INTRODUCTION
Zhuhai Xingji Meizu Information Technology Co., Ltd. and its global affiliates (also referred to as “Meizu”, “we”, “us”, or “our”) take your privacy seriously where we deal with your personal data and information. Personal data and information refers to any type of data and information that identifies or relates directly or indirectly to you personally such as your name, account ID, phone number or data that can be linked with such information in order to identify you directly or indirectly (collectively refer to as the “Personal Information”).
This Privacy Policy describes our practices in connection with Personal Information that we collect from you in person and through your use of our account services.
Where there are local variations or additions concerning how we use your Personal Information collected from your home country, these are set out clearly in the【13. Country Specific Schedules】section of this Privacy Policy. Please treat these schedules as a part of this Privacy Policy.
QUICK GUIDE TO CONTENTS
1 ABOUT US
2 HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
3 HOW WE SHARE YOUR PERSONAL INFORMATION
4 WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST?
5 DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
6 DO WE TRANSFER YOUR PERSONAL INFORMATION?
7 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
8 SENSITIVE PERSONAL INFORMATION
9 YOUR PRIVACY RIGHTS
10 CHILDREN
11 UPDATES TO THIS PRIVACY POLICY
12 CONTACTING US
13 COUNTRY SPECIFIC SCHEDULES
1.ABOUT US
References to “we” or “us” in this Privacy Policy are to Zhuhai Xingji Meizu Information Technology Co., Ltd. We will be responsible as a data controller for all the Personal Information we collect through your use of our account services.
2.HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
We receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our account services.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either “to provide a requested service or carry out a contract with you”; “where we have a legal obligation”; “ where you have given us your consent”; “where it is necessary for our legitimate interest” (this means that we have a business or commercial interest in using your Personal Information).
The tables below set out clearly how we collect and use your Personal Information.
Please bear in mind that if you choose not to provide information requested by us, or if you object to our use of your Personal Information where we have made it clear that this information is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.
2.1 Personal Information that you provide to Meizu
Information we collect | How we use your information |
Signing up to our products and services and log in to your account You give us Personal Information about you when you sign up to an account on our products and services and log in to your account. This is generally information including your phone number, verification code and password. You also give us Personal Information about you when you use your account. This is generally information including account information, IP address, device ID(GUID, IDFV). | Provide a requested service / carry out a contract with you · To register your account and provide you with account functionality on our products and services, such as arranging access to your account, maintaining your account and providing you with related customer service. |
Retrieve your password You give us Personal Information about you when you retrieve your password. This is generally information including your phone number, verification code and new password. | Provide a requested service / carry out a contract with you · To enable password retrieval. |
Customer Service Support You give us Personal Information about you when you contact us through our customer service email or by other methods in relation to an order or support request you have made with us. This is generally information including your name, Flyme account number, and details of your enquiry or query. | Provide a requested service / carry out a contract with you · To communicate with you regarding your access to our services and provide you with related customer service. |
Responding to requests for the exercise of rights by the subject of personal information You give us Personal Information about you when you exercise your rights related to Personal Information, such as the right to access, copy or delete. This is generally information including your phone number, account information and details of your enquiry or query. | Provide a requested service / carry out a contract with you · To response to your request, including to verify that this exercise request is from you. |
2.2 General Enquiries
Information we collect | How we use your information |
General Enquiries You give us Personal Information about you when you contact us or otherwise interact with us generally, including via email, telephone call or otherwise. This is generally information including your name, contact information, and details of your communication. | Provide respond to inquiries · To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our products and services. |
2.3 Automatically Collected Information
Information we collect | How we use your information |
Recording your action of clicking confirm, agree or decline When you review and select to confirm this policy or to agree or decline other agreements in the interactive interface, we collect and use your device information (such as variable Android ID) and log information (timestamp and corresponding system, application, and protocol version information), Flyme account and device model, which is collected automatically by the system. | Necessary to comply with legal obligations Necessary to enable defence of legal proceedings · to comply with legal regulations and to confirm which version of this policy is valid for you in order to protect your legal rights and interests. |
2.4 Internal Business Processes
Information we collect | How we use your information |
Audits (Internal and External) and Compliance Our audit and compliance process may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interest To verify that our internal processes function as intended. Necessary to comply with a legal obligation To verify that our internal processes are compliant with legal, regulatory or contractual requirements. |
Fraud and Security Our fraud and security monitoring process may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interest To carry out fraud and security monitoring within our business, for example, to detect and prevent cyberattacks or attempts to commit identity theft. |
Administration Our administrative processes may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interest To operate efficiently within our business model and corporate structure, in a way that effectively services our customers, including by using a range of centralised and localised business functions. |
Legal claims Our legal claims process may apply to any of the above Personal Information we collect about you. | Necessary to comply with a legal obligation / Legitimate interests (depending on the situation) · To effectively defend or bring claims to protect our legal rights and interests, and to respond to investigations from regulators or law enforcement. |
3.HOW WE SHARE YOUR PERSONAL INFORMATION
We share and disclose, or may share or disclose your Personal Information for the following purposes:
· We share your Personal Information with affiliates for the purposes described in this Privacy Policy.
