legal
Privacy Policy
Effective as of 11th April 2023
This website (and any mobile site or mobile application that links to this Privacy Policy) (collectively, the “Sites”) is owned and operated by Tixity Group Limited (a company established in Hong Kong SAR with its principal place of business at Unit A, 3/F, Cheong Sun Tower, 116-118 Wing Lok Street, Sheung Wan, Hong Kong) (“Tixity”, “we”, “our”, and “us”).
At Tixity, we are committed to respecting your privacy. This Privacy Policy explains how we collect, use and disclose personal information that we receive when you visit the Sites, or communicate with us both on the Sites and offline as a business customer, prospective customer or general contact. Tixity has developed policies and procedures consistent with the Personal Data Privacy Ordinance (“PDPO”), the General Data Protection Regulation (GDPR) and other relevant privacy laws.
This Privacy Policy applies to Tixity and its subsidiaries, and, for GDPR purposes, covers our processing activities as a data controller. We also process personal information as a data processor on behalf of our customers (please see “Tixity as Data Processor” below).
The Sites are not intended for or directed at children under the age of 16 years and we do not knowingly collect information relating to children under this age.
We are not required to appoint a formal data protection officer under data protection laws. However, we have designated a Privacy/Data Protection Compliance team who you can reach out to about any queries you may have in relation to this Privacy Policy.
Tixity adheres to the following fair information principles when processing your personal information as data controller:
- Accountability – Tixity is responsible for personal information and data under its control and has designated a Privacy/Data Protection Compliance team to manage our compliance with applicable data protection laws.
- Lawfulness, fairness and transparency – personal information and data must be processed lawfully, fairly and in a transparent manner.
- Purpose identification and limitation – personal information and data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Tixity will identify the purposes for which personal information is collected at or before the time the information is collected.
- Data minimisation – personal information and data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy – personal information and data must be accurate and, where necessary, kept up to date.
- Storage limitation – personal information and data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed.
- Integrity and confidentiality – personal information and data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
Information you give us
You may provide us with information through the Sites, by email, over the phone or otherwise communicate or are in contact with us as a business customer or business contact, when you:
- request additional information about our services or ask us to contact you;
- use our services as a client or customer;
- receive client support from Tixity;
- register with us on the Sites; and
- make any comment or contribution on our Sites.
The categories of personal information you provide may include:
- Contact details, including first and last name, email address, phone number, mailing address and any other identifier that permits Tixity to make contact with you;
- Employment details, including job title and company name and the category or type of organization you work for;
- Account details, including the password you use to register with us;
- Preferences, including your personal or professional interests; and
- Communications data, including information that you may submit to us via posting on our forums or in your correspondence with us.
We do not generally seek to collect sensitive personal information (also known as “special categories of personal data”) through our Sites. Sensitive personal information is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; health or sex life, sexual orientation; genetic or biometric information. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.
Information we collect from you
Tixity collects, stores and uses information about your visits to the Sites and about your computer, tablet, mobile or other device (“device”) through which you access the Sites. This includes the following information:
- technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;
- information about your visits and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used
referred to together as “Technical and Usage Data” in this Privacy Policy.
If you have any questions or complaints regarding our Privacy Policy or practices, please contact us as set out in “Contacting Us” above.
If you are located in the UK or EEA, you also have the right to complain to the relevant data protection supervisory authority. In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/). If you are located in the EEA, you can find details regarding your local data protection regulator here.