Privacy Policy

Softtop Limited ("Softtop", "we", "us" or "our") is the controller and responsible for your personal data. This privacy policy aims to give you information on how Softtop collects and processes your personal data through your use of this website, including any data you may provide when you purchase a product or service or sign up to our newsletter.

If you have any questions about this privacy policy, please contact us at info@softtop.tech or call +1 805 600 0925. You have the right to make a complaint at any time to the Privacy Commissioner for Personal Data in Hong Kong. Your use of our platform is also subject to our Terms & Conditions.

We keep our privacy policy under regular review. This version was last updated on 13 February 2024. Historic versions can be obtained by contacting us. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites and are not responsible for their privacy statements. For details on how we protect your data on our own platform, see our Security page. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

• Identity Data — first name, last name, username, title, date of birth and gender.
• Contact Data — billing address, delivery address, email address and telephone numbers.
• Financial Data — bank account and payment card details.
• Transaction Data — details about payments to and from you and products/services you have purchased.
• Technical Data — IP address, browser type and version, time zone, browser plug-in types, operating system and platform.
• Profile Data — username and password, purchases or orders, interests, preferences, feedback and survey responses.
• Usage Data — information about how you use our website, products and services.
• Marketing & Communications Data — your preferences in receiving marketing from us and your communication preferences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a product or service you have with us and will notify you if this is the case.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us. This includes personal data you provide when you:

• Apply for our products or services
• Create an account on our website
• Subscribe to our service or publications
• Request marketing to be sent to you
• Enter a competition, promotion or survey
• Give us feedback or contact us

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns via cookies, server logs and other similar technologies.

• Technical Data from analytics providers such as Google, advertising networks, and search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators and publicly available sources such as Companies House and the Electoral Register.

We will only use your personal data when the law allows us to — most commonly where we need to perform a contract, where it is necessary for our legitimate interests, or where we need to comply with a legal obligation.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what may be of interest to you. You will receive marketing communications from us if you have requested information or purchased goods and services from us and have not opted out.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message or by contacting us directly. This will not apply to personal data provided as a result of a product/service purchase or other transactions.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis.

We may share your personal data with the following parties for the purposes set out in this policy:

• Internal parties — our employees, affiliates, contractors and specifically authorised individuals who need the information to provide our products and services.
• Service providers — processors based in Hong Kong and outside Hong Kong who provide IT and system administration services.
• Professional advisers — lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and authorities — HM Revenue & Customs and other authorities who require reporting of processing activities in certain circumstances.
• Business transfers — third parties in connection with a merger, acquisition, or sale of assets, with the new owners obligated to honour this policy.

We share your personal data within Softtop Limited. This will involve transferring your data outside the European Economic Area (EEA). Whenever we transfer personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• Transfers only to countries deemed to provide an adequate level of protection by the European Commission.
• Use of specific contracts (Standard Contractual Clauses) approved by the European Commission which give personal data the same protection it has in Europe.
• Where using US-based providers, ensuring they participate in the EU-US Privacy Shield framework.

Contact us at info@softtop.tech if you want further information on the specific mechanism used when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to your personal data is limited to those employees, agents, contractors and other third parties who have a business need to know — they will only process your personal data on our instructions and are subject to a duty of confidentiality.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data (see Your Legal Rights below). In some circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice.

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

You will not have to pay a fee to access your personal data or exercise any other right. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, it could take longer — in this case, we will notify you and keep you updated.

To exercise any of these rights, contact us at info@softtop.tech.

• Legitimate Interest — the interest of our business in conducting and managing our business to give you the best service and most secure experience. We always consider and balance any potential impact on you before we process your personal data for legitimate interests.
• Performance of Contract — processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a Legal Obligation — processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

• Service providers based in Hong Kong and outside Hong Kong providing IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers providing consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

If you have any questions about this privacy policy or how we handle your personal information, please reach out. We would appreciate the chance to deal with your concerns before you approach any regulatory body.