POCKETECH LIMITED

POCKETECH Privacy Policy

1. Data controller and representative

POCKETECH LIMITED and its related organizations (collectively, “POCKETECH”, “us,” or “we”) implement the processing of personal data specified below through our Websites (the “Websites”) and desktop apps and mobile applications (the “Applications” or “Products”). POCKETECH is committed to protecting your personal information. We recognize how important the security of your personal information is to you. To secure your personal information, we use adequate administrative, technological, and physical security procedures.

 

POCKETECH LIMITED, 6/F MANULIFE PLACE 348 KWUN TONG ROAD KL, HK is the data controller. Privacy-related inquiries may be forwarded to [email protected].

 

Please read the following privacy policy carefully as it offers you, as the User of the Websites and/or Applications (the “User” or “You”), with important information about the different personal data processing practices performed by POCKETECH LIMITED.

2. Data processing implemented by POCKETECH LIMITED

“Personal Data” refers to any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to that natural person’s physical, physiological, genetic, mental, economic, cultural, or social identity. We process different types of data and in different ways depending on how you interact with us.

 

2.1 Personal data processing relating to your visit to our website, as well as the purchase and usage of our products

 

When a User accesses our Websites, purchases a POCKETECH LIMITED product via the Websites or the Application, or uses our goods, POCKETECH LIMITED processes personal data in the following ways:

 

2.1.1 We collect data when you visit our websites.

 

– information about how you access our Websites (including the URL that directed you to a POCKETECH Websites and the search phrases typed into a search engine that directed you to a POCKETECH Websites);
– Your actions and visits to our websites;
– The date and time of the visit, as well as the length of time spent on the Websites.

 

2.1.2 We only gather data if you provide it to us.

 

– Name;
– Gender;
– Age;
– Image;
– Email address;
– Address;
– Country;
– Postal code;
– Phone number;
– Payment information such as Credit card information/debit card information or other payment/billing information;
– Your account data;
– Content of customer support communications.

 

2.1.3 We collect data when you use our products.

 

We have several goods, and each product may gather different types of data. In general, if you use our products, we may gather the data listed below.

 

– the serial number of your product;
– We gather information about the products you use and how you use them, such as launch data, feature use, page hits, and sign-in information.
– Your local device information, including but not limited to device information, device hardware, operating system, other software on your system, Username, POCKETECH ID, location, IP address, operational log information, file size and type;
– Crash data as well as information about the files you’re working with. If the User experiences a crash, we will ask if the User accepts to submit the original document to POCKETECH. POCKETECH can only have access to the original document if the User decides to give it to POCKETECH.

 

2.1.4 Purpose and legal basis of the processing

 

POCKETECH collects information about you for the following purposes. Our processing of the acquired personal data is based on the User’s permission or other legal reasons (such as for the performance of statutory duties or statutory obligations, or for the conclusion or performance of a contract with the User, etc.).

 

For POCKETECH to deliver the requested stuff to the User;
The gathered data are required for POCKETECH to identify and bill the User and charge its bank card number in order to complete a contract to which the User is a party.
In order to provide customer service or assistance;

 

For the purposes of identity verification and anti-piracy;
Internal statistics and analytical needs. Analyze your usage of our Websites and products in order to better understand how they are being used so that we may enhance our services and the User experience, as well as engage and retain Users.


For the purpose of chargeback management;
In order to offer you advertisements for POCKETECH items and services that we believe may be of interest to you.

 

2.1.5 Recipients of the personal data

 

We treat your personal information with care and confidentiality, and will only share it with third parties to the extent specified below. We do not disclose, sell, rent, or exchange personal information with other parties for marketing reasons.

 

– Service Providers: We may share your personal information with organizations who assist us in running our business by processing personal information on our behalf for the aforementioned objectives. Such companies include payment processing companies that can assist us in processing transactions, parties that provide our third-party cookies and tracking tools that may send tracking data or analysis reports to POCKETECH, email delivery service providers that can assist us in delivering promotion emails to you, server companies that we hire to provide service to you, charge back management service providers, fraud monitoring and prevention providers, social medias, and third-party online retailers.

