Privacy Policy

1. Introduction
   1. Who We Are. Talents Times Technology Limited (“Talents Times“, “we”, “us”, or “our”), a Hong Kong registered limited company, is the data processor and is responsible for your Data (as defined below) on our Anyone Platform (as defined below) which is an online “product and service matching” platform provided by us at www.anyonehk.com (the “Site”). We are committed to protecting your data and respecting your privacy in relation to your access to and using Anyone. For our contact information, please refer to the last section of this privacy policy (the “Policy”).
   2. Important Information. This Policy (together with the Anyone Terms (as defined below)) applies to your use of the Anyone Platform, once you have installed a copy of any Anyone mobile application onto your mobile phone or device (the “Device”) and created an account on Anyone. Furthermore, this Policy sets out the basis on which any personal data or information we may collect from you, that you provide to us, or that about you (collective, the “Data” or “your Data” as further detailed in Clause 4.1 below), will be processed by us. Anyone is not intended for children/minors and we do not knowingly collect data relating to children/minors. Please read this Policy carefully to understand our practices regarding the Data and how we will treat it.
   3. We review this Policy regularly and may amend it from time to time. All handling of Data shall be governed by the most recent version of it, available at [link].
   4. The Chinese version of this Policy is a translated version and it is strictly for reference only. If there is any inconsistency between the English and Chinese versions of this Policy, the English version shall always prevail. 

2. Definitions and Interpretation
   1. In these Terms, unless otherwise stated:

1. 2. Unless the context otherwise requires the singular includes the plural and vice versa.

3. Protecting your privacy
   1. We are committed to processing your Data in compliance with the required standards governed by the Privacy Laws which include:
      1. protecting your privacy; and 
      2. ensuring the security of your Data.
   2. Before using and providing your Data for the purposes as set out in this Policy and in accordance with the Anyone Terms, we may be required by law to obtain your written consent or checking the relevant checkbox(es) shown to you in the Anyone Apps, and in such cases, only after having obtained such written consent, may we use your Data in the manner as specified herein.

4. The Data We Collect [YOU MUST REVIEW THIS SECTION CAREFULLY]
   1. For the purpose of providing the Anyone Platform to you and/or in compliance with Legal Compliance, we may collect, use, store and transfer different kinds of Data as follows: [Please modify these as you see fit and please briefly explain how they are used and in what way(s) etc.]
      1. Identity Data: the name, date of birth and other details documented on your Hong Kong Identity Card, passport or other legal identity documents we deem acceptable;
      2. Contact Data: contact details including name, address, phone number, mobile number and/or email address;
      3. Financial Data: payment and other details such as Talents’ bank payment information;
      4. Transaction Data: includes: (i) details about payments to and from you, (ii) details of purchases, (iii) your credit and service history to enable us to assess your eligibility to our offers and/or to accommodate your request for transfer of your account with us, on the Anyone Platform;
      5. Device Data: device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
      6. Content Data: includes information relevant to Anyone stored on your Device such as your Anyone login information, photos, videos or other digital content;
      7. Profile Data: includes your username and password, purchase history, your interests, preferences, feedback and survey responses;
      8. Usage Data: information about how you use Anyone such as your network usage, how you use our network, and your location when you are using Anyone;
      9. Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences; 
      10. Location Data: includes your current location disclosed by GPS technology or other location technologies available on your device;
      11. Third-Party Sign-in Data: data that you have shared with Third-Party Sign-in operators (e.g. account login name, profile picture, contact details) including information that allows us to identify you for verification purpose. Please carefully review the privacy policy of your preferred operator(s); we have no affiliation with such Third-Party Sign-in operators and accept no liability (whether in tort or contract or otherwise) for any loss or damages arising from your use of such operators’ services. You shall bear the total responsibility;
      12. Account Data: account details or Data relating to Anyone registered with us including but not limited to the relevant username, password, account numbers etc.;
      13. Data Requested by Authority: subject to relevant Privacy Laws, all Data requested, sought or demanded by applicable Government Authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
      14. Other Data: any other Data as may be required by us and/or our contractors/service providers, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of Anyone.
   2. Aggregated Data. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such aggregated data could be derived from your anonymized Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on Anyone. However, if we combine or connect such aggregated data with the Data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy. Please also refer to Clause 6.1 (Data Analytics) below.
   3. Additional Data (Optional). 
      1. At your discretion, you may choose to provide additional data for better personalization of your use of Anyone. “Additional Data” may include, but are not limited to, your sex, age, and/or other personal preferences etc.
      2. Provision of the Additional Data is optional as we only use them to provide you with a personalized experience on Anyone (“Personalization”). No Personalization would be available to you without such Additional Data.
   4. You may need to provide Data about other individuals to us or a Talent such as when you purchase a service on Anyone for and on behalf another person (e.g. signing up for a fitness class for a friend). If so, you may be required to confirm your compliance with the Privacy Laws, for example, Part 6A of the PDPO (relating to Data Protection Principle 3 Use of Data), including confirming that you have informed those individuals of the use, disclosure and transfer of Data from you to us and from us to third parties (e.g. a Service Provider) and possible disclosure of the individual’s details by us to you; and that you have obtained those individuals’ authorization and/or consent to such use, disclosure and transfer (or the extent to which such authorization and/or consent was obtained). You should also advise them that we can be contacted for further information at the details stated in the last section of this Policy.
   5. Data supplied by you will be held by us, and will be accessible by our employees, relevant Service Provider(s) (when you make a purchase from them) and authorized third parties (consistent with the situations or for the purposes set out in this Policy) or as otherwise indicated by prior notice to you or, where required, by obtaining your consent.

