For the purposes of this policy (the “Privacy Policy”):
− “Applicable Regulations” means the Hong Kong Personal Data (Privacy) Ordinance, and any and all regulations applying to us;
− “Do-not-call Registers” means a register comprising customers not wishing to be contacted for advertising purposes;
− “Information” means details of a particular or a company;
− “Funds Sniper” means Funds Sniper Limited;
− “Terms and Conditions” means the terms and conditions of Funds Sniper in the relevant section on the Website;
− “we”, “us”, “our” or “Funds Sniper” means Funds Sniper Limited;
− “Website” means www.fundssniper.com, www.fundssniper.de, www.fundssniper.fr, and www.fundssniper.uk; and
− “you”, “your” or “yours” means the persons to whom this policy applies.
The security of your personal data is important to us. We comply with Applicable Regulations and have safeguards in place to protect the personal data stored with us.
This Privacy Policy sets out the basis on which we may collect, use, disclose, process and manage your personal data. Please read this Privacy Policy carefully to understand our practices regarding personal data.
By visiting the Website, you are accepting and consenting to the practices described in this Privacy Policy.
1. We may collect and process the following data about you
1.1 Information you give us. You may give us Information about you by filling in forms on our Website or by corresponding with us by phone, e-mail, or otherwise. This includes Information you provide when you register to use our Website, subscribe to our services, or report a problem with our Website. The Information you give us may include your:
1.1.1 personal particulars Information such as name, e-mail, phone number and residential address;
1.1.2 company details (if any) such as name of your company, company address, position held and phone number;
1.1.3 personal opinions disclosed to us (such as feedback on our products and website); and
1.1.4 the Information obtained from a mobile device with your consent.
1.2 Information we collect about you. With each visit to our Website we may automatically collect the following Information:
1.2.1 technical Information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login Information, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform;
1.2.2 Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time);
1.2.3 services you viewed or searched for;
1.2.4 page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and
1.2.5 methods used to browse away from the page and any phone number used to call our customer service number.
1.3 Information we receive from other Sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, analytics providers, search Information providers, and credit reference agencies) and may receive Information about you from them. Where this is the case, we will ensure this will be in full compliance with Applicable Regulations.
2. How we use your Information
2.1 Information you give to us and Information we collect about you. We will notably use this Information for:
2.1.1 developing and providing our services (whether made available by us or through us) including but not limited to: carrying out research; planning and statistical analysis; analytics for the purposes of developing or improving our services, security, service quality, and advertising strategies;
2.1.2 assessing and processing applications, instructions, or requests;
2.1.3 communicating with you, including providing you with updates on changes to services (whether made available by us or through us) including any additions, expansions, suspensions, and replacements of or to such services and facilities, and their terms and conditions;
2.1.4 managing our infrastructure and business operations and complying with internal policies and procedures;
2.1.5 to carry out our obligations arising from any contracts entered into between you and us and/or to provide you with the information and services that you request from us;
2.1.6 to provide you with information about other services we offer;
2.1.7 to notify you about changes to our services;
2.1.8 to respond to any inquiry you have made through our Website, or via phone, e-mail, or otherwise;
2.1.9 where required to protect your vital interests or that of another natural person;
2.1.10 to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
2.1.11 to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
2.1.12 as part of our efforts to keep our Website safe and secure;
2.1.13 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
2.1.14 to respond to queries or feedback;
2.1.15 addressing or investigating any complaints, claims, or disputes;
2.1.16 verifying your identity for the purposes of providing products, or services;
2.1.17 conducting screenings or due diligence checks as may be required under applicable law, regulation, or directive;
2.1.18 complying with all applicable laws, regulations, rules, directives, orders, instructions, and requests from any local or foreign authorities, including regulatory, governmental, tax, and law enforcement authorities or other authorities;
2.1.19 enforcing obligations owed to us; and/or
2.1.20 seeking professional advice.
2.2 Information we receive from other sources. We may combine this Information with the Information you give to us and the Information we collect about you. We may use this Information and the combined Information for the purposes set out above (depending on the types of Information we receive).
