by us and your carrier’s respective privacy policy(ies). Personal Information will only be shared by us to provide or improve our products, Service and advertising and will not be shared with third parties for their own marketing purposes.

7.2 We share Personal Information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and Service, and conducting customer research or satisfaction surveys. These companies are obligated to protect your Personal Information and may be located wherever we operate. You further agree that: -

(a) you shall read the full contents of the Privacy Policy of any such third-party;

(b) we have no control over the contents and operation of such third-party and their use to the Personal Information (although we shall use our reasonable endeavor to ensure they have appropriate personal data privacy mechanism in place); and

(c) you shall indemnify us, the Associates, contractors, suppliers or distributors against liability from any of your interaction with such third-party.

7.3 Unless prior written consent has been obtained from you or it is required by applicable laws or court orders, we will not sell, send, share or disclose your Personal Information to third parties.

7.4 It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for us to disclose your Personal Information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, such disclosure is necessary or appropriate.

7.5 We may also disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce the Agreement or protect our operations or our customers. Additionally, in the event of a reorganization, merger, amalgamation or sale, we may transfer any or all Personal Information that we collected to the relevant third party. Your continued usage of the Sites (where ownership of the Sites may no longer be owned by us) shall constitute as your consent to such transfer (if any).

8 SECURITY AND CONFIDENTIALITY

8.1 We provide limited access to your Personal Information to the Associates who we reasonably believe need to access the relevant Personal Information in order to maintain or provide the Service to you.

8.2 Whist we have physical, electronic and procedural safeguards that comply with our legal obligations to protect your Personal Information, we cannot guarantee that it is 100% secure and we cannot and will not guarantee the absolute security of your Personal Information. By your continued use of the Service, you hereby declare that you understand and accept the risk(s) as disclosed hereinabove.

9 PERSONAL INFORMATION RETENTION

9.1 We will retain your Personal Information as long as the Account is still in existence or we need to provide Service to you. If you do not want us to use your Personal Information, you may terminate the Account.

9.2 We also may terminate the Account in accordance with the Agreement and your Personal Information will also be deleted and/or archived in accordance with Clause 13 of the Agreement.

9.3 We will retain and use your Personal Information if necessary to comply with legal obligations, enforce the Agreement and / or resolve disputes.

10 CHANGE OF THIS PRIVACY POLICY

10.1 We may amend this Privacy Policy at any time by email (legal@posify.me), or via posting the amended Privacy Policy on the Sites ( http://www.posify.me/legal/privacy ). All amended Privacy Policy shall automatically be effective [15] days after the posting day of such amended Privacy Policy. Your continued use of the Service after the effective date of such amended terms and / or conditions constitutes your acceptance of the amended Privacy Policy.