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Privacy Policy
1. GENERAL PROVISIONS
1.1 This Privacy Policy (the"Policy") defines the procedure for collecting, processing, storing and protecting personal data of site users upt.ai/ and related mobile applications and services (hereinafter referred to as the "Services") provided by UpT AI Limited (hereinafter referred to as "UpT AI", "we", "us", "our").
1.2 Legal basis. This Policy has been developed in accordance with:
- The Hong Kong Personal Data (Privacy)) Ordinance, Cap. 486 ("PDPO");
- Принципами защиты Data Protection Principles ("DPP");
- General Data Protection Regulation of the European Union (GDPR) — for users from the EU.
UpT AI Limited
No. 5,17th Floor, STRAND 50, 50 BONHAM STRAND, Shunwan, Hong Kong
Email: _________________.
1.4 Representative to the EU on GDPR issues: _______________.
1.5 By accepting this Policy(at the time of registration or using the Services), you confirm your consent to the terms of processing your personal data described below.
2. DEFINITIONS
2.1 "Personal data"means any information related directly or indirectly to a specific or identifiable individual (subject of personal data), including name, email address, IP address, device data, etc.
2.2 "Personal data processing"means any action with personal data: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, destruction.
2.3 "Cookies"— small text files placed on your device when you visit our site to provide functionality, behavior analysis and personalization.
3. WHAT DATA DO WE COLLECT
3.1 Data that you provide to us voluntarily:
Data Category | Examples |
Registration data | Name, Email address, Password |
Profile information | Age, gender, country of residence, profile picture |
User content | Videos, comments, messages, files uploaded to Services |
Payment data | Payment information (processed through third-party payment providers, we do not store bank card data) |
Feedback | Support messages, survey responses, and reviews |
3.2 Data collected automatically when using the Services:
- Technical data: IP address, browser type and version, operating system, device model, and unique device identifiers.
- Usage data: date and time of the session, pages viewed, time on the page, clicks, click-throughs, and history of interaction with Services.
- Location data: general geographical location (at the city/country level) based on the IP address (if you allowed access to geodata in the device settings).
- Файлы Cookies and similar technologies: For more information, see our Cookie Policycookie.
- From payment systems — payment confirmation, transaction status.
- From analytical services — aggregated usage statistics.
- From partners — if you came to us via an affiliate link.
4. PURPOSES OF DATA COLLECTION AND PROCESSING
We process your personal data only if there are legal grounds provided for in the PDPO and GDPR:
Purpose of processing | Legal Basis (GDPR) | Data Categories |
Creating and managing your Account | Executing a contract (Article 6 (1) (b)GDPR) | Registration data |
Provision of access to the Services and their functioning | Performance of the contract (Article 6 (1) (b)GDPR) | All categories of data required for the provision of the service |
Technical support and responses to requests | Performance of the contract; legitimate interests (Article 6 (1) (f)GDPR) | Contact details, contact history |
Improvement of Services, usage analysis, development of new functions | Legitimate interests (Article 6 (1) (f)GDPR) | Technical data, usage |
data Security, fraud prevention | Legitimate interests (Article 6 (1) (f)GDPR) | Technical data, IP addresses, usage data |
Marketing communications (newsletters) | Your consent (Article 6 (1) (a) GDPR) | Name, email address |
Compliance with legal obligations | Legal obligation (Article 6 (1) © GDPR) | Data required by law (for example, for tax authorities) |
5. LEGAL BASIS FOR PROCESSING
5.1 Execution of the agreement. Processing is necessary for entering into and executing a contract with you (creating an Account, providing Services).
5.2 Legitimate interests. We process your data for:
- ensuring the security of our Services;
- improve the quality of service.
- prevention of fraud and abuse;
- analytics and statistics (in depersonalized form).
5.4 Legal obligations. The processing is necessary to comply with the laws of Hong Kong and other applicable jurisdictions.
6. COOKIES AND SIMILAR TECHNOLOGIES
For more detailed information about the types of cookies, their purpose, and retention periods, please refer to our Privacy Policy.The Cookie policycookie.
