Privacy Policy
Regtitude Limited (the “Company”, “we”, “us” or “our”) is holding group of companies (“Regtitude Group”), including OFB application. This privacy policy (the “Policy”) applies to the information that we collect when you use our Regtitude and/or OFB application and website (the “Platform”) or purchase products and/or services from the Platform.
We acknowledge privacy is the fundamental right of an individual, and we shall make every effort to uphold this right. We value and respect the privacy of the people we are dealing with. We are committed to protecting the privacy, confidentiality, and security of the personal information we hold by complying with the strictest standards of the applicable privacy laws and regulations, including, but not limited to, the Personal Data (Privacy) Ordinance (Cap. 486, the Laws of Hong Kong) (the “PDPO”) with respect to the management of Personal Data (as defined in the following section 1.1). We are equally committed to ensuring that all our employees and agents uphold these obligations.
This Privacy Policy defines what information and Personal Data we collect, why we collect it, how we use and disclose it, and how we safeguard Personal Data in accordance with the PDPO. Please read this Privacy Policy in its entirety before using our Platform. You are deemed to have agreed and consented to the principles, statements, and practices outlined in this Privacy Policy regarding the collection, use, and disclosure of your information when you use, access, or interact with our Platform.
1. What are Personal Data and related terms?
1.1 “Personal Information” is any information or opinion, whether correct or incorrect and whether recorded in a material form or not, about an identified individual or an individual who can be reasonably identified from that information. This includes information or an opinion that directly or indirectly identifies you (such as your name) as an individual. This definition of personal information is described as "personal data" in the PDPO; and the PDPO’s definitions are provided below. In this Policy, the terms of “Personal Information” and “Personal Data” are used interchangeably.
1.2 This Policy adopts the PDPO's definitions of the following terms:
1.2.1 “Data Subject” is the individual who is the subject of the personal data;
1.2.2 “Data User” is a person who, either alone or jointly with other persons, controls the collection, holding, processing or use of personal data; and
1.2.3 “Data Processor” is a person who processes personal data on behalf of another person (a Data User), instead of for his/her own purpose(s). Data Processors are not directly regulated under the PDPO. Instead, Data Users are required to, by contractual or other means, ensure that their Data Processors meet the applicable requirements of the PDPO; and
1.2.4 “Personal Data” means information which relates to a living individual and can be used to identify that individual. It must also exist in a form which access to or processing of is practicable.
2. What Personal Data do we collect?
2.1. The Personal Data we collect about you depends on the nature of your dealings with us or what you choose to share with us.
2.2. To facilitate the services offered on our Platform, we may need to collect the following Personal Data from you:
2.2.1. your name;
2.2.2. your address(es);
2.2.3. your age and date of birth;
2.2.4. your identity card number;
2.2.5. your email address;
2.2.6. your phone number;
2.2.7. your account registration information on the Platform;
2.2.8. when you request any support from us or report any problem to us;
2.2.9. information provided from using certain services or features;
2.2.10. information from completion of a survey or questionnaire;
2.2.11. technical information, including the Internet protocol (IP) address used;
2.2.12. your log-in information, browser, time zone setting, browser plug-in types and versions, operating system and platform;
2.2.13. details of any transactions, purchases, and payments you made on the Platform;
2.2.14. your general interaction with the Platform, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Platform, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information;
2.2.15. information received from third parties, such as business partners, sub-contractors, payment and delivery services, referral by other users;
2.2.16. information from your mobile device with your previous consent; and
2.2.17. information you provide about other people, such as the names, telephone numbers, and emails of friend(s), family, or contact(s) with whom you want to share information on or about the Platform.
2.3. For the avoidance of doubt, the list of Personal Data that we may collect in the above section 2.2 is not exhaustive and serves only as examples.
2.4. Under certain circumstances, it may be necessary for us to collect sensitive personal data (“Sensitive Personal Data”) about you. This might include genetic data, biometric data, racial or ethnic origin data, health status data. It also includes data (such as finance or credit reference data) which, if improperly handled, may put an individual at significant risks of discrimination or serious harm.
2.5. Generally speaking, your provision of Personal Data is on a voluntary basis. However, if you do not provide us with sufficient information, our Platform may be unable to provide you with the requested information, products, and/or services.
