Posted on 07/11/2018


This policy sets out the basis on which Nowsnapp of Unit 1, 9/F,
Sing Ho Finance Building, 168 Gloucester Road, Wan Chai, Hong Kong (Company
Number 67853339) (together with our subsidiaries, our holding company,
subsidiaries of our holding company from time to time, collectively called
“Nowsnapp Limited” or “we”) collects personal data from you and how we
process such data. 

By visiting our
website (our “Site”) or
using Nowsnapp or any other applications or software we provide from
time to time (collectively our “App”), you accept and consent to the
practices set out below. 

Collection of information

For the purposes outlined in Clause 2, we may
collect and process the following information about you:

Information you give us – information that you provide us (which may include your name,
address, email address, telephone number, credit card information and other
personal description) by filling in forms on our Site or our App, or by
corresponding with us (by phone, email or otherwise), for example:

when you register for an account with us in our

when you report any problem to us;

when you use certain features on our Site or our

when you request any support from us; or

when you complete any survey or questionnaire we
send you.

Information we collect about you – information automatically collected when you visit our Site or
use our App, for example:

technical information, including the Internet
protocol (IP) address used to connect your computer to the Internet and your
log-in information, browser type and version, time zone setting, browser
plug-in types and versions, operating system and platform;

information about your visit, including the full
Uniform Resource Locators (URLs), clickstream to, through and from our site
(including date and time), products you viewed or searched for, page response
times, download errors, length of visits to certain pages, page interaction
information (such as scrolling, clicks, and mouse-overs), methods used to
browse away from the page, and any phone number used to call our customer
service number.

We only retain personal data for so long as it
is necessary. Data may be archived as long as the purpose for which the data
was used still exists.

Uses made of the information 

We use information held about you for the
following purposes:

providing, improving and developing our

researching, designing and launching new
features or products;

presenting content and information in our Site
and our App in the most effective manner for you and for the device you use;

providing you with alerts, updates, materials or
information about our services or other types of information that you requested
or signed up to;

collecting overdue amounts;

responding or taking part in legal proceedings,
including seeking professional advice;

for direct marketing purposes (please see
further details in Clause 2.2 below);

communicating with you and responding to your
questions or requests; and

purposes directly related or incidental to the

We intend to use your personal data in direct
marketing (i.e. offering or advertising products or services by sending the
relevant information directly to you). We require your consent specifically for
this purpose and you may opt out any time. For the purpose of this

the personal data that may be used in direct
marketing are those that you provide to us or we collect from you under Clause
1.1 above;

the type of services or products that may be
offered or advertised will be our marketplace platform, and services
requested through the platform by our users;

the relevant information may be sent to you
by email and in-app message;

you may opt out any time by emailing us at We will cease to send you marketing information without

Disclosure of your information 

We will keep your personal data we hold confidential but you agree
we may provide information to:

any member of our group, which means our
subsidiaries, our ultimate holding company and its subsidiaries, as defined in
Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the Law of
Hong Kong;

personnel, agents, advisers, auditors,
contractors, financial institutions, and service providers in connection with
our operations or services (for example staff engaged in the fulfilment of your
order, the processing of your payment and the provision of support services);

our overseas offices, affiliates, business
partners and counterparts (on a need-to-know basis only);

persons under a duty of confidentiality to us;

persons to whom we are required to make
disclosure under applicable laws and regulations in any part of the world; or

actual or proposed transferees of our operations
(or a substantial part thereof) in any part of the world.


Our Site uses cookies to distinguish you from
other users of the Site. This helps us to provide you with a good experience
when you browse our Site and also allows us to improve our Site.

A cookie is a small file of letters and numbers
that we store on your browser or the hard drive of your computer if you agree
to the use of cookies. Cookies contain information that is transferred to your
computer’s hard drive.

We use 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 (usually the current visit to a website or a browser

We use the following cookies: 

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, use a shopping
cart or make use of e-billing services.

Analytical/performance cookies – They 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 finding what they are
looking for easily. 

Functionality cookies – These are used to
recognise you when you return to our Site. This enables us to personalise our
content for you, greet you by name and remember your preferences (for example,
your choice of language or region).

You can block cookies by activating the setting
on your browser that allows you to refuse the setting of all or some cookies.
However, if you do so, you may not be able to access all or parts of our Site.

We may use third-party web services on our Site.
The service providers that administer these services use technologies such as
cookies (which are likely to be analytical/performance cookies or targeting
cookies), web server logs and web beacons to help us analyse how visitors use
our Site and make the information displayed on it more relevant to your
interests. The information collected through these means (including IP
addresses) is disclosed to these service providers. These analytics services
may use the data collected to contextualise and personalise the marketing
materials of their own advertising network.

Third-party sites

Our Site, our App or our communication with you may from time to
time contain links to third-party websites over which we have no control. If
you follow a link to any of these websites, please note that they have their
own practices and policies. We encourage you to read the privacy policies or
statements of these websites understand your rights. We accept no
responsibility or liability for any practices of third-party websites.


All information you provide to us is stored on
our secure servers.

Any payment transactions will be encrypted using
TLS/SSL technology.

Where we have given you (or where you have
chosen) a password that enables you to access certain parts of the Site, you
are responsible for keeping this password confidential. We ask you not to share
a password with anyone.

We restrict access to personal information to
our employees, service providers and contractors on a strictly need-to-know
basis and ensure that those persons are subject to contractual confidentiality

We review our information collection, storage
and processing practices from time to time to guard against unauthorised
access, processing or use.

Please note, however, the transmission of
information via the Internet is not completely secure. Although we will do our
best to protect your personal data, we cannot guarantee the security of your
data transmitted to our Site; any transmission is at your own risk. 

Data transfer

The data that we collect from you may be
transferred to, and stored at, a destination outside Hong Kong. It may also be
processed by persons referred to in Clause 3 above who operate outside Hong

By submitting your personal data you agree to
this transfer, storing or processing of data outside Hong Kong. We will take
all steps reasonably necessary to ensure that your data is treated securely in
accordance with this privacy policy.

Your rights

You have the right to:

check whether we hold personal data about you;

access any personal data we hold about you; and

require us to correct any inaccuracy or error in
any personal data we hold about you.

Any request under Clause 8.1 may be
subject to a small administrative fee to meet our cost in processing your

Changes to our privacy policy

We may amend this policy from time to time by posting the updated
policy on our Site. By continuing to use our Site and our App after the changes
come into effect means that you agree to be bound by the revised policy.

Contact us

If you have any questions, comments or requests regarding personal
data, please address them to:

Customer Happiness
+852 5997 8511

updated: 20 Jun 2018