7. TRANSFER OF DATA TO THIRD PARTIES
7.1 We do not sell your personal data to third parties.
7.2 We may share your data with the following categories of recipients:
Recipient category | Transfer target |
Technical contractors (hosting providers, cloud services) | Ensuring the operation of Services |
Analytical services (Google Analytics and analogs) | Usage analysis, service improvement |
Payment systems | Payment processing, fraud prevention |
Professional consultants (lawyers, auditors) | Consulting services, protecting the rights |
of Government agencies | Based on legitimate requests under Hong Kong law |
7.3 Agreements with third parties. All third parties to whom we transfer data for processing on our behalf undertake to comply with the requirements of the PDPO and the GDPR and enter into relevant Data Processing Agreements with usAgreements, including the obligations provided for in Article 28 of the GDPR.
8. CROSS-BORDER DATA TRANSFER
8.1 Your personal data may be transferred and processed in countries outside the European Economic Area (EEA), including: Hong Kong (Special Administrative Region of China), where our servers are located and our activities are carried out.
8.2 When transferring data outside the EEA, we provide an appropriate level of protection by:
- Standard Contractual Provisions (SCCS) approved by the European Commission;
- decisions of the European Commission on the adequate level of protection (where applicable);
- other mechanisms permitted by the GDPR.
9. DATA RETENTION PERIODS
9.1 We only store your personal data for as long as it is necessary to fulfill the purposes for which it was collected or to comply with legal requirements.
9.2 Estimated storage periods:
Data type | Retention period |
Active Account | data For the entire Account validity period + 30 days after deletion (for technical completion) |
Data from deleted Accounts | will be deleted or depersonalized within 90 days of deletion, except for data that must be stored longer by law |
Payment Information and data related to financial transactions | for up to 7 years (in accordance with the requirements of Hong Kong tax law) |
Logs of support | requests Up to 24 months after the last interaction |
Marketing data (subject to consent) | Prior to revocation of consent or termination of interaction + 12 months |
9.3 After the retention period expires, the data is safely deleted or depersonalized.
10. YOUR RIGHTS
10.1 Rights of Hong Kong residents (according to the PDPO):
Right | Description |
Right of access | You can request a copy of your data that we process |
Right to rectification | You can request that inaccurate or incomplete data be corrected |
10.2 Additional rights of EU residents (in accordance with the GDPR):
Right | Description |
Right to erasure ("right to be forgotten") | You can request the deletion of your data under certain circumstances |
Right to restrict processing | You can request the suspension of processing of your data |
Right to data portability | You can request the transfer of your data to you or another controller in a structured, machine-readable format |
Right to object | You can object to the processing of your data based on our legitimate interests |
Right to withdraw consent | You you have the right to withdraw your consent at any time |
10.3 How to exercise your rights:
- To exercise your rights, please contact us at: _______________(A representative contact is also available for EU residents: __________________).
- We will respond to your request within 40 days (according to PDPO requirements) or within one month(according to GDPR).
- Data access requests may be subject to a reasonable fee in accordance with the PDPO; data correction requests are free of charge.
- You also have the right to file a complaint with the Hong Kong Data Protection Commissioner’s Office (PCPD) or your country’s data protection supervisory authority (for EU residents).
11. DATA SECURITY
11.1 We take all necessary technical and organizational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
11.2 These measures include:
- data transfer encryption (SSL/TLS);
- data encryption during storage.
- firewalls and intrusion detection systems;
- strict data access control based on theneed-to-know basis;
- regular testing of security systems.
- relevant supervisory authority (Hong Kong PCPD and / or EU authority) within 72 hours from the moment when we became aware of this;
- you directly without undue delay if the leak poses a high risk to your rights.
12. CHILDREN
12.1 Our Services are not intended for persons under the age of 13. We do not knowingly collect personal data from children under the age of 13. If we become aware that we have collected a child’s data without parental consent, we will take steps to delete such information.
13. CHANGES TO THE PRIVACY POLICY
13.1 We may update this Policy periodically. In case of significant changes, we will notify you:
- by email (to the address specified in your Account).
- via a notification on the site or in the app.
14. CONTACT INFORMATION
14.1 General questions and user support:
Email: ________________.
14.2 Privacy and Data Protection Issues (GDPR):
Email: ________________.
EU Representative for GDPR issues: ___________________.
14.3 Postal address for legal notifications:
UpT AI Limited, No. 5,17th Floor, STRAND 50, 50 BONHAM STRAND, Sheung Wan Hong Kong