Privacy Policy

By accepting this Privacy Policy, you agree and confirm that English is the official, legally binding language. If any conflicts or discrepancies arise between documentation, information, or communications in English and any other language, the English version will take precedence.

DA PLATFORM500 SOFTWARE DISTRIBUTION HK LIMITED (the “Company”, “we”, “us” or “our”) handles personal data collected through https://platform500.com/#. and its associated services in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”) and the applicable Data Protection Principles, as amended from time to time.

Collection of Personal Data

Depending on how you interact with us, we may collect:

• Your name, email address and other contact information you provide.
• Information contained in enquiries, applications, correspondence and feedback.
• Information necessary to provide and administer the services you request.
• Technical and usage information, such as your IP address, browser and device information, approximate location derived from your IP address, pages visited, session duration and interactions with the Service.

We collect personal data by lawful and fair means and limit collection to information that is adequate, relevant and not excessive for the purposes concerned.

Please ensure that the personal data you provide is accurate and up to date, and notify us of relevant changes.

Where providing information is voluntary, you may choose not to provide it. However, if information is necessary to respond to an enquiry, assess an application or provide a requested service, failure to provide it may prevent us from doing so.

If you provide another individual’s personal data, you must be authorised to disclose it to us, inform that individual of the relevant provisions of this Privacy Policy and obtain any consent required by applicable law.

We may also collect or generate anonymous or aggregated statistical information to understand use of the Service. Information will not be treated as anonymous if an individual remains identifiable from it.

Purposes of Collection and Use

We may use personal data for the following purposes, where relevant to your interaction with us:

• Responding to enquiries and communicating with you.
• Assessing applications and establishing, administering and managing client relationships.
• Providing, maintaining and supporting the Service.
• Analysing usage and improving the functionality and performance of the Service.
• Protecting the security of our systems and preventing or investigating fraud, misuse or unauthorised activity.
• Maintaining records, handling complaints, resolving disputes and establishing, exercising or defending legal claims.
• Complying with applicable legal and regulatory obligations and lawful requests from competent authorities.
• Conducting direct marketing in accordance with Section 5 below.

Personal data will be used only for the purpose for which it was collected or a directly related purpose. We will obtain the consent required under the PDPO before using it for a new purpose, unless otherwise permitted by law.

Cookies and Similar Technologies

Our website may use cookies and similar technologies to support functionality, remember preferences and analyse usage. Where information collected constitutes personal data, this Privacy Policy applies. Further details and available choices are set out in our Cookies Policy.

You may also manage cookies through your browser settings.

Direct Marketing

We will use your personal data for direct marketing only after informing you of the kinds of data to be used, the classes of products or services to be marketed and how to communicate your consent, and obtaining your consent in accordance with the PDPO.

Before providing your personal data to an affiliate or another third party for its direct marketing, we will provide the required information in writing, including the classes of recipients and whether the transfer is for gain, and obtain your written consent.

You may ask us to stop using or providing your personal data for direct marketing at any time, free of charge, through the unsubscribe facility or contact details below. We will comply with your request and notify relevant recipients where required by law. Website use or silence does not, by itself, constitute marketing consent.

Disclosure of Personal Data

We do not sell, rent or trade your personal data.

Where necessary for the purposes described in this Privacy Policy or an applicable Personal Information Collection Statement, we may disclose personal data to the following classes of recipients:

• Service providers: Providers supporting our operations, including website hosting, IT support, communications, analytics and, where relevant to the Service, payment processing.
• Affiliated companies: Group companies assisting with the provision, administration or support of the Service.
• Professional advisers: Legal advisers, auditors, accountants and other advisers where necessary for their professional services.
• Authorities and other legally authorised recipients: Courts, regulators, law enforcement agencies and other persons where disclosure is required or permitted by law.
• Business transaction parties: Potential or actual purchasers, successors and their advisers in connection with a merger, acquisition, restructuring or transfer of business, subject to appropriate confidentiality safeguards and applicable PDPO requirements.

Disclosures will be limited to information appropriate for the relevant purpose. Disclosure for a new purpose will require the consent prescribed by the PDPO unless an applicable exemption or other legal permission applies.

Where we engage a data processor, we will adopt contractual or other measures to prevent unauthorised or accidental access, processing, erasure, loss or use, and to prevent retention beyond the period necessary for the processing concerned.

Disclosure to an affiliate or service provider does not automatically authorise that recipient to use personal data for its own direct marketing.

Transfers Outside Hong Kong

Personal data may be stored or processed outside Hong Kong where our service providers or other authorised recipients operate.

Where such transfers occur, we will comply with applicable PDPO requirements and take appropriate steps, including contractual or other safeguards where necessary, to protect the data and ensure its use remains consistent with the purposes for which it was collected.

Data Retention

We will take all practicable steps to ensure that personal data is not retained longer than necessary to fulfil the purposes for which it is or is to be used.

Retention periods depend on the type of information, the services provided and applicable legal requirements. Relevant considerations include:

• The duration of your relationship with us.
• Whether information remains necessary to handle enquiries, complaints or outstanding matters.
• Applicable legal, regulatory, accounting and recordkeeping requirements.
• The establishment, exercise or defence of legal claims.

Once personal data is no longer required, we will take all practicable steps to erase it securely or irreversibly anonymise it, unless continued retention is required or permitted by law.

Security of Personal Data

We will take all practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use.

Our safeguards will be appropriate to the nature of the data and the potential harm arising from a security incident, and may include access restrictions, confidentiality obligations and technical and organisational controls.

Your Rights and Requests

Subject to the applicable provisions and exemptions under the PDPO, you may:

1. Request confirmation of whether we hold personal data about you.
2. Request access to a copy of your personal data.
3. Request correction of inaccurate personal data.
4. Request that we stop using or providing your personal data for direct marketing, free of charge.

You may also contact us to request deletion of personal data or cessation of a particular use.

We will assess such requests against the purposes for which the data remains necessary and our obligations under the PDPO and other applicable laws. These requests do not constitute an unrestricted right to erasure or cessation of processing.

Please submit access and correction requests in writing to the official email listed.

We may request information reasonably necessary to verify your identity and clarify the scope of your request.

We will handle requests within the time limits prescribed by the PDPO, generally within 40 days for data access and correction requests, subject to applicable exceptions. Where we cannot comply, we will provide the notification and reasons required by law.

We may charge a non-excessive fee for complying with a data access request, as permitted by the PDPO, and will inform you of any applicable fee.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or applicable legal requirements. The current version will be published on the website with its last updated date.

An update to this Privacy Policy does not, by itself, authorise a new use of personal data or replace any consent required by the PDPO.

Contact and Complaints

For privacy enquiries, complaints, data access or correction requests, or direct-marketing opt-out requests, please contact:

DA PLATFORM500 SOFTWARE DISTRIBUTION HK LIMITED

Email: [email protected]

If you believe that we have handled your personal data in breach of the PDPO, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

Information about the complaint procedure is available at https://www.pcpd.org.hk/.