3. Why do we collect and use your Personal Data?
3.1. We collect and use Personal Data for the following purposes:
3.1.1. performing our agreement with you to provide content and services on the Platform, including but not limited to the creation of smart contracts, the carrying of business matching and smart matching, as well as providing, improving and developing our products and services;
3.1.2. researching, designing and launching new platforms, products, services document templates, legal forms or features;
3.1.3. providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
3.1.4. sending to your service provider and/or financial institutions at your request for the purpose of using our services and/or Platform;
3.1.5. exercising our rights under our contracts with you, including collecting amounts outstanding from you;
3.1.6. responding or taking part in legal proceedings, including seeking professional advice, or for the purposes of the legitimate and legal interests of the Company or a third party (e.g. the interests of our other customers);
3.1.7. compliance with any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside Hong Kong existing currently and in the future or other legal obligations that we are subject to;
3.1.8. communicating with you and responding to your questions or requests;
3.1.9. researching, market trends related to individuals, customer profiling, behaviour and segmentation;
3.1.10. analysing how you access and use our Platforms, products and services including those available on our websites and apps;
3.1.11. advertising and marketing our platforms, products and services and other related subjects;
3.1.12. determining the amount of indebtedness owed to or by you;
3.1.13. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Regtitude Group and/or any other use of data;
3.1.14. facilitating consolidated supervision of the Regtitude Group for the conduct of internal audit and the performance of risk management;
3.1.15. responding to any legal, governmental, or regulatory or quasi-governmental related matter, action or proceeding (including any prospective action or legal proceeding);
3.1.16. making or investigating any claim or responding to any search or document request, including but not limited to action, proceeding, request from government authorities, Hospital Authority or the Law Society of Hong Kong;
3.1.17. providing analytics by third party on our behalf via the Platform which are aggregated or de-identified information with third parties, which cannot reasonably be used to identify you;
3.1.18. processing Personal Data with our strategic partners to provide products and services, or that help us market to customers (including, but not limited with Regtitude Group on document creation service and a third-party provider on optical character recognition technology);
3.1.19. reviewing the Personal Data from time to time to identify problems and solve disputes, to identify users who use multiple user identifications or aliases, and to compare and review your Personal Data for errors, omissions and accuracy;
3.1.20. subject to your consent, introducing, providing and marketing to you the Company, other companies of the Regtitude Group or the company's business partners of the products/services, and the provision, maintenance, management and operation of such products/services;
3.1.21. purposes directly related or incidental to the above; or
3.1.22. where you have given consent to it.
3.2. Your IP address may be used to help diagnose problems with our server, to administer our Platform, and for security needs. We may provide aggregate statistics about our customers, sales, traffic patterns, and related site information to third-party vendors, but these statistics will include no personal identifying information.
3.3. Reasons for collecting and processing Personal Data determine and limit what Personal Data we collect (this section 3) and how we collect and process it (section 4 below), how long we store it (section 5 below), who has access to it (section 6 below) and what rights and other control mechanisms that are available to you as a Data User (section 8 below).
4. How do we collect and process your personal information?
4.1. We collect information about you in three main ways:
4.1.1. when you provide it to us;
4.1.2. with automatic technologies; and
4.1.3. when third party sources provide it to us.
Information Directly Provided by or Collected from You
4.2. We collect your personal information directly from you when you:
4.2.1. interact with us over the phone;
4.2.2. interact with us in person;
4.2.3. interact with us online; and
4.2.4. apply for a position with us as an employee, contractor, or volunteer.
4.3. Basic Account Data
4.3.1. When setting up your user account (“User Account”) on the Platform, we will collect your name, Hong Kong Identity Card Number, email address, and phone number. You are also required to choose a username and a password. The provision of this information is necessary to register a User Account. You are responsible for keeping this password confidential. We ask you not to share a password with anyone. Your password is kept encrypted at all times, so it cannot be decoded even if someone gains access to our database. However, to avoid unauthorized use of your account by others, you must take steps to control your password.
4.3.2. During setup of your account, the account is automatically assigned a number (the "ID") that is later used to reference your User Account without directly exposing a personal identifier about you.
4.3.3. You agree to provide accurate information to help us serve you best, to periodically review such information, and to update such information as and when necessary.
4.4. Transaction and Payment Data
In order to make a transaction online, you may need to provide payment data to us to enable the transaction. If you pay by FPS (Fast Payment System), you may need to provide your bank account number or telephone/mobile number. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date, and security code) to us, which we will process and transmit to the payment service provider of your choice to enable the transaction and, if required, perform anti-fraud checks. Likewise, we will receive data from your payment service provider for the same reasons.
