Nibanme and its parent company, its subsidiaries, associated companies and affiliated companies or entities (hereinafter “Nibanme”, or “we”) respect and protect the privacy rights of the users. We undertake to provide the relevant privacy rights and security policies herewith (hereinafter “Privacy Policy”) in accordance with Personal Data (Privacy) Ordinance (Chapter 486 of the law of Hong Kong) under Hong Kong laws and the relevant privacy protection principles.

Please read carefully all the provisions of this Privacy Policy. If you do not agree or accept this Privacy Policy, please do not use our services. Please note that personal data is provided on a wholly voluntary basis. However, if you would like to use our services, you must register for membership, and also to provide the personal data that we request, such as your email address or mobile phone number, or to bundle your personal Facebook account, Google account or similar account. Otherwise you shall not register as our member successfully. At the time you provide your personal data on the website or the smartphone app for our webpage or services, you will have agreed to the terms and conditions in this Privacy Policy. Regardless of when or through what means or services do you provide your personal data, you are deemed to have agreed to NIBANME’s collection, use and sharing of the said personal data in accordance with the terms of this Privacy Policy.

This Privacy Policy provides the details on how NIBANME collect, use, store, process or transfer your personal data. All the personal data that you provide to us will be treated with strict confidentiality. To this end, we follow the following principles in our privacy policy:

A. Our Commitment to the Protection of Your Personal Data

We are committed to protecting the personal data (hereinafter “Personal Data”) in our possession and your privacy. In order to ensure that you make an informed and assured decision in providing your Personal Data, we provide the details on our collection and use of your Personal Data herein. We will also explain the choices you have before consenting to our collection and use of your Personal Data.

B. Types of Personal Data that We Collect

It is necessary to our business operation (including but not limited to the verification of your identity, the activation and management of your account, the handling of security or technical issues, and to respond to your expectations on our products and services) (hereinafter “services”) that we collect, use and retain certain Personal Data.

We collect different types of Personal Data in accordance with your requests or in furtherance of the services and products that we provide. These types of Personal Data may include:

• Contact Information, such as name, alias, address, phone number, social media user ID, email address, and similar contact data.

• Organization and contacts Information, such as your employer or organisations that you are a member of, information about your colleagues or those within your organisation, your status with an organisation, and similar data.

• Account Information, such as security-related information (including usernames and passwords, authentication methods, and roles), service-related information (including purchase history and account profiles), billing-related information (including payment, shipping, and billing information), and similar data.

• User content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our services (including information in alerts, folders, notes, and shares of content), and similar data.

• Device & Browser Information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.

• Usage Information and Browsing History, such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, API calls, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, purchases or next steps you may make after seeing an advertisement, and marketing preferences), and similar data.

• Location Data, such as the location of your device, your household, and similar location data.

• Demographic Information, such as country, preferred language, age and date of birth, marriage status, gender, physical characteristics, personal or household/familial financial status and metrics, military status, and similar data.

• Your Image, such as still pictures, video, voice, and other similar data.

• Identity Information, such as government-issued identification information, tax identifiers, social security numbers, other government-issued identifiers, and similar data.

• Financial Information, such as billing address, credit card information, billing contact details, and similar data.

• Social media and online content, such as information in social media and online profiles, online posts, and similar data.

• Career, education, and employment related information, such as job preferences or interests, work performance and history, salary history, status as a veteran, nationality and immigration status, demographic data, disability-related information, application information, professional licensure information and related compliance activities, accreditations and other accolades, education history (including schools attended, academic degrees or areas of study, academic performance, and rankings), and similar data.

Some Personal Data are necessary for the provision of certain services. If you are not able to provide such Personal Data for these certain services, we may not be able to provide the said products and services to you. If you provide your Personal data to us, you are deemed to have done so on a fair and reasonable basis.

You agree and warrant the registration information and other required data that you provide are truthful and accurate; and you shall maintain the accuracy of the said data.

