This Privacy Policy sets out:
(a) what information we collect about you when you visit our
website, use our mobile applications (or app) or products or services, or
otherwise interact with us;
(b) how we use, share, store, and secure the information; and
(c) how you may access and control the information.
In this policy:
“Personal
information” refers to any data,
information, or combination of data and information that is provided by you to
us, or through your use of our products or services, that relates to an
identifiable individual;
“Platform” is as defined in our Terms of
Use; and
“Cyclops” or “we” is as defined in our Terms of Use.
1. What
information we collect about you
1.1 We collect the following types of information about you:
(a)
account
and profile information that you provide when you register for an account or
sign up for our products or services, for example your name, email address,
physical address and telephone number (collectively, “Account
Data”);
(b)
information
you provide through our support channels, for example when you report a problem
to us or interact with our support team, including any contact information,
documentation, or screenshots (collectively, “Support Data”);
(c)
content
you provide through use of our products or services, for example personal
information contained in the documents that you create in our app
(collectively, “User Content”);
(d)
communication,
marketing, and other preferences that you set when you set up your account or
profile, or when you participate in a survey or a questionnaire that we send
you (collectively, “Preference Data”);
(e)
details of
any transactions, purchases, or orders that you’ve made with us
(collectively, “Transaction Data”);
(f)
payment
information, for example your payment card information or bank account details
(collectively, “Financial Data”);
(g)
information
about your device or connection, for example your internet protocol (IP)
address, login data, browser type and version, time zone setting, browser
plug-in types and versions, operating system and platform, and other technology
on the devices you use to access our products or services and information we
collect through cookies and other data collection technologies (please read our
Cookies Policy for details) (collectively, “Technical Data”); and
(h)
information
about your use of or visit to our Platform, for example your clickstream to,
through, and from our Platform, products you viewed, used, or searched for,
download or other errors, page response times, length of visits to certain
pages, page interaction information (such as scrolling, clicks, and
mouse-overs), or methods to browse away from the page (collectively, “Usage
Data”).
1.2 We collect the above information when you provide it to us or
when you use or visit our Platform. We may also receive information about you
from other sources, including:
(a)
our
personnel, agents and consultants in connection with our operations or
services, for example our staff engaged in the fulfilment of your order, processing
of your payment, and provision of support services;
(b)
other
users of our products or services, for example when a member of your
organisation registers an account for each team member on our Platform;
(c)
other
services linked to your account, for example if you register or log in your
account using your Google credentials, we receive your name and email address
to authenticate you, as permitted by your Google profile settings;
(d)
our group
companies or overseas offices that provide information technology, system
administrative, and/or marketing services; and
(e)
our
business partners and service providers who provide technical, payment,
delivery services, advertising networks, analytics, market research, and search
information services.
1.3 We do not collect sensitive data or special category data
about you. This includes details about your race, ethnic origin, politics,
religion, trade union membership, genetics, biometrics, health, or sexual
orientation.
2. How
we use information we collect
2.1 We only use your personal information where the law allows us
to. We use your personal information only where:
(a)
we need to
perform the contract we have entered into (or are about to enter into) with
you, including to operate our products or services, to provide customer support
and personalised features, and to protect the safety and security of our
Platform;
(b)
it
satisfies a legitimate interest which is not overridden by your fundamental
rights or data protection interests, for example for research and development
to improve our products or services, and in order to protect our legal rights
and interests;
(c)
you’ve
given us consent to do so for a specific purpose, for example we may send you
direct marketing materials or publish your information as part of our testimonials
or customer stories to promote our products or services with your permission;
or
(d)
we need to
comply with a legal or regulatory obligation.
2.2 If you have given us consent to use your personal information
for a specific purpose, you have the right to withdraw your consent any time by
contacting us (please refer to paragraph 9 for contact information), but please
note this will not affect any use of your information that has already taken
place.
2.3 We do not share your personal information with any company
outside our group for marketing purpose, unless with your express specific
consent to do so.
2.4 For visitors to or users of our Platform who are located in
the European Union, we have set out our legal bases for processing your
information in the Legal Bases Table at the end of this policy.
3. How
we share information we collect
3.1 We share information with other companies in our group in
order to operate our Platform and to offer and improve our products and
services.