4.5. Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others, e.g., in forums, chats, or when you provide feedback or other user-generated content. This data includes:
4.5.1. Information that you enter into our legal self-help documents and other legal forms, including your first name, last name, Hong Kong Identity Card number or passport number, residential address, or country of residence;
4.5.2. Information that you post, comment, or follow in any of our Platforms;
4.5.3. Information sent through chats or social media;
4.5.4. Information you provide when you request information or support from us or use our services, including information necessary to process your orders with the relevant payment merchant; and
4.5.5. Information you provide to us when creating documents.
Information Collected by Automated Technologies
4.6. Cookies
4.6.1. When you use our Platform, we may automatically collect certain data about how you access and interact with our Platform which may, when combined with other information about you, constitute Personal Data. Automated technologies, such as our use of ‘cookies’, web beacons, and similar technologies help us achieve our goal of providing you with the best possible service. When you access our Platform, our servers will record or track information sent from the browsers. This can include the following information (without limitation):
4.6.1.1. attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software, and device identifiers;
4.6.1.2. device locations, including specific geographic locations identified through GPS signals or other means;
4.6.1.3. connection information such as the name of your mobile operator, ISP or other service provider, browser type, and IP address;
4.6.1.4. the website from which you have reached the Platform;
4.6.1.5. the website pages viewed;
4.6.1.6. details of the services on the Platform that you look at, information, tools, and content available on our Platform that you use;
4.6.1.7. time spent on the Platform;
4.6.1.8. links of our Platform that you click on; and
4.6.1.9. information related to any of the above.
4.6.2. Our use of cookies enables us to:
4.6.2.1. provide you with a more personalized experience on our Platform. It allows us to remember you when you revisit our Platform. You can also access your previously saved information and/or documents;
4.6.2.2. study browsing habits on the Platform. The more we understand what you are interested in, the greater our ability to offer you customized solutions and targeted advertisements and other marketing materials; and
4.6.2.3. obtain information regarding the number of visitors to the Platform and the pages viewed.
4.6.3. In most cases, cookies are deleted when you close your browser; these are referred to as session cookies. However, persistent cookies stay on your browsing device either until such time as you delete them, or they expire. By using the Platform, you consent to us using cookies. Such use of data does not disclose any of your Personal Data, and we will not collect, process, or use any of your Personal Data in this regard.
4.6.4. You can alter your computer browser settings to block or delete cookies. If you opt to block or delete cookies on the Platform, you may not be able to access certain products or services, and this could have an effect on the performance of the Platform on your system (for example, banner ads may not display properly). If you have registered an account with us, you may be required to re-enter your password more frequently during your use of our Platform if you choose to disable cookies.
4.6.5. In some cases, we also use cookies or similar technologies provided by trusted third parties. This setup allows for more accurate tracking of our users by associating that user with the same ID over various sessions and devices. This approach may combine analytics data with other Personal Data about you that we have collected by the methods stipulated in this section 4. Any such combined data will be treated as Personal Data by us and used in accordance with this Privacy Policy. By registering an account with us and using the Platform, you consent to us using session unification in this way.
4.7. Your Use of Services
In order to provide you with our services, we need to collect, store, and use various information about your activity on our Platform. Content-related information includes your ID, as well as information about your preferences, progress, and time spent, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.
4.8. Content Recommendations
We may process information collected under this section 4 so that content, products, and services shown on the pages and in update messages displayed when launching the service can be tailored to meet your needs and populated with relevant recommendations and offers. This is done to improve your customer experience.
Information Collected by Third-Party Sources
4.9. We may also receive information about you from other third parties we have engaged, such as compliance service providers, business associates, subcontractors, analytics providers, platform providers, public information providers, and/or search information providers.
Sensitive Personal Data
4.10. In the scenario outlined in this section 4.10, your consent to our collection of your Sensitive Personal Data is required for us to provide you with particular services. Our inability to provide you with the corresponding services may result from our failure to obtain your consent; however, this will not affect our capacity to offer you other services:
4.10.1. To verify your identity and/or conduct due diligence, we may process your specific identity information in the form of identification documents or vehicle license numbers;
4.10.2. To communicate with you and conduct due diligence, we may process your residential address;
4.10.3. To process payment transactions with you, we process your financial account information, credit card numbers, and billing transaction details;
4.10.4. To provide access to services delivered through our Platform and conduct statistical analysis, we may process unique device identifiers, IP addresses, browser type and settings, open rates, click-through rates, and other metrics on when and how our Website is used; and
4.10.5. To provide our Services, we process your medical or health data, information, reports, or any forms/documents containing such information.
