SETTLED

1. Scope

1.1 This Privacy Policy explains how we collect, use, disclose, protect, and store personal data in connection with the Services. NV TECHNOLOGIES acts as “data user” under the Hong Kong Personal Data (Privacy) Ordinance, Cap. 486 (PDPO). We comply with the Six Data Protection Principles (DPP1–DPP6).

1. Scope

1.1 This Privacy Policy explains how we collect, use, disclose, protect, and store personal data in connection with the Services. NV TECHNOLOGIES acts as “data user” under the Hong Kong Personal Data (Privacy) Ordinance, Cap. 486 (PDPO). We comply with the Six Data Protection Principles (DPP1–DPP6).

2. What We Collect

2.1 Identification and contact data (e.g., name, email, phone, company, role); account credentials; business information; support communications; usage and device data (IP address, device/browser, log data); cookies and similar technologies; and, if relevant to a regulated use case, KYC/AML data as permitted by law.

2.2 Where we collect personal data directly, we provide a Personal Information Collection Statement (PICS) specifying purposes, whether provision is obligatory, consequences of not providing, classes of transferees, direct marketing arrangements (if any), your access/correction rights, and our contact details

2. What We Collect

2.1 Identification and contact data (e.g., name, email, phone, company, role); account credentials; business information; support communications; usage and device data (IP address, device/browser, log data); cookies and similar technologies; and, if relevant to a regulated use case, KYC/AML data as permitted by law.

2.2 Where we collect personal data directly, we provide a Personal Information Collection Statement (PICS) specifying purposes, whether provision is obligatory, consequences of not providing, classes of transferees, direct marketing arrangements (if any), your access/correction rights, and our contact details

3. Why We Use Personal Data (DPP1, DPP3)

3.1 We use personal data for: operating, securing, and improving the Services; account setup and support; communications; analytics; legal compliance; and, if you consent, direct marketing.

3.2 We only use personal data for the original purpose of collection or a purpose directly related to it. Otherwise, we obtain “prescribed consent” before new uses, including direct marketing.

3. Why We Use Personal Data (DPP1, DPP3)

3.1 We use personal data for: operating, securing, and improving the Services; account setup and support; communications; analytics; legal compliance; and, if you consent, direct marketing.

3.2 We only use personal data for the original purpose of collection or a purpose directly related to it. Otherwise, we obtain “prescribed consent” before new uses, including direct marketing.

4. Sharing and Transfers

4.1 We share data with service providers under contract (IT hosting, support, analytics, payment, compliance), group companies, professional advisers, and authorities where required by law.

4.2 International transfers: Section 33 (cross-border transfer restrictions) of the PDPO has not been brought into force. As a matter of good practice, we implement safeguards such as PCPD’s Recommended Model Contractual Clauses for cross-border transfers and due-diligence on recipients.

4. Sharing and Transfers

4.1 We share data with service providers under contract (IT hosting, support, analytics, payment, compliance), group companies, professional advisers, and authorities where required by law.

4.2 International transfers: Section 33 (cross-border transfer restrictions) of the PDPO has not been brought into force. As a matter of good practice, we implement safeguards such as PCPD’s Recommended Model Contractual Clauses for cross-border transfers and due-diligence on recipients.

5. Security (DPP4)

5.1 We take all practicable steps to protect personal data against unauthorized or accidental access, processing, erasure, loss, or use, including encryption in transit, access controls, network segmentation, secure software development, logging/monitoring, and vendor security reviews.

5. Security (DPP4)

5.1 We take all practicable steps to protect personal data against unauthorized or accidental access, processing, erasure, loss, or use, including encryption in transit, access controls, network segmentation, secure software development, logging/monitoring, and vendor security reviews.

6. Retention (DPP2)

6.1 We do not keep personal data longer than necessary for the purposes for which it was collected, unless a longer period is required by law, regulation, audit, or the defense of legal claims. We maintain and apply retention schedules.

6. Retention (DPP2)

6.1 We do not keep personal data longer than necessary for the purposes for which it was collected, unless a longer period is required by law, regulation, audit, or the defense of legal claims. We maintain and apply retention schedules.

7. Your Rights (DPP6)

7.1 You have the right to request access to and correction of your personal data we hold. To exercise these rights or obtain a copy of our Privacy Policy Statement (PPS) or PICS, contact: privacy@nv-technologies.com.

7. Your Rights (DPP6)

7.1 You have the right to request access to and correction of your personal data we hold. To exercise these rights or obtain a copy of our Privacy Policy Statement (PPS) or PICS, contact: privacy@nv-technologies.com.

8. Direct Marketing

8.1 We will only use your personal data for direct marketing where we have obtained your explicit consent or are otherwise permitted by law. You may opt out at any time.

8. Direct Marketing

8.1 We will only use your personal data for direct marketing where we have obtained your explicit consent or are otherwise permitted by law. You may opt out at any time.

9. Data Breaches

9.1 Hong Kong has no mandatory statutory breach notification at the time of this notice. The PCPD recommends notifying the PCPD and affected individuals as soon as practicable when a breach presents a real risk of harm; we follow the PCPD’s guidance and maintain a breach response plan. Proposed amendments to introduce mandatory notification are under consideration by the authorities.

9. Data Breaches

9.1 Hong Kong has no mandatory statutory breach notification at the time of this notice. The PCPD recommends notifying the PCPD and affected individuals as soon as practicable when a breach presents a real risk of harm; we follow the PCPD’s guidance and maintain a breach response plan. Proposed amendments to introduce mandatory notification are under consideration by the authorities.

10. Children’s Privacy

10.1 Our Services are not directed to children. If you believe a child provided personal data, contact us to review and delete where appropriate.

10. Children’s Privacy

10.1 Our Services are not directed to children. If you believe a child provided personal data, contact us to review and delete where appropriate.

11. Other Regimes That May Apply

11.1 If we target or monitor individuals in the EU/EEA or UK, we comply with applicable GDPR/UK GDPR requirements (e.g., consent for non-essential cookies). If we process Mainland China residents’ data in a way that makes the PRC Personal Information Protection Law apply, we will comply with its principles and cross-border rules.

11. Other Regimes That May Apply

11.1 If we target or monitor individuals in the EU/EEA or UK, we comply with applicable GDPR/UK GDPR requirements (e.g., consent for non-essential cookies). If we process Mainland China residents’ data in a way that makes the PRC Personal Information Protection Law apply, we will comply with its principles and cross-border rules.