Privacy Policy

Introduction

Hieroglyph Digital Technology Limited (hereinafter referred to as the “Company”, “we” or “us”) is a blockchain innovation company, providing institutions and their data assets with encryption, storage and management services by operating Cinfinix mobile application (“Cinfinix“).

This privacy policy (the “Privacy Policy”) sets out how we collect, store and use your personal data in compliance with the applicable laws and regulations in Hong Kong . This Privacy Policy is a binding contract and you must agree to it to the same extent as our Terms of Use in order to use our services. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This Privacy Policy does not cover personal data (if any) that may be collected from elsewhere, including but not limited to any offline and other sites linked to and from Cinfinix, as well as the practices of third parties that the Company does not control or own, or individuals that the Company does not employ or manage.

Consent to Installation of Cinfinix

By using Cinfinix, submitting information or using any of our products and/or services, you are agreeing with and accepting the terms and the practices outlined in this Privacy Policy and it is your duty to inform us of any change in the information. If you do not agree with or accept this Privacy Policy, please do not use Cinfinix, provide information to us or use our products and/or services.

Retention and Security of Personal Data

Your personal data will be kept confidential as we will take reasonably practical steps to protect your personal data that is kept for longer than necessary and we will comply with all statutory and regulatory requirements in Hong Kong concerning retention of personal data. Any personal data that is no longer needed to fulfill the purposes stated in this Privacy Policy, the personal data will be destroyed .

We adopt appropriate measures to protect and safeguard the security of your personal data collected by us against loss, unauthorized access, use, modification or disclosure using reasonable endeavours.

Our protective measures include:

Electronic measures: the computer systems and storage media for storing your personal data are subject to strict login restrictions;
Management measures: only responsible employees duly authorized by us can have access to your personal data, and such employees shall comply with our internal rules concerning personal data confidentiality;
Technical measures: we use encryption techniques where necessary to convey your personal data; and
Other measures: our network servers are protected by proper firewall.

Despite our protective measures, we cannot guarantee that the information transmitted via Cinfinix is absolutely safe, so we cannot absolutely guarantee that the personal data that you provide to us through Cinfinix will be safe at any time. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and we shall not be held liable for compensation for such loss or damage.

Personal Data You Provide To Us

Cinfinix generally collects personally identifying information (such as, for example, email address, contact address, etc.) with your specific knowledge and consent. This includes but is not limited to creating an account with us, using any of our services, making an in-app purchase on Cinfinix, sharing data via Cinfinix’s social media function, conducting any activities on Cinfinix, entering a raffle sweepstakes or giveaway and completing a survey, etc. You can choose not to provide us with certain personal data, but we may not be able to process your applications, or you may not be able to take advantage of many of our special features. When you consent to provide us with your personal data, you will also grant us your consent to share your personal data with the third parties who may be involved in the provision of any of our services, including but not limited to, the relevant application store provider, your mobile network operator and the payment-process services provider (if any).

You have the right to request access to your personal data, and request correction of any of your personal data which is incorrect subject to the charge of a reasonable fee by us for processing and complying with your data access request. For any requests for access to or correction of your personal data, please contact us based on the details set out in the “Contact” of this Privacy Policy below. For deletion of your personal data, you can trigger “Cancel Account” function in the “Account and Security” of the App. When you cancel your account, we will delete your personal data and posts.

Public Areas

When you post, contribute or share any content to the public area of Cinfinix, the content you submit will be made available to the general public. To protect your privacy, we would recommend that you should exercise caution when submitting, sharing or posting on such public area any personal data or sensitive information, including but not limited to your full name, address, phone number, or any other information that would allow other users or third parties to locate you or obtain information about you. You are entirely responsible for your use of Cinfinix, for all contents that you submit or post on Cinfinix and any activities that occur under your account, and for ensuring, protecting and safeguarding the confidentiality and the security of your account. We shall not be held liable for any claim, loss or damage resulting from a breach of the foregoing, your use of and contributions on Cinfinix, or any unauthorized use of your account.

Automatic Information

Our servers may automatically collect automatic and/or aggregate information about your computer or electronic device when you visit Cinfinix , including but not limited to the website and mobile app that referred you, Internet Protocol (“IP”) address, the type and configuration of the internet browser of your computer or electronic device, browsing preference (such as language settings and font size, geo-location information and operating system of the computer or electronic device used for accessing our websites), and other usage and traffic information (the “Automatic Information”). We use the Automatic Information to analyze trends, gather and prepare statistics or demographic information and administer Cinfinix so that we may provide improved web experiences to you. Such Automatic Information is not personal data as it is collected in a manner that would not identify you personally.

We may provide the Automatic Information to our partners, agents, contractors or service providers to show how our users collectively use Cinfinix. We may share the Automatic Information with our partners for improving your user experience on Cinifinx and other products and/or services provided by us. For the avoidance of doubt, this Privacy Policy in no way restricts or limits our collection, transfer and use of any Automatic Information.

Permitted Disclosure of Information

If we are legally required to disclose data collected by us or provide access to our database in order to cooperate with police investigations, legal proceedings, or otherwise to comply with any applicable laws or regulations, court order or lawful requests from any government authority in Hong Kong, we are permitted to disclose or provide such data for such purpose without prior notice to or consent by you.

