This Coverbase platform (“Platform”) is owned and operated by Cloudian International (Hong Kong) Limited (the “Company” or “We”). We respect personal data and are committed to full implementation and compliance with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486 (the “Ordinance”). This Policy applies to all Platform users whose personal data is collected, by whatever means, used and held by us.
2. Kinds of Personal Data Collected, Used and Held
2.1 Your name, username, email address, telephone number, fax number, contact person, location information, IP address, transaction record in the Platform, business profile, insurance policy number, and any documents and data that you choose to upload or made available to the Platform (including but not limited any contract documents and insurance policies) as well as any personal data and information contained therein will be collected, used and held by the Company.
2.2 You may provide us with your personal data of your own will. To sign up for an account and use this Platform, your username, email address, mobile phone number, IP address and transaction record in the Platform are regarded as mandatory. You will not be able to sign up for an account and access the features of the Platform if you do not provide the said mandatory data.
2.3 Apart from the information above, no other personal data will be collected by us.
2.4 You hereby represent and warrant that you shall NOT upload or make available any confidential information or trade secrets to the platform without the requisite consent or approval.
3. Purposes of the Personal Data are Held
3.1 We will use your personal data for the following purposes:
(a) Identification and Verification: verifying your identity for handling requests of access, correction and erasure of personal data;
(b) Provision of Services: operating, maintaining and providing our services (please refer to our website for the details of our services) and communicating with you in respect of the services by the Company to you, including but not limited to sending reminders to you;
(c) Account and Activity Handling: registering for an account and identity verification;
(d) Direct Marketing: using your personal data for direct marketing purposes and to share marketing information after we have obtained your consent;
(e) Statistics: carrying out statistics and data analysis on users’ patterns and preferences and measuring the effectiveness of advertisements, provided that such statistics will contain only anonymous data; and
(f) Security: preventing fraud and hacking and imposing related restrictions and account bans on violators.
3.2 Should you be under the age of 18, please obtain prior consent from your parents or guardians before providing your personal data.
4. Transfer of Personal Data
4.1 Apart from statutory requirements and/or the purposes stated hereinabove, the personal data we collected about you will not be transferred or disclosed to any other party without your prior approval.
5. Retention of Personal Data
5.1 We will retain all your personal data for so long as is necessary for the fulfilment of the purpose(s) for which it was collected and of the legal requirements.
5.2 If you desire to erase your personal data from our electronic databases after ceasing to use the Platform, please contact us.
5.3 Our information and data are stored and maintained in our electronic database, facilities, servers and back-up servers which may be located outside your country, where the legal protection and standard of security requirements may not be equivalent to the same provided by and legally required by the applicable laws and regulations of your country. You hereby expressly consent to our transferring, storing, maintaining and retaining all your information and data in our electronic databases, facilitates, servers and back-up servers located outside your country for the purposes referred to in Clause 3.
6. Accuracy and Change of Personal Data
In order to ensure the correctness of your personal data, particularly contact details, retained by the Company, you may receive our request for confirmation or verification. Please feel free to contact us for correction or a change of personal data.
7. Personal Data Handling and Security Measures
7.1 We have established security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data. All personnel that may access the data will be ensured to comply with the requirements of data protection.
7.2 Our security measures are listed below:
(a) Controls on password complexity, re-tries or resets are implemented to prevent passwords from being compromised;
(b) Advanced encryption technology is used to protect the safety of personal data (including names, email addresses, telephone numbers and etc) during transmission. Our SecureSocketLayer (SSL) system will prevent your data from being transmitted from unauthorized interception or access by third parties;
(c) Only the personnel that have been trained with the strict privacy guidelines and procedures are authorized to access or handle your personal data. Such personnel are accountable for non-compliance with the related obligations; and
(d) The security system will be reviewed regularly.
8. Limitation of Liability
8.1 We have implemented all reasonably practicable procedures, measures and steps to safeguard the security of your personal data. However, no method of transmission over the Internet, or method of electronic storage, is totally secure. We cannot guarantee absolute security.
9. Third-Party Websites
9.1 After clicking on an advertisement or a hyperlink button on this Platform, you may have left this Platform and entered the website of our advertising client, content provider, supplier, associated company or business partner. Your visit to these third parties’ websites is not protected by this Policy.
9.2 These third-parties’ websites are not owned or controlled by the Company. We have not authorized them to collect any personal data from you. Therefore, we are not responsible for any exposure of your data at these websites or losses arising from a third-party website’s practice or policy. Please contact the manager or owner of such websites directly for any enquiries or questions about their own privacy practices or policies.
10. Third-Party Payment Gateway
10.1 If you wish to make transactions via our Platform, you have to make the payment through a third-party payment gateway.
10.2 The third-party payment gateway is not owned or controlled by the Company. We have not authorized or requested the third-party payment gateway to collect any personal data from you. Therefore, we are not responsible for any exposure of your personal data with it. Please contact the manager or owner of the third-party payment gateway directly for any enquiries or questions about their own privacy practices or policies.
11.1 We may use “Cookies” to improve our internet service and enhance your online experience. Cookies are small files that are automatically stored on your web browser in your computer that can be retrieved by this Platform. The information collected by Cookies is anonymous visitors’ personalized settings information. We will not collect any personal data from you when the cookies are being used. You can disable cookies by changing the settings of your web browser. Cookies cannot be used to run programs or deliver viruses to your computer and/or device.
13. Access to Personal Data
13.1 Under the Ordinance, you have a right to request access to, and to request correction of, your personal data in relation to this Platform. If you wish to exercise these rights, please contact us.
14. Contact Us
Last Updated: 04/05/2023