Last updated: 1st Dec 2023
Thank you for using PONS.ai! We are dedicated to protecting your personal data with the utmost integrity, and aim to collect as little information about you as operationally possible.
This policy sets out the basis on which Pons Company Limited ("PONS.ai", "the Company", “We”, “Us”, “Our”), with company number 2708064 registered in Hong Kong, collects personal data from you and how we process such data. By visiting or using our website https://www.pons.ai and software applications (collectively our “Platform”), you accept and consent to the practices set out below.
In this Policy, the term "personal data" refers to any information that pertains to, characterizes, or has the potential to recognize an individual, whether directly or indirectly.
“You”, or “Your” denotes the individual accessing or using the Platform, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform, as applicable.
When you conduct a transaction, we engage third-party payment processors to collect credit card or other financial information. PONS.ai does not see or store the credit card or payment information you provide whatsoever, but only evidence that the payment was or was not made.
Our Service is not intended for use by individuals under the age of 13 and we do not knowingly collect any personal data from them. Please kindly notify us immediately if you, as a parent or legal guardian, are aware that your child has provided us with personal data. We will delete personal data from anyone under the age of 13 (who did not first obtain verifiable parental consent) from our servers in the event that we become aware of it.
1 Collection of information
1.1 For the purposes outlined in Clause 2, we may collect and process the following information about you:
(a) Information you explicitly give us, which may include your personal identity (e.g. full name, company role, social media handles, profile picture, etc.), company information (e.g. company name, logo, etc.), contact information (e.g. e-mail, phone number, etc.), data inputs (e.g. textual and image inputs, etc.), billing information, preferences, etc. by interacting with the Platform. For example:
(i) when you register for an account with us on our Platform;
(ii) when you report any problem to us;
(iii) when you use certain features on our Platform;
(iv) when you request any support from us; or
(v) when you complete any survey or questionnaire we send you.
(b) Information automatically collected when you use our Platform, for example:
(i) standard technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, user agent information (including browser type and version, operation system, platform), time of usage and time zone setting; and
(ii) details of any generations and interactions you made on our Platform.
1.3 The Company will keep Usage Data for the purpose of internal analysis. Typically, Usage Data is kept for a shorter duration, unless it is used to enhance the security or improve the functionality of Our Service. Alternatively, if there is a legal obligation to keep this data for an extended period, we will do so.
2 Uses made of the information
2.1 We use information held about you for the following purposes:
(a) providing, improving and developing our services;
(b) researching, designing and launching new features or products;
(c) presenting content and information in our Platform in the most effective manner for you and for the device you use;
(d) providing you with notifications, alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
(e) collecting overdue amounts;
(f) in any part of the world;
(g) responding or taking part in legal proceedings, including seeking professional advice;
(h) for direct marketing purposes (please see further details in Clause 2.2 below);
(i) communicating with you and responding to your questions or requests; and
(j) purposes directly related or incidental to the above.
2.2 We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:
(a) the personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 1.1 above;
(b) new services or products that the Company has developed;
(c) the relevant information may be sent to you via any means you explicitly provided us;
(d) you may opt out any time by emailing us at email@example.com. We will cease to send you marketing information without charge.
3 Disclosure of your information
We will keep your personal data we hold confidential but you agree we may provide information to:
(a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the Law of Hong Kong;
(b) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);
(c) our overseas offices, affiliates, business partners and counterparts (on a need-to- know basis only);
(d) persons under a duty of confidentiality to us;
(e) persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
(f) actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.
4.3 We may use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Platform or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
4.4 We may use the following cookies:
(a) Essential cookies – these cookies enable core functionality such as security, verification of identity and network management. These cookies can’t be disabled.
(b) Marketing cookies – these cookies are used to track advertising effectiveness to provide a more relevant service and deliver better ads to suit your interests.
(c) Functionality cookies – these cookies collect data to remember choices users make to improve and give a more personalised experience.
(d) Analytics cookies – these cookies help us to understand how visitors interact with our website, discover errors and provide a better overall analytics.
4.5 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Platform.
4.6 We may use third-party web services on our Platform. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Platform and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.
5 Third-party sites
Our Platform or communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.
6.1 All information you provide to us is stored on our secure servers.
6.2 Any payment transactions will be encrypted.
6.3 Where we have given you (or where you have chosen) a password or code that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password or code with anyone, and we have no access to your password whatsoever.
6.4 We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
6.5 We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
6.6 Although we will do our best to protect your personal data, please note that no method of electronic transmission via the Internet is completely secure. We cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk.
7 Data transfer
7.1 The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons referred to in Clause 3 above who operate outside Hong Kong SAR.
8 Your rights
8.1 As compliant with GDPR (General Data Protection Regulation) and CCPA (California Consumer Privacy Act), you have the data protection right to make a verifiable consumer request up to two times within a 12-month period to:
(a) check whether we hold personal data about you over the past twelve (12) months;
(b) access or remove any personal data we hold about you;
(c) require us to correct any inaccuracy or error in any personal data we hold about you; and
(d) request to receive a copy of your data that is processed on our Platform, including:
(i) the categories of Personal Data we collected about you;
(ii) the categories of sources for the Personal Datawe collected about you;
(iii) our business or commercial purpose for collecting or, if applicable, selling that Personal Data;
(iv) the categories of third parties with whom we share that Personal Data;
(v) the specific data points or pieces of Personal Data we collected about you
8.2 Any request under Clause 8.1 may be subject to a small administrative fee to meet our cost in processing your request. Please contact firstname.lastname@example.org to exercise your right.
8.3 PONS.ai does not sell your personal data, as defined under CCPA. If in the future we do sell your personal data, you will be notified and may have the right to opt-out of such sale.
8.4 The Company may not be able to fulfill your request or disclose personal data related to you if we are unable to verify your identity or authority to request such personal data. For our California consumers, Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal data.
9.1 The Company reserves the right to modify this policy at any time by posting the updated policy on our Platform. If we make changes to this policy, we will post the revised policy on the Platform and update the “Last Updated” date at the top of this policy.
If you disagree with the revised policy, you may terminate this agreement with immediate effect. If you do not terminate your agreement within seven (7) calendar days from the date the revised policy become effective, your continued access to or use of the Platform will constitute acceptance of the revised policy.
10 Contact us
If you have any questions, comments or requests regarding your personal data, please contact email@example.com.