2.3 Information we disclose about you.
We may from time to time share your personal Information with any member of Funds Sniper or with selected third parties, whether located in Hong Kong or elsewhere. Any such sharing will be made in full compliance with Applicable Regulations. The following are the types of third parties we may share some of your personal data with:
− Supabase. Supabase is a third-party service for back-end hosting and database management hosted on Amazon Web Service (AWS). Supabase is located at 970 Toa Payoh North #07-04, Singapore 318992. Have access to Privacy Policy of Supabase: https://supabase.com/privacy
− Vercel. Vercel is a third-party service for front-end hosting hosted on AWS. Supabase is located at 440 N Barranca Ave #4133, Covina, CA 91723, USA. Have access to Privacy Policy of Vercel: https://vercel.com/legal/privacy-policy
− Amazon Web Service (AWS). AWS is a third-party service for hosting services. AWS is located at 535 Jaffe Rd, Causeway Bay, Hong Kong. Have access to Privacy Policy of AWS: https://aws.amazon.com/fr/compliance/hong-kong-data-privacy/
− Stripe. Stripe is a third-party service for payment services. Stripe is located at 354 Oyster Point Boulevard, South San Francisco, California, 94080, USA. Have access to Privacy Policy of Stripe : https://stripe.com/privacy
− Xero. Xero is a third-party service for accounting services. Xero is located at 10/F, YF Life Tower, 33 Lockhart Road, Wanchai, Hong Kong. Have access to Privacy Policy of Xero : https://www.xero.com/legal/privacy/
− Brevo. Brevo is a third-party service for marketing email management. Brevo is located at 106 boulevard Haussmann, 75008 Paris, France. Have access to Privacy Policy of Brevo: https://www.brevo.com/legal/privacypolicy/
2.3.1 We will never sell your personal data without your prior written consent. If we sell any business or assets, we will also request your prior written consent to disclose your personal data to the prospective buyer of such business or assets. In the absence of your consent within Five (5) days following our request, we will erase your personal data before the potential transfer of such business or assets.
2.3.2 If you give your consent to us and that we sell our company or substantially all of our assets to a third party, your personal data may then be one of the transferred assets.
2.4 Use of personal data for marketing purposes.
2.4.1 We may use your personal data to offer you services including special offers, promotions, or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, and other mobile messaging services. In doing so, we will comply with Applicable Regulations.
2.4.2 In respect of sending telemarketing messages to your telephone number via short message service, telephone calls, facsimile, and other mobile messaging services (if any), please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do-not-call Registers. If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your telephone number, we may, if applicable, send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
2.4.3 You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
2.4.4 To find out more about how you can change the way we use your personal data for marketing purposes, please contact us (please see the “Contact us” section below).
2.4.5 Nothing in this section shall vary or supersede the Terms and Conditions that govern our relationship with you.
3. Where we store your personal Information
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 staff operating outside Hong Kong who works for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, and the provision of support services.
4. Access and correction
You may contact our data protection officer, dpo@fundssniper.com to exercise your rights. You may check whether we hold your personal data and request access to such personal data or make corrections to personal data held by us. Applicable Regulations also provide relevant individuals with additional rights including the right to obtain information on how Funds Sniper processes your personal data, receive certain information provided in an electronic format and/or request that these be transmitted to a third party, request for your information to be erased, object or restrict the use or processing of your information in some circumstances. These will be subject to ongoing obligations imposed on us pursuant to any applicable law or regulation, and/or our legitimate reason or entitlement to continue processing your information, and/or to refuse that request. Please contact us (please see the “Contact us” section below) for details on how you may request access or correction to or exercise your rights with respect to the processing of your personal data.
5. Data Retention
The period for which we will retain your data is dependent upon any statutory retention periods we are required to adhere under Applicable Regulations. After the expiration of that period, personal data shall be securely deleted, as long as it is no longer required for the fulfilment of any contract, initiation of a contract, or in relation to other legal proceedings.
6. Other Websites
Our website may contain links to other websites which are not maintained by us. This policy only applies to our Website. When visiting these third-party websites, you should read their privacy policies which will apply to your use of the websites.
7. Contact us
To contact us on any aspect of this Privacy Policy or your personal data or to provide any feedback that you may have, please get in touch with us through our email at admin@fundssniper.com or you may contact our data protection officer:
Data Protection Officer (DPO)
Funds Sniper Limited
Address: Room 1305, 13/F, Hollywood Centre,
233 Hollywood Road,
Sheung Wan, Hong Kong,
Email: dpo@fundssniper.com
8. Changes to our Privacy Policy
Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently for any updates or changes to our Privacy Policy.