5. How is the Data collected?
   1. We will collect and process the following data about you:
      1. Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by accessing to or using any part or function of the Anyone Platform. It includes but not limited to information you provide when you register to use Anyone, other functions available in Anyone, and when you report a problem with Anyone. If you contact us, we will keep a record of that correspondence. 
      2. Information we collect about you and your device. When you use Anyone, we will automatically collect Data including Device, Content and Usage Data. On the Site where no user logon is required, we collect similar but anonymized data using Cookies (please see Clause 6.2 below) and other similar technologies.
      3. Location Data. We also use location data received from your device to determine your current location. Some of Anyone’s location-enabled services require such data for the feature to work (e.g. locating/matching nearby Talents). If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by denying or disabling Location Data access in your device settings.
      4. Information we receive from other sources including third parties and publicly available sources. We may also receive Data from various third parties and public sources (e.g. Google searches) as set out below:
         1. Device Data from analytics providers (e.g. Google), advertising networks, or/and search information providers;
         2. Contact, Financial and Transaction Data (e.g. credit check) from providers of technical, payment and delivery services;
         3. Identity and Contact Data (e.g. background check of Talents) from data brokers, aggregators, and/or publicly available sources.

6. Privacy Data
   1. Data Analytics. To better serve your needs and preferences, our servers may collect data relating to your network, device and/or app activities. In addition to Clause 4.2 (Aggregated Data), we may also collect aggregated, anonymous, statistical data on the server’s usage (such as browser information, operating system information, IP address, domain name, device ID, location, cookies, logs, configuration, and other diagnostic data) so that we may better cater to the behavior of users of Anyone.
   2. Our Site Uses Cookies. 
      1. We use Cookies and/or other tracking technologies to distinguish you from other users of the Anyone Platform and to remember your preferences. This helps us to provide you with a good experience when you use Anyone and also allows us to improve Anyone. For detailed information on the Cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy [link].
      2. Anyone only provides Users’ or Talents’ account logon via the respective Anyone Apps. There is no user or account information on our websites.
      3. You will be prompted to accepted our Cookie Policy upon your first visit to the Site.

