Privacy Policy

This policy sets out: A. The information we collect about you when you visit our website, use our products or services, or otherwise interact with us; B. How we use, share, store, and secure the information; and C. How you may access and control your information.

In this policy, “Kolup” or “we” refers to Kolup, located at Room 24, 4/F, Core E, Cyberport 3, 100 Cyberport Road, Hong Kong, and “Platform” means our website and applications related to Kolup services.

1. What Information We Collect About You

1. We collect the following types of information about you:

   • Account Data: Information you provide during registration, such as your name, email, and phone number.
   • Support Data: Information provided through support interactions, including contact details and documents.
   • Preference Data: Marketing and other preferences set during account setup or surveys.
   • Transaction Data: Details of transactions and orders made.
   • Financial Data: Payment information like bank account details.
   • Technical Data: Device or connection information, such as IP address, browser type, and cookies data.
   • Usage Data: Information about how you interact with our Platform.

1. We collect information when you provide it or automatically when you use our Platform. We may also receive information from:

   • Our personnel involved in operations or service delivery.
   • Other users of our products or services.
   • Our affiliates providing technological or marketing services.
   • Our business partners and service providers for technical, payment, and analytics services.

2. We do not collect sensitive data such as race, religion, or health information.

2. How We Use Information We Collect

1. We use your personal information lawfully, including:

   • To perform our contracts with you, such as providing our services and ensuring Platform security.
   • For legitimate interests not overridden by your rights, such as research and protecting our legal rights.
   • With your consent, for example, to send marketing materials.
   • To comply with legal obligations.

2. You may withdraw consent for specific uses at any time by contacting us. However, this does not affect past uses based on consent.

3. We do not share your personal information with third parties for marketing without your explicit consent.

3. How We Share Information We Collect

1. We share information with third-party service providers that assist in providing, improving, and marketing our services.
2. Third-party providers have access to your information as necessary to perform their services and are bound to protect your information in compliance with applicable laws.
3. We ensure our third-party providers maintain equivalent data protection standards.
4. Personal information may be aggregated or de-identified for research purposes.
5. When you use third-party software integrated with our Platform, you may be subject to the third party’s privacy policies.
6. Our Platform may contain links to third-party sites; your interactions with them are governed by their privacy policies.
7. We may share information with authorities to comply with legal obligations.
8. In case of business transfer, your information may be disclosed or transferred to the involved third party, with notification.

4. How We Store and Secure Information We Collect

1. Data is hosted in secure facilities, primarily in Singapore.

2. Security measures include:

   • TLS/SSL encryption.
   • Password-protected accounts with strong password requirements.
   • Restricted access to data on a need-to-know basis.
   • Regular review of our information security practices.

3. We have protocols to handle data breaches and will notify you and regulators as required by law.

4. Despite robust safeguards, no data transmission over the Internet is completely secure.

5. We retain personal data only as long as necessary for business or legal purposes and review our data retention policies regularly.

5. How We Transfer Information Internationally

1. Your information may be transferred and stored outside your country for service delivery.
2. We ensure data protection standards through contractual clauses and appropriate mechanisms for international transfers.

6. Your Rights

1. You have rights to:

   • Be informed about our data practices.
   • Request access to your personal data.
   • Correct inaccuracies in your data.
   • Request data deletion, subject to legal and business considerations.
   • Object to or restrict data processing.
   • Request data portability.
   • Withdraw consent for data processing based on consent.

2. Opt-out of marketing emails via the unsubscribe link or through account settings.

3. We may request verification for identity confirmation when processing your requests.

4. Requests are typically addressed within one month and may incur a fee if excessive.

7. Changes to This Policy

1. We may update this policy by posting revisions on our Platform. Continued use after changes indicates acceptance.

8. Policy Towards Children

1. Our services are not directed to individuals under 16. We will delete any data collected from individuals under 16 upon discovery.

9. Contact Us

1. For questions or concerns, email us at [email protected] or write to:
   • Kolup, Room 24, 4/F, Core E, Cyberport 3, 100 Cyberport Road, Hong Kong.
2. If unresolved, you may file a complaint with a relevant data protection authority.

Last updated 01 September 2024