C. Purposes of the Collection and Use of Personal Data

We may collect and use your Personal Data for any one or more of the following purposes (hereinafter “Purposes”):

• Provide, deliver, analyze, and administer our services (including in connection with the performance of a contract).

• For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our current services.

• Process transactions related to our services and administer accounts or profiles related to you or your organization (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).

• Personalize and make recommendations related to our services and other offerings.

• Contact and communicate with you in connection with our services or other notifications, programs, events, or updates that you may have registered for.

• Send you offers, advertising, and marketing materials, including to provide personalized advertising to you.

• Conduct and communicate with you regarding recruiting and human resources administration.

• Comply with your instructions or to fulfill other, specified purposes for which you have given your consent.

• Detect and prevent fraud and abuse to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our Service or to identify and authenticate you before we provide you with certain information.

• Exercise our rights and to protect our and others’ rights and/or property, including to take action against those that seek to violate or abuse our services.

• Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or authority, as well as to fulfill our contractual obligations with our customers when they arrange access to our services for you.

• Effectuate the sale, merger, acquisition, or other disposition of our business (including in connection with any bankruptcy or similar proceedings).

Without first seeking your prior consent, we shall not knowingly or intentionally use, share or sell your Personal Data for any purpose not related to the foregoing, or use the same for purposes not relevant to the purposes stated in the Collection of Personal Data Declaration as provided to you at the time of the collection of Personal Data.

D. Disclosure and Transfer of Personal Data

In furtherance to the Purposes stated under the foregoing paragraph headed “C. Purposes of the Collection and Use of Personal Data,” we may transfer or disclose your Personal Data to third parties within or outside of Hong Kong, or share it with third party or authorize the third party to review the same. Your Personal Data may be transferred within or outside of Hong Kong. The said third party may include:

• Nibanme and its affiliates, associates, holding company, subsidiary and related entities. We may share your personal information amongst the companies within the NIBANME group of companies/entities.

• Your Organization and Contacts. We may share your personal information with your organization and others with whom you have a relationship in order to fulfill or perform a contract or other legal obligation, including with our customer that arranges access to our Services for you and pays us in connection with your access. We may also share your personal information with your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s).

• Business Partners. We may share your personal information with our business partners to jointly offer, provide, deliver, analyze, administer, improve, and personalize products or services or to host events. We may also pass certain requests from you or your organization to these business providers.

• Third Party Content Providers. We may share your personal information with our third party content providers to perform tasks on our behalf and to assist us in providing, delivering, analyzing, administering, improving, and personalizing content that are delivered as part of our Services. We may also pass certain requests from you or your organization to these content providers.

• Social Media Services. We may work with certain third party social media providers to offer you their social networking services through our services. These social networking services may be able to collect information about you, including your activity on our services. These third party social networking services also may notify your friends, both on our services and on the social networking services themselves, that you are a user of our services or about your use of our Services, in accordance with applicable law and their own privacy policies.

• Third Party Service Providers. We may share your personal information with our third party service providers to perform tasks on our behalf and to assist us in offering, providing, delivering, analyzing, administering, improving, and personalizing our services. For example, service providers who assist us in performing, delivering, or enhancing certain products and services related to our delivery and operation of our services, who provide technical and/or customer support on our behalf, who provide application or software development and quality assurance, who provide tracking and reporting functions, research on user demographics, interests, and behavior, and other products or services. These third party service providers may also collect personal information about or from you in performing their services and/or functions on our services. We may also pass certain requests from you or your organization to these third party service providers.

• Advertisers. We may share your personal information with advertisers, advertising exchanges, and marketing agencies that we engage for advertising services, to deliver advertising on some of our services, and to assist us in advertising our brand and products and services. Those advertising services may also target advertisements on third party websites based on cookies or other information indicating previous interaction with us and/or our services.

• Users. For some of our services, we aggregate information from public records, phone books, social networks, marketing surveys, business websites, and other sources made available to us to create listings and profiles that become a part of our content in these services, such as attorney and legal professional directories. These listings and profiles may be made available to all users of these services. As described above, we may also share your personal information with other users who are your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s). Additionally, if you choose to include your personal information in any reviews, comments, or other posts that you create, then that personal information may be displayed other users as part of your posting.