7. How we use your Data
   1. We will only use your Data when it is legally allowed to do so. Most commonly we will use your Data in the following circumstances where: 
      1. you have consented before the processing;
      2. we need to perform a contract we are about to enter or have entered with you (e.g. passing your Data to a Service Provider/Talents);
      3. it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
      4. we need to comply with a Legal Compliance. 
   2. We may collect, retain and use your Data for the following purposes:
      1. to install the Anyone Apps and register you as a new Anyone user;
      2. to verify your identity;
      3. to process in-app purchases and deliver services on Anyone (e.g. managing payments);
      4. to manage our relationship with you including notifying you of changes to Anyone;
      5. to promote and market our services to you;
      6. to enable you to participate in a promotion (e.g. prize draw), competition or complete a survey;
      7. to administer and protect our business and Anyone including troubleshooting, data analysis and system testing;
      8. to conduct credit checks and detect fraudulent activities in compliance with applicable laws such as the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (Cap. 615);
      9. to deliver content and advertisements to you; 
      10. to make recommendations to you about goods or services which may interest you;
      11. to measure and analyze the effectiveness of the advertising we serve you;
      12. to process your account management on Anyone;
      13. to provide, activate and/or renew our services;
      14. to carry out matching procedures as defined under the Privacy Laws;
      15. to enforce our contractual rights;
      16. to perform research or analyses so that we may improve and optimize Anyone;
      17. to verify your eligibility to our offers of services, promotions, and/or other events;
      18. to monitor trends so we can improve Anyone; and
      19. to comply with applicable laws in or outside Hong Kong as may be required by applicable Government Authorities in relation to your activities on Anyone, including to assist in the prevention, detection of crime or possible criminal activities.
   3. Marketing Communications. We will only send you marketing communications by email, SMS/text, in-app messages, and/or mobile phone notifications if we have your opt-in consent. You have the right to withdraw that consent at any time by contacting us. We will not share your Data with any third party for marketing purposes without your consent.
   4. Other Uses. For other uses such as referring a friend to join Anyone, we will only do so with your consent.

8. Disclosure of Your Data
   1. When you consent to providing us with your Data, we will also ask you for your consent to share your Data with the third parties set out below for [the purposes of disclosing data].
   2. We do not sell your Data to any external third party; we may, to the extent permissible under applicable laws and regulations, disclose your Data to certain the External Parties (who may be within or outside of Hong Kong) for the purpose of:
      1. providing the services that you have requested as use of your Data may be required for the performance of the same; and
      2. managing our services and business.
   3. In addition, we may disclose your Data:
      1. to your authorized representatives and/or your legal advisers when requested by you to do so and we bear absolutely no responsibility for these parties’ actions regarding your Data;
      2. for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties (who may be within or outside of Hong Kong):
         1. our professional advisers, including our lawyers, accountants and auditors;
         2. credit-reporting and fraud-checking agencies;
         3. to financial institutions, charge or credit card issuing companies, credit providers, credit bureau, collection agencies or security agencies;
         4. our affiliates, overseas offices, assignees, transferees and representatives;
         5. to Government Authorities; and/or
         6. to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business.
   4. The External Parties and, if and when applicable, those listed in Clause 8.3(b) above are bound by appropriate confidentiality and privacy obligations in relation to the protection of personal data and that they only use such personal data to carry out the services for which they have been engaged for, and not for their own or other purposes (such as direct marketing).
   5. Additional Data. Pursuant to Clause 4.3, Additional Data shall only be used for Personalization; therefore, any disclosure of Additional Data shall be limited to where we are legally required to do so (e.g. court order).