4.11. You need to carefully consider whether your Sensitive Personal Data should be disclosed to us through our Services.
4.12. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with certain services or otherwise interact with you.
4.13. Sensitive Personal Data shall be transferred only when absolutely necessary.
4.14. You shall have the choice to have Sensitive Personal Data held by us erased and express your choice not to have the data shared or transferred.
4.15. We shall take appropriate measures to protect the security of this Sensitive Personal Data.
Others
4.16. Please do not provide us with the Personal Information of third parties unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Policy.
4.17. You shall be responsible for updating all the information provided on the Platform at the time of registration and ensuring it is correct and accurate at all times. In no event shall the Company be held responsible for the inaccuracy of the said information posted by you on the Platform.
4.18. We also process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. We may share anonymous data, aggregated or not, with third parties.
5. How We Store Data?
Period of Storage
5.1. We will store your information as long as necessary to fulfill the purposes for which the information is collected and processed or—where the applicable law provides for a longer storage and retention period—for the storage and retention period required by law. In particular, if you terminate your service on our Platform, your Personal Data will be marked for deletion except to the degree that legal requirements or other prevailing legitimate purposes dictate a longer storage.
Retention and Deletion of Data
5.2. If you withdraw your consent to the processing of your Personal Data, we will delete your Personal Data without undue delay to the extent legally and technologically permissible and feasible, assuming that the collection and processing of the Personal Data were based on written notice of withdrawn consent.
5.3. In cases where Personal Data cannot be completely deleted to ensure the consistency of the system, the user experience, or the community, your information will be permanently anonymized. Please note that we are required to retain certain transactional data under statutory commercial and tax law for a period of up to seven (7) years.
5.4. If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists, or unless applicable law requires us to retain the data.
Location of Storage
5.6. Without prejudice to the other sections in this Privacy Policy, the data that we collect from you may be transferred to, and stored in, a secured environment, to the extent that is legally permissible, and in some cases, in a location outside of the jurisdiction of Hong Kong. By submitting your Personal Data, you agree to the transfer, storing, or processing of data outside of Hong Kong, subject to the conditions contained herein. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy Policy.
6. Who Has Access to Data
6.1. We are committed to keeping your Personal Data and other information shared with us confidential. We do not sell Personal Data. There are, however, certain circumstances as outlined in this section 6 in which we may disclose or transfer your Personal Data to certain third parties without further notice to you.
6.2. The Company and Regtitude Group may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in section 3 above. This includes our overseas offices, affiliates, business partners, and counterparts (on a need-to-know basis only). In the event of a reorganization, sale, or merger, we may transfer Personal Data to the relevant or proposed transferees of our operations (or a substantial part thereof) in any part of the world.
6.3. We may also share your Personal Data with our third-party providers that provide customer support services, optical character recognition, artificial intelligence, or big data technology in connection with the documents, products, content, and services distributed via us. Your Personal Data will be used in accordance with this Privacy Policy and only as far as this is necessary for performing customer support services.
6.4. We may also share your information with our personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example, staff engaged in the fulfillment of your order, the processing of your payment, and the provision of support services); persons under a duty of confidentiality to us; or persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world.
6.5. In accordance with internet standards, we may also share certain information (including your IP address and the identification of content you wish to access) with our third-party network providers that provide content delivery network services and server services in connection with us. Our content delivery network providers enable the delivery of digital content you have requested, by using a system of distributed servers that deliver the content to you, based on your geographic location.
6.6. We may allow you to link your User Account to an account offered by a third party. If you consent to link the accounts, we may collect and combine information you allowed us to receive from the third party with information of your User Account to the degree allowed by your consent at the time. If the linking of the accounts requires the transmission of information about your person from us to a third party, you will be informed about it before the linking takes place and will be given the opportunity to consent to the linking and the transmission of your information. The third party's use of your information will be subject to the third party's privacy policy, which we encourage you to review.
6.7. We may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.
6.8. WE UNDERSTAND THAT THE NATURE OF DOCUMENTS CREATED BY OUR MEMBERS MAY BE SENSITIVE, PRIVATE, AND CONFIDENTIAL, AND IT IS OUR POLICY NOT TO ACCESS THE CONTENT OF ANY DOCUMENTS CREATED BY OUR MEMBERS UNLESS IT IS ABSOLUTELY NECESSARY.