• In the Event of Merger, Sale, or Change of Control. We may transfer this Privacy Policy and your personal information to a third party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control (such as the result of a bankruptcy proceeding).

• Other Disclosures. We may disclose your personal information to third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request, to enforce our terms and conditions or other rights (including investigations of potential violations of our rights), to detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of NIBANME, our users, or the public.

The Personal Data that you provide may be received from or transferred to other jurisdictions outside of Hong Kong for the above Purposes.

E. [Introduction and Declaration of Automatic Renewal services

If you use App Store to confirm the purchase of subscription plans, any subscription fee shall be deducted directly from your Apple ID. If you do not disable the automatic renewal option within the 24 hours before the end of the subscription period, automatic renewal shall apply to your account. You may disable the automatic renewal option in the account setting of App Store at any time.]

F. The Use of Cookies and Server

When you visit any of our website or smartphone mobile app, we may use cookies and/or action tags (also known as single pixel GIF or web beacon) to store and trace your data or your preferences. Cookies are the small text files transmitted from our website to your computer, installed hardware or mobile device. We use cookies in order to provide better services to you, and/or within one or more time period or across different time periods, to store your data in multiple web pages. Most browsers automatically accept cookies, but you may also modify the browser setting to block cookies. However, if you stop using cookies or reject the request to accept cookies, you may not be able to use certain features on our website or smartphone mobile app.

Cookies will only save the data that you provide or of the choices you made when you visit our website. For example, unless you choose to enter your email address, the website is not able to identify your email. Permitting a given website or smartphone mobile app to develop cookies does not mean permitting the said website, any other website or smartphone mobile app to read the other parts of your computer or mobile phone. Only the cookies developed by the said website can read the relevant cookies. As long as any of the Purposes for which you have agreed to allow us to use your Personal Data remain valid, we will preserve the data collected from your computer, installed hardware or smartphone mobile app via the cookies and/or action tags (also known as single pixel GIF or web beacon). We may also work with a third party to assess the effectiveness of our advertisements or to investigate the usage and activities of any of our website or smartphone mobile app. These third parties may read, retrieve and use the said cookies and/or action tags (also known as single pixel GIF or web beacon). The data collected by the cookies and action tags by the said third party remain anonymous.

We may also collect data on your IP address, browser type, website address and the time of access. These types of data are used for internal research. Because these types of data are not personal, they will be processed separately from your Personal Data. In certain special circumstances, the IP address may assist us in deterring and/or preventing abusive behaviors or unlawful activities on the website or smartphone mobile app.

If you interact with us on social media (for example, clicking “like” or “comment” on our mobile app, Facebook or Instagram pages), we may interact with you, and to send messages to you through these platforms. We will interact with you in accordance with the rules of the relevant social media platforms. However, we shall not be liable to the way in which the operators of these platforms collect and process your Personal Data, nor shall we be held responsible for any posts of third party and any other users on our social media account.

G. Direct Marketing

Subject to the provisions under applicable laws, rules, regulations or licensing requirements, we may use and/or transfer the collected Personal Data of the users of the smartphone mobile app and subscription services, or otherwise the Personal Data of the persons who participate in voting, games, contests, lucky draw or promotional activities to any company of NIBANME, who may contact you to recommend, promote or market our products and services via email, SMS, push notification, in-app notification or any communication means existing or shall be invented in the future. Our affiliated company, subsidiary or associated company (with business in legal, regulatory, company secretarial, finance, professional services, administration, provision of professional information or activities of charity and non-profit work) may contact you to promote their products, services and/or our business partner’s products or services and/or marketing matters (including tips and information on banking, insurance, investment, financial services, legal services, regulatory, professional services, public services or other consumer goods and services). The said marketing includes, but is not limited to, the provision of the latest deals, discounts, notices for special events, promotion and the joint marketing campaigns that we conduct with our content supplier or advertiser. We shall send express notification to you before the collection of such Personal Data, and it shall be provided on a voluntary basis. Only when we have obtained your consent do we use, provide and/or transfer your Personal Data for any promotional and marketing purposes. We honor all requests to cease using and/or transferring Personal Data for the purpose of direct marketing. You may elect not to receive the said direct marketing information and/or decline to consent to the transfer of your Personal Data for direct marketing purposes at any time. You may contact us with the contact information provided under Part K of this Privacy Policy. Unless we have your express consent, and subject to the terms of this Privacy Policy, we shall not transfer, sell, or share your Personal Data.