3.2 We share information with third parties that help us operate,
provide, support, improve, and market our products and services, for example
third-party service providers who provide cloud hosting, maintenance, backup,
storage, infrastructure, billing, payment processing, customer support,
business analytics, and other services.
3.3 Third-party service providers have access to your personal
information only for the purpose of performing their services and in compliance
with applicable laws and regulations. We require these third-party service
providers to maintain confidentiality and security of all personal information
that they process on our behalf and to implement and maintain reasonable
security measures to protect the confidentiality, integrity, and availability
of your personal information.
3.4 We take reasonable steps to confirm that all third-party
service providers that we engage process personal information in the manner
that provides at least the same level of protection as is provided under this
policy. Where any third-party provider is unable to satisfy our requirements,
we will require them to notify us immediately and we will take reasonable steps
to prevent or stop non-compliant processing.
3.5 If you use any third-party software in connection with our
products or services, for example any third-party software that our Platform
integrates with, you might give the third-party software provider access to
your account and information. Policies and procedures of third-party software
providers are not controlled by us, and this policy does not cover how your
information is collected or used by third-party software providers. We
encourage you to review the privacy policies of third-party software providers
before you use the third-party software.
3.6 Our Platform may contain links to third-party websites over
which we have no control. If you follow a link to any of these websites or
submit information to them, your information will be governed by their
policies. We encourage you to review the privacy policies of third-party
websites before you submit information to them.
3.7 We may share your information with government and law
enforcement officials to comply with applicable laws or regulations, for
example when we respond to claims, legal processes, law enforcement, or
national security requests.
3.8 If we are acquired by a third party as a result of a merger,
acquisition, or business transfer, your personal information may be disclosed
and/or transferred to a third party in connection with such transaction. We
will notify you if such transaction takes place and inform you of any choices
you may have regarding your information.
4. How
we store and secure information we collect
4.1 We use cloud service providers to host the information we
collect to enable us to operate as a global platform.
4.2 We have adopted the following measures to protect the security
and integrity of your personal information:
(a)
any
document that you create, store, and e-sign in our app is stored in encrypted
form on disk and securely transmitted with TLS/SSL encryption;
(b)
any
payment transactions are encrypted using TLS/SSL technology;
(c)
your
account is protected by passwords that must be at least 14 characters long;
(d)
access to
your personal information is restricted to personnel or service providers on a
strictly need-to-know basis, who will only process your information on our
instructions and who are subject to a duty of confidentiality; and
(e)
our
information collection, storage, and processing practices are reviewed
regularly.
4.3 We have put in place procedures to deal with any suspected
privacy breach and will notify you and any applicable regulator of a breach
where we are legally required to do so.
4.4 While we implement safeguards designed to protect your
information, please note that no transmission of information on the Internet is
completely secure. We cannot guarantee that your information, during
transmission through the Internet or while stored on our systems or processed
by us, is absolutely safe and secure.
4.5 We only retain personal information for so long as it is
reasonably necessary to fulfil the purposes we collected it for, including for
the purposes of satisfying any legal, accounting, or reporting requirements.
After such time, we will delete or anonymise your information, or if this is
not possible, we will securely store your information and isolate it from
further use. We periodically review the basis and appropriateness of our data
retention policy.
5. How
we transfer information internationally
5.1 We collect information globally. We transfer, process, and
store your information outside your country or place of residence where we or
our service providers operate for the purpose of providing our products and
services to you. We store information in AWS Hong Kong .
5.2 Some of the countries in which our companies or service
providers are located may not have the privacy and data protection laws that
are equivalent to those in your country or place of residence. When we share
information with these companies or service providers, we make use of
contractual clauses, corporate rules, and other appropriate mechanisms to
safeguard the transfer of information.
6. Your
rights
6.1 You have the right to:
(a)
be
informed of what we do with your personal information;
(b)
request a
copy of personal information we hold about you;
(c)
require us
to correct any inaccuracy or error in any personal information we hold about
you;
(d)
request
erasure of your personal information (note, however, that we may not always be
able to comply with your request of erasure if the personal information is
still necessary for the purpose which we originally collected it for, or for
record keeping or legal compliance purposes);
(e)
object to
or restrict the processing by us of your personal information (including for
marketing purposes);
(f)
request to
receive some of your personal information in a structured, commonly used, and
machine readable format, and request that we transfer such information to
another party; and
(g)
withdraw
your consent at any time where we are relying on consent to process your
personal information (although this will not affect the lawfulness of any
processing carried out before you withdraw your consent).