6.9. If we engage outsourcing service providers or data processors (whether within or outside Hong Kong), outsourcing service providers or data processors are required to adhere to specific standards, including any standards prescribed by a privacy regulator, to prevent any loss, unauthorized access, use, modification, or disclosure of data, either by contractual provisions or other means.
6.10. The community includes document sharing, request, and/or comments areas where users can exchange ideas and communicate with each other. When posting a message to a sharing, request, and/or comments area, please be aware that the information is being made publicly available online; therefore, you are doing so at your own risk. If your Personal Data is posted on one of our public areas against your will, please use the reporting function and the help site to request its removal.
6.11. We may also share your information with any agent, contractor, or third party who provides administrative, technology, or other services (including direct marketing services) to the Company and/or our affiliates and has the obligation to keep Personal Information confidential.
6.12. To understand the Company's policy on the use of your Personal Data for promotional purposes, please refer to section 7 below.
7. Direct Marketing
7.1. Subject to your separate consent or where explicitly permitted under applicable laws on email marketing, we may send you marketing messages about products and services offered by us to your email address. In such a case, we may also use your collected information to customize such marketing messages, as well as collect information on whether you opened such messages and which links in their text you followed.
7.2. The Company intends to:
7.2.1. use your name, contact details (such as phone number, email address, and mailing address), gender, products and services information, pattern and behavior, financial background, and demographic data held by the Company from time to time for direct marketing;
7.2.2. conduct direct marketing in relation to the following classes of products and services that the Company, our affiliates, and our co-branding partners may offer:
7.2.2.1. elderly care services and products;
7.2.2.2. insurance services and products;
7.2.2.3. wealth management services and products;
7.2.2.4. pensions, retirement plans, investments, brokering, financial advisory, credit, and other financial services and products;
7.2.2.5. media, entertainment, and telecommunications services; and
7.2.2.6. donations and contributions for charitable and/or non-profit making purposes.
7.2.3. The above products and services may be provided by the Company and/or:
7.2.3.1. any of our affiliates;
7.2.3.2. third-party financial institutions;
7.2.3.3. the Company, our affiliates, and our co-branding partners providing the relevant products and services; and
7.2.3.4. external service providers supporting the Company or any of the above-listed entities in providing the relevant products and services.
7.2.4. The Company also intends to provide the data described in sections 7.2 and 7.2.3 above to all or any of the persons described in this Privacy Policy above for use by them in marketing those products and services, and the Company requires your written consent (which includes an indication of no objection) for that purpose.
7.3. You can opt-out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent on the same page where you previously provided it or clicking the "unsubscribe" link provided in every marketing email.
8. Miscellaneous
8.1. Where you provide us with data about another person (e.g., your attorney, executor, or beneficiary), you should give that person a copy of or a link to this Privacy Policy and, in particular, inform him/her how we may use his/her data.
8.2. The minimum age to create a User Account on the Platform is 18. We will not knowingly collect Personal Data from persons under the age of 18.
8.3. Nothing in this Privacy Policy shall limit your rights as a Data Subject under the PDPO.
8.4. To the extent permitted by law, the Company and other members of the Regtitude Group may record electronic communications with you to ensure compliance with legal and regulatory obligations and internal policies for the purposes outlined in this Privacy Policy.
8.5. This Privacy Policy shall be deemed an integral part of all contracts, agreements, documents creation and storage, account opening documents, and other binding arrangements which you have entered into or intend to enter into with us.
8.6. We cannot fully guarantee the security of your Personal Data because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Data over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Data on a secure device within a secure environment.
9. Data Access Requests
9.1. You have the right:
(a) to check whether we hold data about you and to request access to such data;
(b) to require us to correct any data relating to you which is inaccurate;
(c) to ascertain our policies and practices in relation to data and to be informed of the kind of personal data held by us;
(d) in relation to uploaded documents, to delete the uploaded documents or to change the access rights of others to your uploaded documents.
9.2. In accordance with the provisions of the PDPO, we have the right to charge a reasonable fee for the processing of any data access request.
9.3. You should send requests for access to data, correction of data, or information regarding policies and practices and kinds of data held to:
Regtitude Limited
31/F., Tower 5,
The Gateway, Harbour City,
Tsim Sha Tsui,
Hong Kong
Attention: Ruby Chan, Privacy Officer
10. Revision Date
This Policy was most recently revised on 8 August 2024 ("Revision Date"). If you were a user prior to the Revision Date, this Policy replaces the previous one.
© 2024 by Regtitude Limited | Terms and Conditons
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