· When you log in and use applications developed by our affiliated companies using your Flyme account, we share your account information (including account ID, profile picture, and nickname) with these companies to help you log in and use their products with your Flyme account.
· We share your Personal Information with third parties who perform services of account security risk identification and guarantee on our behalf (and in some cases, our affiliates), to facilitate the services they provide to us. This Personal Information includes device information such as device mode, device ID, device mode, operation system type, IP address and timestamp.
· We share your Personal Information with third parties who perform services on our behalf (and in some cases, our affiliates), to facilitate the services they provide to us. These can include consultants, providers of professional advisory services (lawyers and accountants), service providers involved in hosting, marketing technology, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, email delivery, credit card processing, auditing and other similar services.
· We share your Personal Information if we have a duty to do so, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal or regulatory obligation, such as pursuant to court orders, enforcement action from regulators or law enforcement; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of us, our affiliates, you, other third parties, users of our products and services or the general public.
· We share your Personal Information in connection with sales or business transactions. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
· We share your Personal Information to enforce our terms and conditions or any other contracts we have with you and to allow us to pursue available remedies or limit the damages that we may sustain in any action, such as pursuant to court orders and engaging debt collection agencies.
4.WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE INFORMATION WE REQUEST?
If you do not provide the Personal Information necessary or withdraw your consent for the processing of your Personal Information where this information is necessary for us to provide our products and services to you, we will not be able to provide those services to you.
5.DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
No, we do not carry out automated decision making.
6.DO WE TRANSFER YOUR PERSONAL INFORMATION?
Please note that as a result of the global nature of our operations, your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our products and services you understand that your Personal Information may be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.
In particular, our Internet Data Center team is based in Hongkong, China(“Hongkong”), and so the Personal Information you provide to us while interacting with us will be stored and processed in Hong Kong. However, Personal Information that is explicitly stated in this Privacy Policy to be processed locally will not be transmitted and stored in Hong Kong.
Please see the 【13. Country Specific Schedules】of this Privacy Policy for information on how we protect your Personal Information when it is transferred from your country of residence to a location outside your country of residence.
7.HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law. Unless otherwise required by law or authorized by you to extend the storage period, we will only store your personal information for the shortest time necessary to provide you with our products/services. We provide you with relevant cancellation and deletion functions in accordance with legal requirements. After you apply for cancellation or deletion, we will delete your personal information in accordance with the legal requirements, and the minimum necessary storage period can be decided by you.
When the collection and use of personal information exceeds the necessary storage period, we will delete or anonymize your personal information as soon as possible in accordance with the requirements of laws and regulations, except as otherwise provided by laws and regulations.
8.SENSITIVE PERSONAL INFORMATION
We ask that you not send us, and you not disclose to us, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation or sex life, political opinions, religion or philosophical beliefs, health related information, criminal background or trade union membership) on or through our products and services or otherwise unless we expressly request this information.
9.YOUR PRIVACY RIGHTS
If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict, erasure or delete Personal Information), you may contact us at: dpo@global.xjmz.com. We will respond to your request consistent with applicable law.
In your request, please make clear what actions you are requesting we carry out with regards to your Personal Information and the specific information that your request concerns, so that we can action your request more readily. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.
Please see the 【13. Country Specific Schedules】 of this Privacy Policy for information on specific data protection rights provided by your country of residence.
