Last Updated: 3 March 2023

Your privacy is important to us.

DigiGear Technology Limited (‘we’, ‘us’ or ‘our’, as the context may so require) is committed to the privacy and security of data we collect in compliance with the requirements under the Hong Kong Privacy (Data Protection) Ordinance (Chapter 486 of the Laws of Hong Kong) (‘PDPO’).

This Privacy Policy (‘Policy’) explains how we manage personal data and information. This Policy applies to the personal data or information collected, held, processed or used by us in our ticketing platform business (‘Services’), including while you are visiting and using our website https://digigear.io (‘Website’).

For the purposes of the relevant data protection laws, we are the data user which controls the collection, holding, processing or use of your data. This Policy applies to us, our operating divisions, subsidiaries, affiliates and branches (as applicable). This Policy forms part of our Terms of Use.

This Policy is prepared in English and Chinese. If there is any conflict between the English and Chinese versions of this Policy, the English version prevails.

We respect your privacy and shall:

• implement online and offline procedural safeguards to protect the security and confidentiality of the personal data we collect;
• collect the personal data to the extent necessary and adequate for the purpose of our Services to you;
• not to disclose your personal data to external parties unless you have agreed, we are required by law or we have previously informed you.

1. Information Collection

We may, in the course of and in relation to the provision of our Services, collect and process the following information about you:

• Onboarding: your personal information (including without limitation to your name, your company name, address, telephone number, mobile phone number, email address, website, nature of business and product/service details etc. of your company) when you register or onboarded with us, use our Services, attend our functions, or communicate with us. In some circumstances, we may also collect personal identification data such as your passport or identity card number, date of birth and/or nationality for compliance, security and verification purposes;
• Blockchain technology related: blockchain identifiers, such as blockchain addresses and keys (as applicable);
• Account sign-in facility: in connection with an account sign-in facility, your log-in and password details;
• Communication: the content of any communications you send to us, for example, to report a problem or to submit queries, concerns or comments regarding the Website or our Services;
• Automatic collection: automatic collection of data when you visit the Website or use our Services. Such data or information may include your internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information on how you use the Services. We collect such technical information during your visit to the Website through our automatic data collection tools, which may include cookies and other commonly used technologies. We collect such data for the purpose of improving the functionality of the Website and the quality of our Services.

The supply of personal data by you is necessary in order for us to provide you with the requested Services and for us to perform our contractual obligations to you (as applicable). If you do not supply such data, we may not be able to provide the requested Services.

We only retain personal data for so long as it is necessary for the fulfillment of the purpose (including any directly related purpose) for which the data is or is to be used.

2. Use of information

We use personal data that we collect from you for the following purposes:

• to verify your identity for the purpose of satisfying our compliance protocols;
• to determine your eligibility for any of our Services or products;
• to determine your compliance with the terms and conditions that apply to any of our Services and applicable laws;
• to enable us to provide our Services to you;
• to manage your information and accounts;
• to provide access to certain functionalities and features of our Services;
• to communicate with you with respect to your account and activities on our Services;
• to process your financial information and other payment methods for the provision of the Services;
• to provide event advertising and marketing services;
• to process applications and transactions; and
• to allow you to register and/or attend to events.

Additionally, we may use the personal data collected to analyze and improve our Services such as:

• detecting security incidents, protecting against malicious, deceptive or fraudulent activities, and assisting the prosecution in prosecuting those responsible for those activities;
• undertaking research for technological development and demonstration;
• researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
• improving, upgrading or enhancing our Services;
• ensuring internal quality control, including debugs and repair errors that impair existing intended functionality;
• enforcing our terms and policies; and
• complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

We may conduct direct marketing by sending e-newsletters to you or via email and/or other means of communication whether now or hereafter known. We may use your personal data to market the following products and/or services to you:

• the offering and/or whitelisting of digital assets (provided the digital asset under offer does not warrant us to conduct a regulated activity); and
• other information related to digital assets generally.