 

Furthermore, POCKETECH may reveal the following personal information about the User:

 

– Public Authorities: if POCKETECH is required to disclose or reveal such personal data to comply with a legal requirement, or to defend the rights, property, or safety of its company, customers, or others; and

 

– Business Transactions: to legal successors or substitute operators of all or a portion of POCKETECH’s various companies.

 

2.1.6 Transfer of personal data

 

POCKETECH may send acquired personal data to recipients situated outside the EU, and such destinations may not have regulations that protect the User’s personal data to the same degree as the EU.

 

POCKETECH assures that the User’s personal data is treated securely and secured against unauthorized access, loss or deletion, illegal processing, and any processing that is inconsistent with the goals set out in this privacy policy.

 

Please find the following transfer details below:

 

– To conduct transactions, POCKETECH may send your payment information to payment processing businesses outside the EU.

 

– POCKETECH may use third-party cookies and tracking technologies (such as AdWords and Google Analytics) to measure how Users use the Websites and products; such Websites use data and product usage data may be transmitted to and stored in third-party servers located outside the EU. These third-party cookies and tracking tools may provide tracking data or analytical reports to POCKETECH for the purposes stated above. The majority of third-party cookies and tracking programs process your personal information anonymously.

 

– POCKETECH may transmit your email address and other relevant information, such as your name, to email delivery service providers located outside the EU in order to send you promotional emails.

 

– POCKETECH may keep personal information on servers leased from server service providers.

 

– To perform relevant services, POCKETECH may send your relevant personal information to marketing platforms and service partners outside the EU.

 

– In order to perform the relevant service, POCKETECH may send your relevant personal information to fraud monitoring and prevention suppliers located outside of the EU.

 

2.1.7 Duration of the storage

 

POCKETECH will keep the gathered personal data for as long as required to fulfill our contractual or legal obligations and as authorized by relevant law. We shall destroy the personal data after this time period in accordance with relevant regulations. To establish the existence of a right, contract, or legal duty, POCKETECH shall save relevant personal data through intermediate archives for a period of time that does not exceed what is technically necessary for the purpose of the storage and in line with applicable legislation.

 

In terms of banking information, it will be removed once the payment has been completed and becomes effective. The withdrawal time period may also apply. The credit card number and expiration date (but not the CVV security code) might be held through intermediate archives for evidentiary purposes in the event of a payment dispute, for the length specified by relevant legislation.

 

2.2 Personal data processing in relation to comment areas

 

When a User decides to remark on a POCKETECH product via the Websites or Applications, POCKETECH conducts the following personal data processing:

 

2.2.1 We only gather personal data if you provide it to us.

 

POCKETECH collects the following personal data in connection with this processing:

– Your email address;
– Your name or a nickname;
– Any other potentially personal information submitted by the User through its remark (age, location, etc.);
– The substance of your comment.

 

2.2.2 Processing purpose and legal basis

 

POCKETECH implements this processing in order to improve its products and provide consumers and potential consumers with better and more transparent information about POCKETECH products. Said remarks and associated personal data are submitted voluntarily by the User, and the processing of the acquired personal data is based on the User’s permission.

 

POCKETECH may utilize your comments (together with your relevant information) for marketing reasons in order for people to better understand and use our products.

 

2.2.3 Recipients of the personal data

 

We treat your personal information with care and confidentiality, and will only share it with third parties to the extent specified below. We never disclose, sell, rent, or exchange personal information with third parties for marketing reasons.

 

– Service Providers: We may share your personal information with organizations who assist us in running our business by processing personal information on our behalf for the aforementioned objectives. Email delivery service providers, which can assist us in delivering promotional emails to you, server businesses we engage to offer service to you, social media, third-party online forums, and other marketing platforms and service providers are examples of such organizations.