Collection, Use and Storage of Personal Data

We may collect, use and/or store your personal data for any of the following purposes, including:

To enhance or improve user experience, Cinfinix, our products and/or services, or to facilitate our performance of our services or any services offered on Cinfinix;
To administer and protect our business and Cinfinix through means including troubleshooting, data analysis and system testing;
To register, verify, process and maintain membership programs for our users;
To process, verify, operate, manage, administer and maintain gaming experience for our users;
To create an online marketplace where users can communicate directly and negotiate transactions of goods and services;
To provide you with promotional materials or conduct direct marketing if you provide your consent or do not object in writing;
To provide your personal data to another person or entity for its use in direct marketing if you provide your consent or do not object in writing;
To process in-app purchases and deliver services including managing payments and collecting money owed to us;
To conduct and process any contests, raffle sweepstakes, giveaways and/or surveys that we may from time to time organize in relation to Cinfinix, our business, products and/or services, and to announce the winners of the relevant contests and/or sweepstakes (as the case may be) on Cinfinix or any other medium/channels as may be required under the applicable laws in Hong Kong;
To detect, investigate, identify and protect against and/or prevent fraudulent transactions and other misuses of our websites and/or other activities on Cinfinix which may violate our Privacy Policy and/or Terms of Use or may be illegal;
To enforce this Privacy Policy ; and
To comply with or as permitted by any applicable laws or regulations, court order or lawful request from any government authority in Hong Kong.

To facilitate the purposes set out in the paragraph above, we may transfer, disclose, grant access to or share your personal data with any of our subsidiaries, holding companies, associated or affiliated companies, agents, contractors, service providers and business partners that we gather when you are on Cinfinix and when you are using our services. Also, this Privacy Policy covers the use of any personal data that our business partners may share with us.

Direct Marketing

Subject to your express consent or no objection in accordance with local privacy laws, we may use your personal data including your name, contact details (such as phone number, email address and mailing address), account and transaction information to send you news, offers, promotions and joint marketing offers about products, services and offers and promotional campaigns provided or hosted by us or our co-branding, rewards or loyalty programme partners, charities or other third party financial institutions and service providers .

You may withdraw your consent or no objection at any time by contacting us based on the details set out in the “Contact” of this Privacy Policy below. The withdrawal of your consent or no objection will be processed and will take effect as soon as practicable.

Cookies

In order to distinguish you from other users—especially other users on the same network as you— we would use cookies to track your specific computer or electronic device. Cookies are small computer text files that are sent from a website and mobile app to the browser of your computer or electronic device and are stored on your device. The information collected by cookies is anonymous visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No customer personal data is stored in cookies . Cookies are used by websites that you visit and browse to improve your website and mobile app browsing experience and provide the website and mobile app operators with non-personal data or analytical information to improve the quality of the websites and mobile app, and the browsing experience of the websites and mobile app. For example, we use cookies to save your device’s browsing preferences and settings. For these reasons we require you to keep cookies enabled when using Cinfinix and our websites. Additionally, our cookies may be accessible by third parties or be provided to third parties including, for example, Google via Google AdSense on Cinfinix. We do not have any control over and are not responsible or liable for such third parties’ collection and use of the cookies. Please refer to those third parties’ relevant policies regarding their collection and use of cookies for further information.

Please note that you have the right to disable cookies on your computer or electronic device. Disabling any or all cookies function on your computer or electronic device may lead to improper functioning of some features and functionality of Cinfinix.

Third Party Websites

Cinfinix may contain links to third party websites, advertisers or services that are not owned or controlled by us. If you wish to access to a third party website or mobile app via Cinfinix, you should do so at your own risk and you understand that neither this Privacy Policy nor our Terms of Use apply to your use of such sites. We have no control over and assume no responsibility for the content, privacy policies or practices of any provider of third party websites, advertisements or services or their use of your personal data and the provider of such third party websites, advertisements or services should undertake the duty to safeguard your personal data provided to them. You should review the privacy policies and terms of use in relation to such third party website and mobile app, advertisements or services that you visit or use before accessing to and providing your personal data, and we shall not be liable in relation to your activities on or with such third party websites, advertisers or services.

Amendments

We may amend this Privacy Policy from time to time, and the amended version will be posted on Cinfinix which shall supersede any previous versions. Any changes to this Privacy Policy will become effective as soon as the changes are published on Cinfinix. Your continued access of Cinfinix, provision of your personal data to us or continued use of our products or services (as the case may be) after the posting of any revised Privacy Policy by us will constitute your acceptance of the changes or revisions to the Privacy Policy and your agreement to be bound by such changes or revisions.

If you do not agree with the revised or updated Privacy Policy, you must notify us in writing and immediately cease using Cinfinix and our products or services.

Validity

If any clause of this Privacy Policy is held to be invalid or unenforceable for any reason under any applicable laws, rules or regulation or any court of competent jurisdiction in Hong Kong, such clause shall be deemed to be severed from this Privacy Policy. Such unenforceability or invalidity shall not in any way affect the enforceability and/or validity of the remaining clauses of this Privacy Policy which shall continue to be in full force and effect.

Contact

If you are aware of or suspect of any leakage of personal data on Cinfinix, please contact us immediately so that we can take appropriate action as soon as possible. Any inquiries about your rights under this Privacy Policy, or any other matters regarding your privacy, can be directed to [email protected]. You have the right to request access to and/or correction of your personal data held by us. If you wish to make such request, please contact us by email marking “Attention: Personal Data Access / Correction Request” on your correspondence.

If there is any inconsistency between the English and Chinese versions of this Privacy Policy, the English version will prevail.