You have the right to opt out from receiving promotional materials, by simply contacting us (see below for contact details), and we will cease to do so. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.

3. Disclosure

We may share your personal information with the following categories of third parties:

• Service Providers: to our entrusted service providers (processors) which include payment processors; banks; and trust companies;
• Business Partners: to our business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear alongside with ours;
• Affiliates:  to our affiliated and associated companies;
• Other external parties for compliance:to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement or national security requests and legal process, such as a court order; to collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity;
• Other external parties in the event of merger, liquidation and/or sale etc:  If we are involved in a merger, acquisition, financing due diligence, reorganization, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Without prejudice to the generality of the foregoing, for the purpose of crime prevention and detection, and to protect the security and safety of our business and Services, we may provide your personal identification data such as your full passport/identity card no., date of birth and nationality to the relevant law enforcement authorities in Hong Kong — including the Hong Kong Police Force, the Immigration Department, Customs and Excise Department and other government or statutory bodies including the Hong Kong Securities and Futures Commission upon their lawful request.

4. Cookies

We use cookies on our Website to monitor and observe your use of our Website, compile aggregate data about that use, and provide you with more effective service (which may include customizing parts of our Website based on your preferences and past activities).

“Cookies” are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information and the webpage you are currently viewing. Most internet browsers have a facility that will allow you to disable cookies altogether – please refer to your browser’s help menu to find out how to do this. While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

We use email delivery to send emails that you have agreed to receive. Pixels tags and cookies are used in those emails and at our Website to help us measure the effectiveness of our advertising and how visitors use our Website.

5. Security

We implement a variety of security measures to maintain the safety of your personal data and information. All personal information provided to us is transmitted via Transport Layer Security (TLS) and then encrypted into our database, which can only be accessed by those with special access rights to our systems and are required to keep the information confidential. Our computer systems are placed in restricted areas. We only permit authorized employees to access the personal data. We update these physical and technical security processes and procedures from time to time to address new and emerging security threats.

Without prejudice to any of the foregoing, while we take steps to ensure that your data or information is treated securely, no system is fully or completely secure, and therefore we cannot ensure, guarantee or warrant the absolute security of any data or information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

If we learn of a security system’s breach, we will attempt to notify you electronically by mail or by sending an e-mail to you pursuant to the information you supplied to us.

6. Hyperlinks

The Website may, from time to time, contain links to external sites operated by third parties for your convenience. We have no control of and are not responsible for these third party sites or the content thereof. Once you leave the Website, we cannot be responsible for the protection and privacy of any information which you provide to these third party sites. You should exercise caution and peruse the privacy policy for the website you visit.

7. Changes

We may revise this Policy from time to time at our sole discretion. If there are any material changes to this Policy, we will notify you as required by applicable laws. You understand and agree that you will be deemed to have accepted the updated Policy if you continue to use the Services after the new Policy takes effect. The latest version of this Policy will be available at /pages/privacy-policy.

8. Your privacy rights

By using our Service, making an application or visiting our Website, you acknowledge the collection and use of your personal data by us as outlined in this Policy. If you do not agree with the use of your personal data as set out in this Policy or the Terms of Use, please do not use this Website.

Under the PDPO, you have the right:

• to request access to your data;
• to require us to correct your data;
• to ascertain our policies and practices in relation to the personal data and the kind of personal data held by us.

We are permitted by law to charge a reasonable fee for processing a data access request. We may, however, refuse to comply with your data access or correction request under applicable laws, for instance, if we are not supplied with such information as we reasonably require in order to satisfy us as to the identity of the data access or correction requestor.

9. Contact us

If you have any questions concerning the Policy, or if you wish to submit a request to exercise your rights, cease marketing and/or raise any complaints, please contact us at:

DigiGear Technology Limited
Unit 1003, 10/F, Building 19W
No. 19 Science Park West Avenue, Hong Kong Science Park
Pak Shek Kok, New Territories
Hong Kong
E-mail: hi@digigear.io