10.CHILDREN
Our products and services are not directed at children under the age of 18. We do not knowingly collect Personal Information from the children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at dpo@global.xjmz.com. We will investigate any notification and if appropriate, delete the Personal Information from our systems.
Please see the 【13. Country Specific Schedules】 of this Privacy Policy for information regarding children’s Personal Information specific to your country of residence.
11.UPDATES TO THIS PRIVACY POLICY
We may change, amend, modify or update this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you or otherwise post updated versions on our products and services from time to time. Please take a look at the “Update time” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our products and services.
12.CONTACTING US
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us by email at dpo@global.xjmz.com.
We are located at the following address: 4th floor of Factory Building, No.2 Baisha Road, Tangjiawan Town, Zhuhai City, Guangdong Province, PRC.
Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.
13.COUNTRY SPECIFIC SCHEDULES
I. MALAYSIA
Scope and Applicability of this Schedule
In addition to our Privacy Policy, this Schedule describes our practices in Malaysia in connection with Personal Information that we collect from you in person and through your use of our products and services, including smartphones, mobile apps and websites. The Privacy Policy shall be construed as part and integral part of this Schedule, and the Privacy Policy and this Schedule shall be binding on you as user of our products and services, including smartphones, mobile apps and websites in Malaysia.
Personal Information and Sensitive Personal Information
For the purposes of Malaysia,
(a) “Personal Information” as referred in the Privacy Policy shall refers to and be construed as “personal data” as defined under the Personal Data Protection Act 2010 and refers to any type of data and information that identifies or relates directly or indirectly to you personally such as your name, contact details, payment details, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly, other personal data you submitted to us from time to time and all other personal data we again collect from you on any subsequent occasion.
(b) "Sensitive Personal Information" means any personal data consisting of information as to your physical or mental health or condition, your political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission by you of any offence or any other personal data of similar nature.
The above terms shall be construed accordingly in our Privacy Policy.
How We Use Your Personal Information
In Malaysia, we receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our smartphones, mobile apps and websites.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either
· to provide a requested service or carry out a contract with you;
· to take steps at your request with a view to entering into a contract;
· where we have a legal obligation;
· where you have given us your consent, whether explicitly or by your conduct of your sharing the Personal Information with us;
· where it is necessary for our legitimate interest;
· to protect your vital interests;
· for the administration of justice; or
· for the exercise of any functions conferred on any person by or under any law.
By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you:
· consent to us collecting, using, disclosing and/or processing your Personal Information for the Purposes as described in this Privacy Policy;
· consent to us collecting personal data about you from sources other than yourself and using, disclosing and/or processing the same, for one or more of the Purposes as described in this Privacy Policy;
· consent to us disclosing your Personal Information to third party as described in this Privacy Policy;
· consent to us transferring your Personal Information out of jurisdiction to third party as described in this Privacy Policy;
· represent and warrant that you have read and understood the terms and conditions of this Privacy Policy, and you agree, accept and consent to the terms and conditions of this Privacy Policy.
Please bear in mind that if you choose not to provide information requested by us, or if you object to our use of your Personal Information where we have made it clear that this information is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.
Your obligations
(a) It is solely your responsibility and obligation to ensure that the Personal Information you submitted or supplied to us is accurate, complete, not misleading. You are also responsible for updating your Personal Information as and when it becomes incorrect or out of date.
(b) In the event you may need to provide us with Personal Information relating to third parties or other persons (for example about your spouse or children), you confirm that you have (i) obtained their consent or otherwise entitled to provide their Personal Information to us and for us to process according to the Privacy Policy, and (ii) warrant that they have read our Privacy Policy and this Schedule and acknowledge and agree to the terms and conditions set out herein.
(c) Our products and services are not directed to children under the age of 18. We does not knowingly collect Personal Information from the children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at dpo@global.xjmz.com. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you submit or disclose Personal Information of children under the age of 18 or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Information in accordance with the Privacy Policy .
Transfer Of Your Personal Information To Places Outside Malaysia
(a) We may transfer your Personal Information to places outside Malaysia (including Hong Kong) including if the transfer is to our facilities that are located outside Malaysia or if any of our service providers or strategic partners who are involved in providing part of our and/or service or data storage or data processing services for and on behalf of us is located outside Malaysia or has servers and/or related equipment outside Malaysia or if you use the products and/or services from a country other than Malaysia. You consent to us transferring your Personal Information to places outside Malaysia in these instances. We may also transfer your Personal Information to places outside Malaysia where permitted by law.
