Clickful Privacy Policy

Last updated: 30 April 2018

Designjar Limited ("we" or "Clickful", as construed accordingly) is committed to protecting and respecting your privacy. This policy (together with any other documents referred to in it) ("Privacy Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By visiting our Site or using our App you accept and consent to the practices set out below.

Unless otherwise defined, capitalised terms have the same meanings as defined in our Terms of Service.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. 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 in our App;
    • when you ask for information at other times, for example, in connection with a promotion or when you report a problem with the Site;
    • when you report any problem to us;
    • when you set up integration or utilise certain features in our App;
    • request any support from us;
    • 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 Internet protocol (IP) address used to connect your computer to the Internet, your log-in information, browser type and version, time zone setting, browser plug-in types and version, as well as operating system and platform;
    • details of any transactions, purchases and payments you made in our App; and
    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (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.

2. Uses made of the information

The purposes for which information may be used by us in and outside the Hong Kong Special Administrative Region include:

  • ensuring that content from our Site is presented in the most effective manner for you and for your computer;
  • providing you with alerts, newsletter, education materials or information that you requested or signed up to;
  • carrying out our obligations arising from any contracts entered into between you and us;
  • allowing you to participate in interactive features of our service, when you choose to do so;
  • designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
  • complying with laws and regulations applicable to us or any of our affiliates in or outside the Hong Kong Special Administrative Region;
  • legal proceedings, including collecting overdue amounts and seeking professional advices;
  • researching, designing and launching services or products including seminars/events/forums;
  • promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in Clause 2.2 below); or
  • purposes directly related or incidental to the above.

We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

  • your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing;
  • the following classes of services, products and subjects may be marketed in direct marketing:
    • services and products related to our Site and/or our affiliates (including marketing affiliates programs we are a part of);
    • reward, loyalty or privileges programmes, promotional offers and related services; and
    • invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.

We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.

3. Disclosure of your information

We will keep the personal data we hold confidential but may provide information to:

  • personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;
  • our overseas offices, affiliates, business partners and counterparts (if any);
  • 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 or participants of our services in any part of the world.

4. Cookies

Our Site uses cookies to distinguish you from other uses 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 session).

We use the following types of 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 Site, 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); and
  • Targeting cookies – These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.

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.

5. Third party sites

Our Site, or 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.

6. Security

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which 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.

Unfortunately, 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. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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

7. Data transfer

The data that we collect from you may be transferred to, and stored at, a destination outside the country or region of your residence (or, if you reside in the UK, outside the European Economic Area) (the “Home Region”). It may also be processed by persons referred to in clause 3 above who operate outside the Home Region.

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

We may hold your data on servers in Hong Kong, Singapore and any other territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any people listed at Clause 3 above, who may be located in or outside of the Hong Kong Special Administrative Region.

8. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, we will update you on the changes of our Privacy Policy by email. By continuing to use our Services after the changes come into effect means that you agree to be bound by the revised policy.

7. Your consent and rights

By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.

You have the right to:

  • check whether we hold personal data about you and access any personal data we hold about you;
  • require us to correct any inaccuracy or error in any personal data we hold about you.

Details of your legal rights in respect of personal data will depend on the applicable legislations and legal requirements of the country or region of your residence. If you have any question about your legal rights, please contact us.

You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to:

        Name: Designjar Limited
        Address: Block A, 2/F, HK Industrial Building, 444-452 Des Voeux Road West, Shek Tong Tsui, Hong Kong
        Email: support@clickfulapp.com

In accordance with the terms of the the Hong Kong Personal Data (Privacy) Ordinance (the "Ordinance"), we have the right to and may charge a reasonable fee for processing any data access request.

Clickful is required to respond to a User’s request within fourteen (14) days of his or her request and will endeavor to do so wherever possible.

8. Governing law and jurisdiction

Nothing in this Privacy Policy shall limit the rights of the data subject under the Ordinance. This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region. You agree to submit to the exclusive jurisdiction of the Hong Kong courts.