We shall not use your Personal Data to send you our advertisers’ promotional material. The promotional material of our advertisers on our smartphone mobile app is not sent or shown for your viewing with reference to any of your preferences. They are applicable on a general basis and shown to all users of the services.

H. Data Storage

Subject to the provisions under applicable laws, statutes, regulations or accountancy requirements, we shall store the Personal Data that you provide to us with appropriate means. The time of storage shall not exceed the time necessary to effectuate the Purposes as stated in the foregoing. All such relevant data shall be deleted when the said Purposes have been fulfilled

I. Data Security

In order to ensure the proper use and the accuracy of the collected Personal Data, and to prevent unauthorized or accidental access, processing, deletion or other uses of the Personal Data, we have implemented a number of internal policies (including physical measures, electronic safeguards and management guidelines) to protect the safety of Personal Data. However, we are unable to guarantee the complete confidentiality of the communication between us. Please protect your password, credit card, debit card and charge card information adequately to prevent unauthorized access to the same.

J.Other Websites

In order to meet your needs, our smartphone mobile app may contain hyperlinks to third party websites, and the said websites follow different privacy protection practices or policy.

Such third party website has no relationship with our smartphone mobile app. Its content, privacy policy and the said policy’s legality under applicable laws is wholly beyond our control. You understand that the provision of such hyperlinks does not constitute the recognition, agreement or existence of any relationship with such third party websites by NIBANME. It is furthermore beyond our control the Personal Data that you provide to the said website. When you exit our smartphone mobile app and enter another website, you should beware and read the privacy protection declaration or policy of the said website.

K. Your Rights and Our Contact

You have the right to access or modify your Personal Data in our possession. You may also:

• Request to omit or delete your Personal Data;

• Object to our use and/or sharing of your Personal Data for the purposes of direct marketing (please see Part M of this Privacy Policy); and/or

• Object to the opening of your Personal Data file.

Should you wish to exercise any of the above rights, or to obtain a copy of any of your Personal Data, or if you believe that your Personal Data in our collection and retention contain inaccuracies, or to obtain information about our personal data policy and practice and the types of Personal Data in our possession, please contact us as follows:

Nibanme
(Data Protection Officer)
Email：[email protected]

We are committed to providing the appropriate technical measures to enable you to access, update and rectify your Personal Data. When you access, update, rectify and/or delete your Personal Data, we may ask for a verification of your identity as a safeguard of the security of your Personal Data.

Within the permitted extent of applicable laws and regulations, we have the right to reject unreasonable requests (such as requests that will violate the privacy of another). Within the permitted extent of applicable laws and regulations, we have the right to collect reasonable, at-cost fees in handling requests of access to Personal Data.

L. Notes

This Privacy Policy may be amended from time to time. You may access and obtain the latest amended version of this Privacy Policy via the smartphone mobile app. You can thus keep abreast of the ways in which we collect and use Personal Data.

M. Cancellation of Subscription to Direct Marketing Information

You may elect not to accept any marketing and promotional information from NIBANME. There is no cost in cancelling this option.

As of 2021, NIBANME member companies and entities include: holding company, affiliated company, associated company and other organizations jointly controlled or other entity having de facto control of or being controlled by NIBANME, the business run by the said entities and the smartphone mobile app, website, products and services operated or developed by the said entities. This list is updated from time to time. We request our member companies to implement this Privacy Policy.