6.2 Our Platform enables you to update certain information about
yourself, for example you may change your business or personal information by
updating your account settings in our app.
6.3 You may opt out of receiving marketing materials from us by
using the unsubscribe link in our communications or by contacting us (please
refer to paragraph 9 for contact information). Please note, however, that even
if you opt out from receiving marketing materials from us, you will continue to
receive notifications or information from us that are necessary for the use of
our products or services.
6.4 As a security measure, we may need specific information from
you to help us confirm your identity when processing your privacy requests or
when you exercise your rights.
6.5 Any request under paragraph 6.1 will normally be addressed
free of charge. However, we may charge a reasonable administration fee if your
request is clearly unfounded, repetitive, or excessive.
6.6 We will respond to all legitimate requests within one (1)
month. Occasionally, it may take us longer than one (1) month if your request
is particularly complex or if you have made a number of requests.
7. Changes to this policy
7.1 We
may amend this policy from time to time by posting the updated policy on our
Platform. By continuing to use our Platform after the changes come into effect,
you agree to be bound by the revised policy.
8. Policy towards children
8.1 Our
products and services are not directed to individuals under 16. We do not
knowingly collect personal information from individuals under 16. If we become
aware that an individual under 16 has provided us with personal information, we
will take steps to delete such information. Contact us if you believe that we
have mistakenly or unintentionally collected information from an individual
under 16.
9. Contact
us
9.1 Please contact us at [email protected] or submit any written request
to:
Cyclops AR Limited,
19/F, No. 3 Lockhart Road,
Wanchai, Hong Kong
Tel: +852 2873 0625
Attn: Privacy Manager
9.2 Please contact us in the first instance if you have any
questions or concerns. If you have unresolved concerns, you have the right to
file a complaint with a data protection authority in the country or place of
residence where you live or work or where you feel your rights have been
infringed.
10. Cookies
Policy
10.1 Cookies are small text files that are placed on your device by a
web server when you access our Platform. We use cookies to identify your access
and monitor usage and web traffic on our Platform to customise and improve our
products and services.
10.2 We use both persistent cookies and session cookies. A persistent
cookie stays in your browser and will be read by us when you return to our Site
or a partner site that uses our services. Session cookies only last for as long
as the session lasts (usually the current visit to a website or a browser
session).
10.3 We use the following types of cookies:
(a) Strictly necessary cookies – these are cookies that are
required for the operation of our site. They include, for example, cookies that
enable you to log into secure areas of our website.
(b) Analytical/performance cookies – these allow us to recognise
and count the number of visitors and to see how visitors move around our Site
when they are using it. This helps us to improve the way our site works, for
example, by ensuring that users are easily finding what they are looking for.
(c) Functionality cookies – these are used to recognise you when
you return to our site.
(d) Targeting cookies – these cookies record your visit to our
site, the pages you have visited, and the links you have followed.
10.4 You can block cookies by
activating the setting on your browser that allows you to refuse the use of all
or some cookies. However, if you do so, you may not be able to access all or
parts of our site.
11. Legal Bases Table
Processing purpose |
Type of data processed |
Legal basis |
To register you as a user on our
app |
Account Data |
To perform our contract with you |
To enable you to use our products
and services |
Account Data, Transaction Data,
Support Data, Technical Data and User Content |
To perform our contract with you |
To process your payments |
Account Data, Transaction Data,
Financial Data |
To perform our contract with you |
To collect overdue amounts |
Account Data, Transaction Data,
Financial Data |
Legitimate interest to recover
debts due to us |
To notify you about changes to our
products, services, or terms |
Account Data |
To perform our contract with you |
To administer and maintain safety
and security of our Platform |
Technical Data |
To perform our contract with you |
To study usage of our products or
services |
Transaction Data, Support Data,
Technical Data, Usage Data |
Legitimate interest to improve our
Platform, products, and services |
To gather feedback on our products,
services, or features |
Account Data |
Legitimate interest to improve our
Platform, products, and services |
To provide information on products
or services that may be of interest to you |
Account Data, Preference Data |
Consent, which you may withdraw any
time |