1. Our commitment to protect your privacy

At Our Company, we are committed to protecting your Personal Data and your privacy. To ensure that you can make informed decisions and feel confident about sharing certain personal information with us, please read this Privacy Policy to understand who we share your Personal Data with and for what purposes, and the choices you have concerning how your Personal Data is collected and used by us. We may also provide further privacy collection notices highlighting certain uses of your Personal Data, together with the ability to opt in or out of certain uses, when we collect Personal Data from you. The laws of certain countries require us to provide you with additional information about our processing activities and we have included separate appendices to deal with these. As well as this document, please refer to the appendices which apply to you. We will notify you of any changes to our Privacy Policy, including by posting the revised policy on www.Our Company-app.com. The changes will be effective from the date of posting. We endeavor to ensure that all our collection, transmission, storage and usage of personal data is carried out in compliance with the Personal Data (Privacy) Ordinance, Cap 486 of the laws of the Hong Kong Special Administrative Region. By providing your personal data to us, you are consenting to this Privacy Policy.

2. The information we collect

2.1 We will collect and process some or all of the following Personal Data about you:
(a) Information about you and your membership: Your personal information such as your name, email address, contact phone number, your order details, your username, your account credentials and records of your earning and redemption activities;
(b) Location information: Your last known location, location of service;
(c) Your payment details: Payment details used to proceed order payment such as card holder name, credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information;
(d) Information we collect in relation to your car: Information about your car, including the car make, car model, license number, plate number, colour, chasis number, vehicle registration number, total mileage of your car, daily mileage of your car and other details of your car including information of car parts;
(e) Information you provide in the ordering process through Our Company: Your personal information provided when you use the features and functions available in our services, for example, by creating car profile, interacting with car service and product providers through our chat feature, or transacting with other car service and product providers;
(f) Our interactions with you: A record of any interactions and correspondence between us such as making a query or reporting a problem in our Services, emails between you and our representatives, any interactions you have with our staff or representatives for research (e.g. conversations with research interviewer), and any interactions with us or posts that refer to us on social media;
(g) Information we collect in marketing or promotional events: When you register for a survey, campaign, contest and/or lucky draw with us;
(h) Our interactions with you: When you interact with us offline or through an external third party;
(i) Any other information disclosed by you in any of the above-mentioned methods and/or through the use our Services; and
(j) Aggregate data collected through the use of our Services.

2.2 You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you.

2.3 By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent to us that you have obtained the consent of the third party to provide us with their information for the respective purposes.

3. How we collect your information

3.1 We will collect some Personal Data from you directly. We will collect other Personal Data from third parties including:
(a) our Services and our website;
(b) our service providers and agents such as our call centre agents who provide customer service;
(c) our third party marketing and research partners;
(d) organisations which conduct credit and fraud checks; and
(e) providers of third party websites, apps and social media platforms.

3.2 If you provide us with information about other individuals such as details of your car and your order details, you must tell those individuals and let them know where they can find a copy of this Privacy Policy.

4. Your interactions with others

Our Services offer features which allow users to connect and communicate in groups which are public or semi-public, and to share information with each other to complete a transaction. Please use common sense and exercise good judgement when sharing information in these groups or with others. We generally do not monitor or remove the information which you share and such information may remain available on our Services after your Account has been deactivated, terminated or is otherwise closed. You are responsible for the information you choose to share in these groups or with other users.

5. How we use the information we collect

We may use the information collected and received from you for the following purposes:
(a) To verify your identity, update our records and generally maintain your Account with us.
(b) To provide our Services and customise the content shown to you.
(c) T develop, operate, improve, deliver and maintain our Services.
(d) To provide support such as responding to your queries and resolving complaints.
(e) For research purpose: Carry out polls, surveys, analysis and research on how our Services are being used and how we can improve them.
(f) To update you on your listings and our Services (e.g. new offers, new chats, new feedback, new comments). These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates at any time through the Settings page of your Account.
(g) To send you marketing and/or promotional materials on the latest products and services of Our Company or carefully selected third parties. These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates through the Settings page of your Account. These updates may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods.
(h) To send you service-related messages including, without limitation, a welcome/confirmation email when you register your Account and to enforce our Terms of Service and other policies. These messages are not promotional in nature. These messages will be sent by email and/or through push notifications and you may not opt-out of receiving service-related messages from Our Company, unless you deactivate your account.
(i) Perform functions or services as otherwise notified to you at the time of collection.
(j) To provide you a more tailored online advertising experience. Our Company has in place, tools and services are used to create advertisements, to deliver advertisements to devices on behalf of advertisers, to monitor the success of and manage advertising campaigns, and to present you with advertisements that are more likely to be interesting and relevant to you. Delivering relevant ads that are tailored to users’ interests is known as interest based advertising (sometimes also referred to as behavioural advertising). For more information on interest-based advertising, including to understand what opting-out means and your opt out choices for your devices, including computer browsers and mobile browsers and devices, please see the Section 11 Our Company Opt-Out below.
(k) If you are a member of our survey panel, your information may also be used to manage your panel membership; send you service-related messages, new survey opportunities and, updates on your rewards and incentives. These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates through the relevant email and/or Settings page of your Account. These updates may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods.
(l) To provide and carry out cross-application and cross-device advertising (i.e.advertising across browsers and applications on a single device, as well as cross-device advertising), advertising delivery and reporting. Information include information described above and data and collected from a particular computer, browser or device and may be used with another computer, browser or device that is linked to the computer, browser or device on which such data was collected.
(m) For legal and administrative purposes: For legal and administrative purposes such as to comply with our legal and regulatory obligations, verifying and processing payment, screening against fraud, criminal or unlawful activities, or abusive redemption activities and identify suspicious membership accounts that may breach the Asia Miles Terms & Conditions, accounting, billing and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.

