1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE.

The categories of information we collect can include:

• Information you provide to us directly: We may collect personal information such as a username, first and last name, location, phone number, e-mail address, photo, and payment information when you register for a Apoidea website account correspond with us, or otherwise provide us your information. In time, we may permit you to provide additional personal data in your profile.
• Information we collect from third parties: We may collect information about you from third party services. For example, we may receive information about you when you interact with our site through various social media, for example, by logging in through or liking us on Facebook or following us on Twitter. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on such third-party websites and services before linking or connecting them to our website.
• Sharing Information: With your permission, we may collect email address or contact information of people you provide to us when you want to share our content or invite your friends and contacts to connect with our Service. When we invite your friends to join the Service, we will include your name and photo to let them know that you are the person extending the invitation. After sending these invitations, we may also send reminder emails to your invitees on your behalf. We may send invitations or other promotional materials to these contacts.
• How we use this information: We use this information to operate, maintain, and provide to you the features of the Service. We may use this information to communicate with you, such as to send you email messages, and to follow up with you to offer information about our service (our “Service”) and your account. We may also send you emails or messages related to our website or Service (e.g., account verification, payment summaries, change or updates to features of the website). For more information about your communication preferences, see “Your Choices Regarding Your Information” below.
  

For personal data subject to the GDPR, we rely on several legal bases to process the data. These legal bases include where:

• The processing is necessary to perform our contractual obligations in our Terms of Service or other contracts with you (such as to provide you the Service as described in our Terms of Service);
• You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
• The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
• The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.

If you have any questions about or would like further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION.

We and our third party partners may automatically collect certain types of usage information when you visit our website. For instance, when you visit our websites, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use our website (e.g., the pages you view, the links you click, how frequently you access our website, and other actions you take on our website), and allow us to track your usage of our website over time. We may collect log file information about your browser or mobile device each time you access our website. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on our website, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our website. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are not able to respond to Do Not Track signals from your browser at this time.

We may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content, including targeted advertising; (c) provide and monitor the effectiveness of our website; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Service or website.

3. SHARING OF YOUR INFORMATION

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Your Choices About Your Information” section below.

We may share your personal information with:

• Other companies owned by or under common ownership with Speechless Financial. These companies will use your personal information in the same way as we can under this Privacy Policy;
• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, billing, payment processing, email services, or providing analytic services;
• Our business partners who offer a service to you jointly with us, or who partner with us to provide our services to you;
• Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of a bankruptcy or related or similar proceedings; and
• The public, if you are a Contributor we may share your name, photograph and biography on our website and in promotional material.
• Third parties as required by law or subpoena or to if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our website; and/or (c) to exercise or protect the rights, property, or personal safety of Speechless Financial, our users, or others.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

4. YOUR CHOICES ABOUT YOUR INFORMATION

How to control your communications preferences:You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, payment confirmation, changes/updates to our products or features, technical and security notices.)

Modifying or deleting your information:If you have any questions about reviewing, modifying or deleting your account information, you can contact us directly at legal@apoidea.ai.

5. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION IF YOU ARE RESIDENT IN THE EU AND SWITZERLAND
If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

• Right of access. The right to obtain access to your personal data.
• Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
• Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
• Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
• Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

6. HOW WE STORE AND PROTECT YOUR INFORMATION

Storage and Processing:Speechless Financial is located in Hong Kong. Your information collected through our website will be stored and processed in Hong Kong or any other country in which Speechless Financial or its subsidiaries, affiliates or service providers maintain facilities.

Keeping your information safe:Speechless Financial cares about the security of your information, and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the website. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, Speechless Financial will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

7. CHILDREN’S PRIVACY

Speechless Financial does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at legal@apoidea.ai.

8. LINKS TO OTHER WEB SITES AND SERVICES

Our website may integrate with or contain links to other third party sites and services. We are not responsible for the practices employed by third party websites or services embedded in, linked to, or linked from our website and your interactions with any third-party website or service are subject to that third party’s own rules and policies.

9. HOW TO CONTACT US

If you have any questions about this Privacy Policy, the website or the Service, please contact us at 3007-3010 Kimberland Centre, 55 Wing Hong Street, Lai Chi Kok, Hong Kong.

10. CHANGES TO OUR PRIVACY POLICY

Speechless Financial may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy we will update the ‘last updated’ date at the top of this page.

Last updated: 12 September 2019