 

2.2.4 Transfer of personal data

 

POCKETECH transfers gathered personal data to recipients situated outside the EU, and such destinations may not have regulations that protect the User’s personal data to the same level as the EU.

 

POCKETECH assures that the User’s personal data is treated securely and secured against unauthorized access, loss or deletion, illegal processing, and any processing that is inconsistent with the goals set out in this privacy policy.

 

Please find the following transfer details below:

 

– POCKETECH may transmit your email address and other relevant information, such as your name, to third-party email delivery service providers located outside the EU in order to send you promotional emails.


– POCKETECH has the right to store your comments on servers leased from server service providers.


– POCKETECH may also send personal data linked to your comments to social media platforms, third-party online forums, other marketing platforms, and service providers located outside the EU in order to deliver appropriate services.

 

2.2.5 Duration of the storage

 

POCKETECH will keep the gathered personal data for as long as required to fulfill our contractual or legal obligations and as authorized by relevant law. We shall destroy the personal data after this time period in accordance with relevant regulations.

 

2.3 Personal data processing in relation to advertising emails

 

The User may choose to sign up for POCKETECH’s advertising e-mail in order to get information and news about POCKETECH news and goods. In this instance, POCKETECH undertakes the following personal data processing:

 

2.3.1 Personal information gathered

 

POCKETECH only gathers your supplied information in this processing, such as the User’s email address, name or nickname, country, desired product, and response to promotional mailings.

 

2.3.2 Processing purpose and legal basis

 

POCKETECH uses personal data processing to give consumers and potential customers information and news about POCKETECH goods.
The subscription to POCKETECH’s advertising e-mail and the corresponding submission of personal data is optional, and the processing of the obtained personal data is dependent on the User’s consent.

 

2.3.3 Recipients of the personal data

 

We treat your personal information with care and confidentiality, and will only share it with third parties to the extent specified below. We never disclose, sell, rent, or exchange personal information with third parties for marketing reasons.

 

– Service Providers: We may share your personal information with companies that help us to run our business by processing personal information on our behalf of us for the purposes identified above. Such companies include email delivery service providers which can help us deliver promotional emails to you, server companies we hire to provide service to you, and the parties providing our third-party cookies and tracking tools.

 

2.3.4 Transfer of personal data

 

POCKETECH transfers gathered personal data to recipients situated outside the European Union, and such destinations may not have regulations that safeguard the User’s personal data to the same level as the European Union.

 

POCKETECH assures that the User’s personal data is treated securely and secured against unauthorized access, loss or deletion, illegal processing, and any processing that is inconsistent with the goals set out in this privacy policy.

 

Please find the following transfer details below:

 

– POCKETECH may transmit your email address and other relevant information, such as your name, to email delivery service providers located outside the EU in order to send you promotional emails.


– POCKETECH may keep personal information on servers leased from server service providers.


– POCKETECH may use third-party cookies and tracking technologies (such as Google Analytics) to track information on the User’s response to advertising emails; such data will be transmitted to and kept on third-party servers located outside the EU.

 

2.3.5 Duration of the storage

 

POCKETECH will keep the gathered personal data for as long as required to fulfill our contractual or legal obligations and as authorized by relevant law. We shall destroy the personal data after this time period in accordance with relevant regulations.

 

2.4 Cookies and tracking tools

 

To collect information about your usage of our Websites and Applications, POCKETECH employs a number of industry-standard information-tracking mechanisms. POCKETECH places cookies on the User’s device when they visit the Websites and/or use the Applications. The third-party tracking tools are mentioned below, but this does not imply that each of our Websites or Products employs all of them.