9. International Transfers
   1. At times it may be necessary for us to transfer personal data to places outside of Hong Kong or the country/region in which you access Anyone (the “Non-HK Jurisdiction”), for example, for storage, processing and other purposes for which the Data were collected or for the prevention, detection or investigation of crime. In the event that we do transfer your Data outside of Hong Kong or the Non-HK Jurisdiction, we will do so in compliance with the prevailing requirements of the Privacy Laws and other appliable privacy laws of the Non-HK Jurisdiction.
   2. Whenever we transfer your Data out of the Hong Kong, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      1. we will only transfer your Data to countries that have been deemed to provide an adequate level of protection for personal data; and
      2. where we use certain service providers (such as cloud storage server), we, if possible, may use specific contracts which are governed by the laws of Hong Kong and give personal data the same protection it has in the Hong Kong.
   3. Please contact us if you want further information on the specific mechanism used by us when transferring your Data out of the Hong Kong.

10. Data Security
    1. All required efforts are made to ensure that all information you provide to us is stored securely and safely on our servers and is accessible only by our authorized persons or entities.
    2. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using appropriate technology such Secured Sockets Layer. Where you have chosen a password that enables you to access Anyone, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
    3. Once we have received your information, we will use strict procedures and security features to try to prevent your Data from being accidentally lost, used or accessed in an unauthorized way.
    4. Further to Clause 8.4, when we pass your Data to Talents for the provisioning of their services to you, we seek to ensure that they have appropriate security measures in place to keep your Data safe and to comply with applicable principles in relation to data protection. Notwithstanding the foregoing, as each Service Provider has its own privacy policy, please review and make sure you agree to the same before making any purchase on Anyone. We have no control whatsoever in relation to how your Data are processed by individual Services Providers.
    5. Some of the people we share your Data with may process it overseas.  You can contact us for more information about the safeguards we use to ensure that your Data is adequately protected in these circumstances.
    6. Certain services on Anyone may include social networking, chat/forum features. You are responsible to ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users when using these features.
    7. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

11. Data Retention
    1. We will retain your Data in accordance with our internal policies which are in compliance with the Privacy Laws and cover the following principles:
       1. Data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
       2. Except for long-term backup/data archive, Data are purged from our electronic, manual and other filing systems in accordance with the above criteria and our internal procedures.

12. External Links
    1. Anyone may contain links to other websites and other online resources operated by third parties such as our partner networks, advertisers, affiliates and the Talents’ websites. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services as we have no control over them or the way in which the operators of them deal with your data. Please check these policies before you submit any personal data to them.

13. Your Legal Rights
    1. Under certain circumstances you have the following rights under data protection laws in relation to your Data:
       1. Request access to it;
       2. Request correction of it;
       3. Request erasure of it;
       4. Object to processing of it;
       5. Request restriction of processing it; 
       6. Request transfer of it;
       7. Right to withdraw consent; and
       8. Right to ask us not to continue to process your Data for marketing purposes.
    2. Although we take all reasonable precautions to ensure that the Data we collect, use and disclose is accurate, complete and up-to-date, the accuracy of that Data depends on the Data you provide. You have a right to request access to, and correction of, your Data and we recommend that you:
       1. let us know if there are any errors in your Data; and
       2. keep us up-to-date with changes to your Data.
    3. You can exercise any of these rights at any time by contacting us at the details stated in the last section of this Policy. Administrative charges maybe applicable for providing you with access to your Data in response to such request.
    4. You may decline to share Data with us and/or withdraw any consents which you may have provided, in which case, we may not be able to provide you with some of our services.
    5. At any time, you may object to us holding or processing your Data, on legitimate grounds, save and except as otherwise permitted by the applicable law.

14. Contact Us
    1. For issues and enquiries regarding our compliance with our obligations under the Privacy Laws, and any request for access to, correction or deletion of your Data, please contact us in writing at:

Talents Times Technology Limited

ROOM 16 FLAT 01-03 25/F CDW BUILDING 388 CASTLE PEAK ROAD, 

TSUEN WAN, N.T., 

HONG KONG., Hong Kong  

14. 2. If you have any question or issue regarding our handling of your Data, please contact us at (852) 3618 8647 or email to support@anyonehk.com.