(b) By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree to the terms and conditions set out in this Privacy Policy and you consent to us to us collecting, using, disclosing and/or processing your Personal Information, and you hereby give us your consent to transfer your Personal Information to a place outside Malaysia, including Hong Kong.
Sensitive Personal Information
(a) We ask that you not send us, and you not disclose to us, any Sensitive Personal Information, and information related to sexual orientation or sex life, on or through our products and services or otherwise unless we expressly request this information.
(b) If you submit or share your Sensitive Personal Information to us (directly or indirectly), you give us your explicit consent to us processing the sensitive Personal Information.
Your Privacy Rights
(a) If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict, erasure or delete Personal Information), you may contact us at: dpo@global.xjmz.com. We will respond to your request consistent with applicable law.
(b) In your request, please make clear what actions you are requesting we carry out with regards to your Personal Information and the specific information that your request concerns, so that we can action your request more readily. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.
(c) We may charge a reasonable fee for access. We will allow you to access to your Personal Information provided that you have made payment for the fee for access. This right of access is further subject to the legal restriction. We reserve our right to refuse to grant you the access in certain circumstances such as when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or if the access will compromise the Personal Information of others.
Updates To This Privacy Policy
We may change, amend, modify or update this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you or otherwise post updated versions on our products and services from time to time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our products and services. By you submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree that you have accepted and consented to the terms of this Privacy Policy including the amended, modified or updated version of this Privacy Policy.
Security
We have in place security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
However, transactions done via personal devices may not be secured and communications over those devices may be exposed to unauthorized third-party interception.
We cannot accept responsibility for any unauthorised access or loss of Personal Information.
While we cannot guarantee that loss, misuse or alteration of Personal Information will not occur, we make reasonable efforts to prevent such unfortunate occurrences.
Conflict
In the event of any inconsistency between the English version and the Bahasa Melayu version of this Privacy Policy and this Schedule, the English version shall prevail over the Bahasa Melayu version.
II. SINGAPORE
Scope and Applicability of this Schedule
In addition to our Privacy Policy, this Schedule describes our practices in Singapore in connection with Personal Information that we collect from you in person and through your use of our products and services, including Glasses, mobile apps and websites. The Privacy Policy shall be construed as part and integral part of this Schedule, and the Privacy Policy and this Schedule shall be binding on you as user of our products and services, including Glasses, mobile apps and websites in Singapore.
Personal Information and Sensitive Personal Information
For the purposes of Singapore,
(a) “Personal Information” as referred in the Privacy Policy shall refers to and be construed as “personal data” as defined under the Singapore Personal Data Protection Act 2012（“PDPA”） and refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access, such as your name, contact details, payment details, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly, other personal data you submitted to us from time to time and all other personal data we again collect from you on any subsequent occasion.
(b) "Sensitive Personal Information" means any personal data consisting of information as to individuals' national identity card numbers (e.g. national registration identity card and passport numbers), personal data of a financial nature, insurance information, sensitive medical conditions, and personal information of minors.
The above terms shall be construed accordingly in our Privacy Policy.
How We Use Your Personal Information
In Singapore, we receive Personal Information about you, either directly from you, from a third-party source or by automated collection when you use our Glasses, mobile apps and websites.
We use your Personal Information for various purposes (reasons) and our lawful basis (justification) for using your Personal Information is either
· to provide a requested service or carry out a contract with you;
· to take steps at your request with a view to entering into a contract;
· where we have a legal obligation;
· where you have given us your consent, whether explicitly or by your conduct of your sharing the Personal Information with us;
· where it is necessary for our legitimate interest;
· to protect your vital interests;
· for the administration of justice; or
· for the exercise of any functions conferred on any person by or under any law.
By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you:
· consent to us collecting, using, disclosing and/or processing your Personal Information for the Purposes as described in this Privacy Policy;
· consent to us collecting personal data about you from sources other than yourself and using, disclosing and/or processing the same, for one or more of the Purposes as described in this Privacy Policy;
· consent to us disclosing your Personal Information to third party as described in this Privacy Policy;
· consent to us transferring your Personal Information out of jurisdiction to third party as described in this Privacy Policy;
· represent and warrant that you have read and understood the terms and conditions of this Privacy Policy, and you agree, accept and consent to the terms and conditions of this Privacy Policy.
