EasyView Privacy Policy,effective as of October 26, 2020

Thank you for using EasyView products and services. We respect your privacy and are committed to protecting it through our compliance with this Policy.This EasyView Privacy Policy explains our privacy practices for the activities described herein. Please read this Privacy Policy carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.

A reference to “EasyView,” “we,” “us” is a reference to easyview.com.hk. And its relevant affiliate involved in the collection, use, sharing, or other processing of Personal Data.

Please read the following carefully to understand our approach and practices regarding the processing of your personal data.

How Does This Policy Apply?

Under applicable data protection laws, a party is either considered to be a controller or a processor of data. This is a factual assessment and is determined based on the role and activities of the relevant parties.

(i) If you are using the Services as an individual

If you use the Platform to create a Personal Account or are an individual who has been invited to join a Workplace used for personal not business purposes (a “Personal Workplace”) (collectively an “Authorized User”) or are an individual who has been invited to access the Services without an account (an “Individual User”), we will be the controller of the following categories of data:

(ii) If you are using the Services as an Authorized User of a Business Account:

A Business Account is an account owned by (i) a corporate entity or (ii) an individual who uses it for non-personal purposes. If you use the Platform as an Authorized User of a Workplace used and owned by (i) a corporate entity or (ii) a third party who uses it for non-personal purposes (a “Business Workplace”), then we will only be the controller of:

All Workplace Data of a Business Account will be controlled by (i) a corporate entity or (ii) a third party that owns the Workplace (the “Business Workplace Owner”), this data is referred to herein as “Business Owner Controlled Data”. The Business Workplace Owner may be a different person or entity than the person or entity who has invited you to the Workplace (“Workplace Creator”), e.g. in an employment context, you may be invited to a Workplace by a colleague but your employer will likely be the Business Workplace Owner. If you are unclear on the identity of a Business Workplace Owner, please contact us. We will be subject to the instructions of the Business Workplace Owner with regards to our processing of Business Owner Controlled Data. We are, for the purpose of applicable data protection laws, a processor of this data. If you are an employee who is an Authorized User of a Business Workplace and cease to be employed by the Business Workplace Owner, the Business Workplace Owner may terminate your access to all Workplaces they control. On termination, EasyView will convert your access to a Personal Account and the provisions on “If you are using the Services as an individual” above will apply.

Types of Data We Use

We may collect and use the following types of data when you access the platform or use the Services:

Account Data. You, a Business Workplace Owner or Workplace Creator may give us data regarding the creation or activation of your account on the Platform, including your name, your photo, your business telephone number and your email address, passwords, password hints, and similar security information used for authentication and account access when you access the Platform or use the Services, such as IM chat (instant messaging), get quotes, place order, read the research report , other functions. If you only browse and search the introduction of EasyView products, functions and services displayed on our website or if you are an Individual User, you do not need to register as a Platform user and provide the above information.

Workplace Data. We process the content you generate on the Platform and with the Services, including:

Administrative Data. We process data as necessary to administer and provide the Services. This data includes:

Location Data. We process information about your location including location information based on your IP address. With your permission, we may also collect your location data according to Customer's instruction. For the information about the device you are using (such as device model, operating system version, device settings, unique device identifiers, software and hardware characteristics, etc.) where the device is located, based on the specific permissions you grant in software installation and use Location-related information (such as IP address, and sensor information such as Wi-Fi access points). Please note that individual device information, log information, etc. are information that cannot identify a specific natural person. If we use such non-personal information in combination with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information may be treated as personal information during the combined use.

Interactions Data. We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically collected data to personal information. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information, for example, Cookies that enable you to log into secure areas of the Services, to enable us to provide certain features and functionality, to enhance your experience using the Services.

Third Party Data. EasyView permits the integration of other services and applications. If you are using an integrated service, we may receive data from that third party (and will also share certain data with that third party) in order to provide the integrated service.

How We Use Information

We may use, process and/or disclose your personal data for the following purposes including:

We may also process Administrative Data in furtherance of our legitimate business interests. In this regard, we will be processing the Administrative Data:

We will only process Location Data for providing location-specific functions and Account Data for the purpose of providing personalized marketing messages, if we have your consent to do so. For example, we use data we collect to deliver promotional communications. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from EasyView by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions, and promotional communications, we do not use what you say in email, chat, video conference, or voice mail, or your documents, photos, or other personal files to target ads to you.

If you consent to this form of processing, we will share data with our Business Partners to facilitate the provision of such location services and personalized marketing.

We will process Interactions Data to provide personalized display and other productivity tools depending on your settings. We will use automated software to analyze the historical use, your organization trend and other elements to customize your services experience. For example, we may make suggestions, or rank and display the content based on its relevance to a User. We do not share with advertisers information that can be used to identify you personally, such as your name or email address (unless you ask us to do so).

If we stop operating the services of this Services, we will stop collecting your personal data, notify you in the form of announcement 60 days in advance, and delete or anonymize your personal data possessed by us according to applicable laws.