 

 

No.Name and link of third-party tracking toolsData collected by tracking toolsPurpose of data collectionUsed on Website or product
1Adwords
https://policies.google.com/ )
Website usage datatargeting and advertising purposeWebsite
     
2Google Analytics
https://policies.google.cn/privacy )

AppsFlyer SDK
(https://www.appsflyer.com/legal/privacy-policy/)
Website usage data
product usage data
local device data
better understand how the Website and product work, and make improvementsWebsite
product
     

For additional information on cookies and tracking tools, please read POCKETECH’s cookies policy.

 

3. User’s Rights

You may have the following rights, depending on the legislation of your jurisdiction. If the laws of your jurisdiction provide you the following rights, you should get legal advice before using them. According to GDPR, EU residents have the following rights.

RightsContent
The right to be informedThe User has the right to receive clear, transparent, and easily comprehensible information about how POCKETECH collects and uses personal data, as well as information about its rights. This is why POCKETECH is providing the information in this privacy policy to the User.
The right of accessThe User has the right to view its personal data (if POCKETECH is processing it) as well as other specific information (similar to that provided in this privacy policy).
The right to rectificationIf the User’s personal data is erroneous or incomplete, the User has the right to have it remedied.
The right to erasureThis ‘right to be forgotten’ allows the User to seek the erasure or removal of personal data when POCKETECH has no compelling reason to continue using it. There are exceptions to this fundamental right to erasure.
The right to data portabilityThe User has the right to obtain the personal data given to POCKETECH in a structured, generally used, and machine-readable format, and to transmit such data to another controller.

The right to restrict processing

Under specific conditions, the User may ‘block’ or restrict future usage of its personal data.
The right to lodge a complaintThe User has the right to file a complaint with its national supervisory body regarding how POCKETECH manages or processes its personal data (in France, the CNIL).

The right to object to processing

The User has the right to object to the processing of its personal data at any time for reasons related to its specific circumstances.
The right to withdraw consentIf the user has provided its approval to POCKETECH for a specific processing of its personal data, the user has the right to withdraw such consent at any time. If the User does so, whatever POCKETECH has done with the User’s personal data with its consent up to that time is illegal).
The right to define instructionsThe User has the right to specify general or particular directions for the storage, destruction, and use of his or her personal data after death.

However, in order to register with POCKETECH, create an account, and use some POCKETECH Websites, products, or services, you must provide some information, such as your email address: if this information is not provided, we will be unable to administer your POCKETECH account or provide you with the Websites, products, or services you have requested. All other information you provide is optional. Providing optional information will allow us to provide you with a more personalized or tailored experience, such as more personalized or tailored content or products.

4. Information Gathering from Children

POCKETECH’s websites and products are not intended for use by minors under the age of 16, and no information is purposely collected from users under the age of 16. Please do not use any websites or goods if you do not fulfill the appropriate age limits. If a parent or guardian becomes aware that their child has entrusted POCKETECH with Personal Data, or that we have somehow accidentally obtained this information, please contact us at [email protected] so that the information can be removed from our systems.

5. Revision of this Privacy Statement

We may amend this privacy policy (or other privacy-related policies) from time to time to allow POCKETECH to use or disclose your personal data in a different way. If we do, the links to the policy on our Websites (which are usually placed in the footer) will reflect that the policy has changed. The update will become applicable for new Users upon publishing. If the change is significant, it will become effective 30 days after publishing for existing Users. We urge you to examine the privacy policy on a regular basis for the most up-to-date information on our privacy policies.

 

6. POCKETECH Contact

If the User needs to contact POCKETECH for any reason (including to exercise any of the above-mentioned data protection rights), please email [email protected].
POCKETECH will act on the User’s requests and provide information free of charge, unless the requests are manifestly unfounded or excessive (particularly due to their repetitive nature), in which case POCKETECH may charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the requested action), or refuse to act on the request.

7. YouTube Privacy Policy

When using the YouTube upload feature, Google’s privacy policy applies to media uploaded to YouTube. You can view the Google privacy policy here: https://policies.google.com/privacy?hl=en-US