This Statement explains how N2N-AFE (Hong Kong) Limited (“N2N-AFE”, “we”, “us” or “our”) collect, handle, store and protect personal information about you in the context of our services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information. This Statement applies to individuals who use any website, application, including mobile application (“app”), product, software or service of ours that hyperlinks to this Statement (we call these our “Services”). If you decided to download and use our services then the terms and conditions contained within this statement (to the extent applicable) apply to you and by using our Services you agree to abide by the terms and conditions herein contained. Depending on the Service, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which statements apply to which interactions and Services. For example, if you use one of our mobile apps, we provide you a separate notice in relation to a particular data type collected through that app. Please note that this Statement may be amended from time to time without prior notice. You are advised to check for the latest version on a regular basis. If there is any inconsistency or conflict between the English and Chinese versions of this Statement, the English version shall prevail. Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them. We are committed to safeguard the privacy of individuals with respect to your personal data. We assure that our policies and practices, and those adopted by our affiliated companies and agents in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486) (the “Ordinance”) under the laws of Hong Kong, as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of the term “personal data” adopted in this Statement is defined in the Ordinance. Sources of personal information N2N-AFE collect personal information about you from your interactions with us and from certain third parties and other sources. •through your interactions with us and our Services, such as, when you purchase or use our Services, register for an event, request information or call us for support •through your system/device and use of our Services. Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect and improve our Services, analyze usage and improve users’ experience •through cookies and similar technologies included on our Services. •the person(s) arranging for you to access our Services in order to set up a user account •an organization to which you belong where that organization provides you access to our Services •partners and service providers who work with us in relation to your Service •publicly available sources such as public websites, open government databases or other data in the public domain, to help us maintain data accuracy and provide and enhance the Services Types of personal information The type of personal information we collect depends on how you are interacting with us and which Services you are purchasing or using. In many cases, you can choose whether or not to provide us with personal information, but if you choose not to, you may not get full functionality from the Services. The personal information we collect consists of the following: •Name and contact data, such as, first and last name, email address, postal address, phone number, and other similar contact data •Account Credentials, such as, passwords and other security information for authentication and access •User content, such as, communications and files provided by you in relation to your use of the Services •Payment information, such as, payment card number, and the security code associated with your payment instrument, if you make a payment •Device information, such as, information about your device, such as IP address, location or provider •Usage information and browsing history, such as, information about how you navigate within our Services, your browsing history and which elements of our Services you use the most •Location data, for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately •Demographic information, such as, your country, and preferred language Use of personal information This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide and improve Services and for other purposes that are in our legitimate interests, as well as for compliance purposes. We process personal information about you on the basis that it is: •necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfill that contract (i.e., to provide you with Services) •in our or a third parties’ legitimate interests: details of those legitimate interests are set out in more detail below (e.g., provision of Services that we are contractually obliged by a third party, such as your employer or our subscriber, to deliver to you) •where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent •for compliance with a legal obligation (e.g., to respond to a court order or a regulator) Legitimate interests for use N2N-AFE use personal information for a number of legitimate interests, including to provide and improve Services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below. •to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription and Service information •to administer our relationship with you, our business and our third-party providers •to deliver and suggest tailored content such as news, research, reports and business information. We analyze the way you use our Services to make suggestions to you for features or Services that we believe you will also be interested in, and so that we can make our Services more user-friendly •to personalize your experience with our Services. We may retain your browsing and usage information to make your searches within our Services more relevant and use those insights to target advertising to you online on our websites and apps. Your choices in relation to marketing are explained here. We may sometimes share your personal information across our Services so that we can make all of the Services we deliver to you more intuitive •to contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes •to display information you choose to post, share, upload or make available in chat rooms, messaging services, and community and event forums and for related collaboration, peer connection, games and information exchange •to provide any third party, who has made our Services available to you, insights about use of the Services •for internal research and development purposes and to improve, test and enhance the features and functions of our Services •to provide you with marketing as permitted by law •to meet our internal and external audit requirements, including our information security obligations •to enforce our terms and conditions •to protect our rights, privacy, safety, networks, systems and property, or those of other persons •for the prevention, detection or investigation of a crime or other breach of law or requirement, loss prevention or fraud •to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence •in order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work •in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Marketing Subject to obtaining your expressed consent, we may also use your information, such as your name, member ID, gender, identification/passport number, date of birth, location, occupation, title, education level, monthly salary, interest information and choices about the products and/or services you have purchased, to provide you with marketing materials relating to our products and/or services (including financial information, news and education) as well as products and/or services offered by our business partners engaged in the profession of telecommunications, jewellery & watches, device accessories, mobile applications and software, lifestyle networking events, hotels, travelling, banking, wine and tobacco, sports, music, entertainment, gaming, transportation, household, food & beverages, commerce, finance, insurance, betting, education, health and wellness, beauty products, fashion & accessories , electronics, social networking, technology, e-commerce, mobile payment, cloud services, retail, home and décor, media, logistics, auction, real estate, catering, charity, vehicles, governmental services or high-end consumer products. Share of personal information N2N-AFE share personal information within the N2N-AFE group, with our business partners and third party service providers, the person providing for your access to our Services and in accordance with law. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us. We share your information for the purposes set out in this Statement, with the following categories of recipients: •N2N-AFE group companies •the person providing your access to our Services •business partners with whom we deliver co-branded Services, provide content, or to host events, conferences and seminars •third parties that help us deliver Services or act on our behalf •third parties where we have a duty to or are permitted to disclose your personal information by law •third parties in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, in which case we may disclose your personal data to prospective buyers, sellers, advisers or partners and your data may be a transferred asset in a business sale •third parties where reasonably required to protect our rights, users, systems and Services •any person you have asked us to share information with Security of personal information N2N-AFE takes the security of personal information seriously and we use appropriate technologies and procedures to protect personal information (including administrative, technical and physical safeguards) according to the risk level and the service provided. How long we keep personal information N2N-AFE calculate retention periods for your personal information in accordance with the following criteria: •the length of time necessary to fulfill the purposes we collected it for •the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations •any limitation periods within which claims might be made •any retention periods prescribed by law or recommended by regulators, professional bodies or associations •the existence of any relevant proceedings •for data acquire for troubleshooting, testing, inspection, analysis, sensitive information will only be reside under tightly controlled environments and will destroy/delete/shredded after usage. If data needs further analysis, all sensitive data will be scrubbed or masked when it is moved out of the protected environment. Guidelines and Recommendation N2N-AFE follows guidelines and recommendation from authorized parties SFC Keeping of Records Rules https://www.sfc.hk/web/EN/faqs/intermediaries/supervision/keeping-of-records-rules/2003-03-17.html HKMA Customer Data Protection Guidelines & Circular https://www.hkma.gov.hk/eng/key-information/guidelines-and circulars/circulars/2008/20080710-1.shtml If you do not wish to receive more latest updates and promotional materials from N2N-AFE (Hong Kong) Limited, please send a written un-subscription request to us at contact@afe-solutions.com.