6. Who we share your information with

6.1 We may share information about you in the following ways:
(a) When you register for an Account, the information which you make available on your profile may be viewed by other car service and product providers of our Services. Other users of our Services would also be able to view the content which you upload and share on our Services.
(b) We may share the information with our affiliates and with third party service providers who assist us in performing certain aspects of our Services on our behalf, such as processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks. Such service providers will only have access to your personal information to the extent necessary to perform their functions.
(c) We may share the information with our potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.
(d) In addition to other information described in this Privacy Policy, we may collect and share with third party data management platforms or advertising and analytics partners precise location information. This location information may be used by itself, aggregated, or combined with mobile identifiers, and shared with third parties for purposes related to advertising, analytics, attribution (e.g., measuring ad performance), analytics and market research.
(e) We may disclose your Personal Data to governments and regulatory authorities and bodies and to other individuals, bodies and organisations such as dispute resolution, prosecution and law enforcement bodies, legal advisers, organisations which conduct credit and fraud checks, and other individuals, bodies and organisations for the purposes of complying with our legal obligations. We may also disclose your Personal Data to such individuals, bodies and organisations to enable us to provide our travel and lifestyle awards to you and otherwise for legal and administrative purposes.

6.2 We respect your privacy and we will not sell your personal information to any third party. We may disclose data and aggregate statistics about users of our Services and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted advertisements or for other lawful purposes, but these data and statistics will not include information which can be used to identify you.

7. Transmission, storage and security of your information

7.1 By using our Services, you authorise us to use your information in Hong Kong and other countries where Our Company operates for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection.

7.2 No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.

7.3 All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile applications, we ask you not to share your password with anyone.

7.4 Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.

7.5 We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.

8. Protecting your information

The security of your information is important to us. We have security measures in place to protect against the loss, misuse and alteration of information under our control. We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

It is important that you protect against unauthorised access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

9. Accessing and updating your information

9.1 You may access and update your information within our Services.
9.2 Where you provide personal information about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.
9.3 In certain circumstances, you may need to provide to us personal information about someone other than yourself. If so, we rely on you to inform these individuals that you are providing their personal information to Our Company, to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Policy.
9.4 Right to opt out of direct marketing: You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by following the opt out instructions contained in the relevant communications.
9.5 We will take reasonable steps to try and ensure that your Personal Data is accurate. To help us do this, please notify us of any changes to your Personal Data.
9.6 If you wish to:
(a) apply for a copy of the information we hold about you; or
(b) withdraw consent you previously provided to us to use, collect or disclose the information we hold about you,

please contact our Personal Data Protection Officer at the contact details set out in Section 14 below.

Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so.

Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.

9.7 If you wish to delete your personal information please contact us via email.

10. Tracking technologies

We use tracking technologies on our Services.These enable us to understand how you use our Services which, in turn, helps us to provide and improve our Services. However, the tracking technologies do not access, receive or collect information which can be used to identify you. For example, we use Cookies on our Services. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Services, estimate and report our Service's total audience size and traffic, and conduct research to improve our Services. You can configure your device's settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of our Services.

11. Marketing

11.1 We may communicate marketing, promotions and research invitations to you by post, telephone, or online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.
11.2 We may deliver personalised and/or targeted advertisements (each, a Targeted Ad) to you in the course of your use of our Services and/or though a variety of advertising networks and exchanges.
11.3 You may opt out of behavioural tracking and/or interest-based advertising through our Platforms. Your changes to such opt-out setting may take 24 hours to become effective.
11.4 Please note that if you choose to opt out, we will not use information we have collected about you to deliver Targeted Ads, but it does not opt you out of being delivered advertisements. You will still receive generic, non-targeted advertisements. You may still be served advertisements for other reasons, such as: Your age, gender or location.Personalised and/or targeted advertisements from other third parties and not delivered by Our Company through your mobile and/or web activities.
11.5 Please also note that even though Our Company does not share your personal data (other than hashed or device identifiers, to the extent they are personal data in some countries) with any advertising networks and exchanges without your consent or unless as specified in this Privacy Policy, when you view or interact with an advertisement via any of your devices, an advertiser or advertising network or exchanges can infer that you are within their target audience; or when you click on an advertisement, the publisher and/or advertiser will know you visited the page that you clicked on and may still be able to associate personal data collected by such third parties directly from you through their cookies and similar tracking technologies.

12. Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time and all changes will be posted here. If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by email. With or without any notices, all changes made will be valid and effective upon posting. You are responsible for reviewing the changes which we make this Privacy Policy. Your continued use of our Services constitutes your acceptance of the updated Privacy Policy.

13. Third party sites and resources

Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over, and hence, not liable for the content and privacy practices of such sites or resources. By activating a link, such as for example by clicking on the banner of an advertiser, you leave our website and we do not exercise control over any personal data or any other information you give to any other entity after you have left our website. Access to and use of such other websites is at your own risk. You are advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

14. Contact us

If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us by sending an email. Your indication at the subject header would assist us in attending to your email speedily by passing it on to the relevant staff in our organisation. For example, you could insert the subject header as Accessing Personal Data.