Please bear in mind that if you choose not to provide information requested by us, or if you object to our use of your Personal Information where we have made it clear that this information is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have asked for your Personal Information.
Your obligations
(a) It is solely your responsibility and obligation to ensure that the Personal Information you submitted or supplied to us is accurate, complete, not misleading. You are also responsible for updating your Personal Information as and when it becomes incorrect or out of date.
(b) In the event you may need to provide us with Personal Information relating to third parties or other persons (for example about your spouse or children), you confirm that you have (i) obtained their consent or otherwise entitled to provide their Personal Information to us and for us to process according to the Privacy Policy, and (ii) warrant that they have read our Privacy Policy and this Schedule and acknowledge and agree to the terms and conditions set out herein.
(c) Our products and services are not directed to children under the age of 18. We do not knowingly collect Personal Information from the children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our products and services, please email us at dpo@global.xjmz.com. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you submit or disclose Personal Information of children under the age of 18 or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Information in accordance with the Privacy Policy .
Transfer Of Your Personal Information To Places Outside Singapore
(a) We may transfer your Personal Information to places outside Singapore (including Hong Kong) including if the transfer is to our facilities that are located outside Singapore or if any of our service providers or strategic partners who are involved in providing part of our and/or service or data storage or data processing services for and on behalf of us is located outside Singapore or has servers and/or related equipment outside Singapore or if you use the products and/or services from a country other than Singapore. You consent to us transferring your Personal Information to places outside Singapore in these instances. We may also transfer your Personal Information to places outside Singapore where permitted by law.
(b) By submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree to the terms and conditions set out in this Privacy Policy and you consent to us to us collecting, using, disclosing and/or processing your Personal Information, and you hereby give us your consent to transfer your Personal Information to a place outside Singapore, including Hong Kong.
Sensitive Personal Information
(a) We ask that you not send us, and you not disclose to us, any Sensitive Personal Information, and information related to sexual orientation or sex life, on or through our products and services or otherwise unless we expressly request this information.
(b) If you submit or share your Sensitive Personal Information to us (directly or indirectly), you give us your explicit consent to us processing the sensitive Personal Information.
Your Privacy Rights
(a) If you would like to exercise your rights in relation to your Personal Information (such as to access, review, correct, update, suppress, restrict, erasure or delete Personal Information), you may contact us at: dpo@global.xjmz.com. We will respond to your request consistent with applicable law.
(b) In your request, please make clear what actions you are requesting we carry out with regards to your Personal Information and the specific information that your request concerns, so that we can action your request more readily. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request or we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within any legally required time limits.
(c) You may withdraw your consent to our use and disclosure of data with reasonable notice. We will stop using your personal data as soon as possible after withdrawing your consent, and doing so may result in some features being unavailable to you.
(d) We may charge a reasonable fee for access. We will allow you to access to your Personal Information provided that you have made payment for the fee for access. This right of access is further subject to the legal restriction. We reserve our right to refuse to grant you the access in certain circumstances such as when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or if the access will compromise the Personal Information of others.
Marketing
We do not sell or rent your personal information to third parties for marketing purposes without your express consent. If you do not wish to receive marketing communications from us or participate in our customized advertising programs, you can set your preferences in the settings we provide you or by contacting us.
Updates To This Privacy Policy
We may change, amend, modify or update this Privacy Policy at any time. We will notify you of any significant changes where we have a relationship with you or otherwise post updated versions on our products and services from time to time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through our products and services. By you submitting or sharing your Personal Information to us (directly or indirectly) and/or by you using our products and services, you agree that you have accepted and consented to the terms of this Privacy Policy including the amended, modified or updated version of this Privacy Policy.
Security
We have in place security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
However, transactions done via personal devices may not be secured and communications over those devices may be exposed to unauthorized third-party interception.
We cannot accept responsibility for any unauthorised access or loss of Personal Information.
While we cannot guarantee that loss, misuse or alteration of Personal Information will not occur, we make reasonable efforts to prevent such unfortunate occurrences.