How We Share Your Personal Data

In order to provide the Services to you, we may disclose your personal data (including data which you choose to share with us through Third Party Integrations Tools) with the following selected third parties including without limitation to those who may be processing your personal data on our behalf for one or more of the purposes stated above and herein:

Service Providers and Authorized third-party vendors

We may disclose your personal data to service providers who support our business, such as cloud service providers and other technology and authorized third-party vendors (wheresoever located and only to the extent necessary). These service providers and vendors help us provide, administer and support the Services, including research, payment processing and transaction fulfillment, database maintenance, technology services, deliveries, email deployment, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing.

Business Workplace Owners

We will share certain data with Business Workplace Owners only if you are an Authorized User of such Business Workplace Owner.

Third Party Integrations

We may share certain data with Third Party Integrations if you give such Third Party Integrations access to your account and information, and any content you choose to use in connection with those Third Party Integrations.

Our Corporate Group

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, in order to provide the Services including improving and optimizing the Services, preventing illegal use and supporting users.

Sale or Merger

We may also disclose your information to third parties in our legitimate business interests:

Business Partners

If applicable, we will also disclose your information to our business partners so that we can make you special offers via the Services with your consent and / or in our legitimate business interests.

Law Enforcement

We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or based on our legitimate business interest if such use is reasonably necessary to:

International Data Transfers: Privacy Shield and Contractual Terms

We maintain servers located in HK and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

Security of Your Personal Data

We attach great importance to the security of your personal data. However, please note that Information you send to us electronically may not be secure when it is transmitted to us.

Security measures we take include adopting encryption techniques such as Transport Layer Security for all data and information stored in our servers or on your terminal devices.

Despite our best efforts, you understand that due to technical limitations and various potential malicious attacks, no security measures are perfect or impenetrable and it is impossible to ensure permanent and absolute security.

Therefore, we strongly suggest you take active measures, including but not limited to using a complicated password, regularly changing your password, and avoiding disclosure of your account password or other Information relating to logging in to your account, so as to protect the security of your personal data. We also recommend that you do not use unsecure channels to communicate personal data or other sensitive or confidential information to us.

Data Retention

We will retain your personal data for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required, for example to comply with legal obligations or requests or for the establishment, exercise or defense of legal claims, or for legitimate businesses purposes, or as provided by law.

Should you or we terminate your account for any reason, we will take steps to ensure that your personal data is no longer available through the Services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.

Third Party Integrated Services

Our Services may integrate with third-party applications or software or contain links to other online platforms or services operated by third parties, including a Business Workplace Owner. We do not control and this Policy does not apply to such other online applications, software, platforms or services and are not responsible for their content, their privacy policies, or their use of your data. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Platform and/or users of those third-party services without limitation as to its use by us or by a third party. Our integration of such services or inclusion of such links does not, by itself, imply any endorsement of the content on such services or of their owners or operators except as disclosed on the Services. We expressly disclaim any and all liability for the actions of third parties, including, but without limitation to, actions relating to the use and/or disclosure of data by third parties. Any information submitted by you directly to these third parties is subject to that third party's Terms of Service and Privacy Policy.

Right to Object

To the extent that EasyView’s processing of your personal data is subject to the General Data Protection Regulation, we rely on its legitimate interests, described above, to process your data. You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

Right to Withdraw Consent

You have the right to withdraw your consent to our processing of data about you for marketing purposes at any time, and we will stop processing data about you for that purpose.

To exercise any of these rights above, please contact us at service@easyview.com.hk. In addition, you have the right to complain to the applicable data protection supervisory authority.

You also may access, correct or request deletion of personal data We have about you by logging into your account. You may also request cancellation of your account by contacting us at service@easyview.com.hk. We’ll take steps to delete your information within a reasonable timeframe, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.

Complaints

In the event of that you wish to make a complaint about how we process your Information, please contact us in the first instance at service@easyview.com.hk and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a complaint with the data protection authority in the country in which you live or work where you consider we have infringed data protection laws.

Data access and correction

You may request to access and/or correct the personal data currently in our possession at any time by submitting your request to service@easyview.com.hk.

Data Retention

We will retain your personal data for the length of time needed to fulfil the purposes outlined in this Policy unless a longer retention period is required, for example, to comply with legal obligations or requests or for the establishment, exercise or defence of legal claims, or for legitimate businesses purposes, or as provided by law. After such time, we will take commercially reasonable efforts to ensure that your personal data in our possession or under our control is securely destroyed and/or anonymized.

Should you or we terminate your account for any reason, we will take steps to ensure that your personal data is no longer available through the Services, or otherwise used or processed by us, within a reasonable period of time (subject to technical limitations) after such account termination.

Information Relating to Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16 unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child under the age of 16 is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section below and we will take steps to delete their Personal Data from our systems.

Contact Us

If you wish to talk with us about how we process your personal data, please contact us at service@easyview.com.hk and we will endeavor to deal with your request as soon as possible.

Changes

This Policy may be updated by us from time to time to reflect changes to applicable laws, regulations, standards, industry codes or other instruments of a similar nature, or to reflect changes, updates or new features to the Services.We will use commercially reasonable efforts to generally notify all users of any material changes to this Policy, such as through a notice on our Services, however, you should look at this Policy regularly to check for such changes. We will also update the “Last Updated” and “Effective “date at the top of this Policy, which reflects the effective date of such Policy. Your continued access to or use of the Services after the date of the updated Policy constitutes your acknowledgment and agreement that you have read, understood and accepted the terms of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Platform and/or the Services.