This Privacy Policy sets out the basis on which Smallution Limited collects personal data from you and how we process such data. By visiting our website https://www.smallution.com (our “Site”) or using Landing Builder or any other applications or software we provide from time to time (collectively our “App”) or our Services, you accept and consent to the practices set out below:

1) Collection of information

1.1 We collect the following information from or through the Site and/or Services for the purposes further outlined in section 2:

(a) Account Information: The email address and password required for signing up for an Account.

(b) Information provided to us: Your first name, last name, company name, telephone number, and certain other information about you that may be required by us to provide the Services or be disclosed by you during your use of our Site or Services or when you report any problem to us.

(c) IP Addresses: The IP address of any visitor to a landing page you created and published through the Landing Builder.

(d) Cookies: Cookies are small amounts of data that are transferred to your web browser by a web server and are used to collect and store information about a user. (Refer to section 4 regarding the types of cookies we collected and how we use the cookies we collected)

(e) Log files: Your log-in information and your activity log when you visit our Site or use our Services.

(f) Lead Data: The data you collect and solicit from Your Customer through the landing page(s).

If you use the Landing Builder to build forms, you choose which data to collect and process, the nature of the data, as well as the purposes and means of processing. In this case, you are acting as a “Data Controller”. You have the associated responsibilities to provide a privacy policy on protecting the data.

(g) Information about your visit: This includes the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), pages you viewed or searched for, page response times, errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from the page.

1.2 We shall retain the above information and data as long as the laws permit and the purpose for which the data as stated in section 2 below remains effective.

2) Use of the information we collected

2.1 We may use the information we collected from you for the following purposes:

(a) providing, improving, developing and enhancing our Site or Services;

(b) researching, designing and launching new features or products;

(c) analysing trends and monitoring traffic usage;

(d) providing you with alerts, updates, materials or information about our services or other types of information that you requested;

(e) complying with laws and regulations applicable to us in or outside of Hong Kong;

(f) responding or taking part in legal proceedings, including seeking professional advice;

(g) responding to security incidents, claims of any violation of our rights or those of any Third Parties, to protect the rights, property, or personal safety of you, us, our Customers, and the public; and

(h) communicating with you and responding to your questions or requests or comments, including support-related and billing inquiries.

2.2 We may use your Account data to administer your Account and keep track of billing and payments, invoicing, and Account management.

2.3 We log the IP address in order to calculate traffic usage per Account and conversion rates per variant, investigate spam allegations and discrepancies in page statistics, as well as to ensure the security of the webpage, Services, and related data.

2.4 We may use your personal data (those mentioned in clause 1.1) for direct marketing purposes. We require your consent specifically for this purpose. You may opt-out at any time by emailing us at [email protected] and we will cease to send you marketing information.

(a) The type of services or products that may be offered or advertised will be our products, services, news, seminars or events, and those of our affiliates or business partners; and

(b) The relevant information may be sent to you by electronic messages or email.

2.5 While you maintain an Account with us, we may contact you to notify you about changes to the Services, and other important Service-related notices, including but not limited to security and fraud notices, Service suspensions, and outages. These emails and messages are considered essential, non-marketing communications, and you may not opt out of them.

3) Disclosure of your information

3.1 We will keep your personal data confidential but you agree that we may provide information to the following parties as necessary:

(a) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;

(b) our overseas offices, affiliates, business partners and counterparts, and service providers (on a need-to-know basis only);

(c) persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Hong Kong; or

(d) actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Hong Kong.

3.2 This policy is not intended to place any limits on what we may do with data that is aggregated and/or anonymized so it is no longer associated with an identifiable Customer or user of the Services (“Aggregated Data”). We may use your Personal Data to generate Aggregated Data for internal use and for sharing with Third Parties on a selective basis.

4) Cookies

4.1 We use cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

4.2 The cookies we collect include but are not limited to the following:

(a) Persistent cookies - A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services.

(b) Session cookies - Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

(c) Strictly necessary cookies - These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.

(d) Analytical/performance cookies - We use such cookies to monitor the traffic patterns, see how visitors move around our Site when they are using it, gauge the popularity of service options and calculate total visits and views per webpage, variant and Account. This helps us to improve the way our Site works and ensure that visitors see the webpage variant they expect to see if they return to the same website URL.

(e) Functionality cookies - We use such cookies to recognize you when you return to our Site. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).

(f) Targeting cookies - These cookies record your visit to our Site, the pages you have visited and the links you have followed. We use such cookies to make our Site and the information displayed on it more relevant to your interests.

4.3 You agree that should you disable cookies on your browser, certain aspects of the Services may be unavailable to you, and that Smallution is not responsible for any adverse effects arising from your browser or other computer or mobile settings.

4.4 We may use third-party web service on our Site. The service providers that administer these services use technologies such as cookies (likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to study how visitors are using our Site and making information displayed to be in line with your preferences. The information collected through these means (including IP addresses) may be disclosed to these service providers. These analytics services may use the data collected to personalize and contextualize the marketing materials of their own advertising network.

5) Your rights

5.1 You have the right to:

(a) check whether we hold personal data about you;

(b) access the personal data we hold about you;

(c) request correcting any inaccuracy of any personal data we hold about you; and

(d) request updating your Account and Profile Information.

6) Security

6.1 We will strive to prevent unauthorized access to your Personal Data, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. Although we will continue to enhance security procedures as new technologies and procedures become available, we cannot guarantee the complete security of your data transmitted to our Site. Therefore, any transmission is at your own risk.

6.2 You will need a password to login to the Site. We strongly recommend that you choose a strong, unguessable password and that you do not disclose your password to anyone. If you forget your password, we will ask you for your email address and send you an email with instructions for resetting your password.

6.3 You control what Personal Data you provide while using the Site and Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any Personal Data in your possession for the use of the Site and/or Services.

6.4 We restrict access to personal information to our employees, contractors and service providers on a strictly need-to-know basis. We will ensure that those persons are subject to confidentiality obligations.

6.5 We review our information collection, storage and processing practices from time to time to guard against unauthorized access, browsing, processing or use.

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 section 3 above, when operating outside Hong Kong.

7.2 By submitting your personal data, you agree to the transfer, storing or processing of data outside Hong Kong. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy policy.

8) Changes of Privacy Policy

8.1 This Privacy Policy may be amended at any time, with or without notice or notification, so we recommend periodically reviewing it. Continued use of the Site or Services following the posting of any change to this Privacy Policy constitutes your acceptance of all changes.

9) Contact Us

9.1 If you have any questions about this Privacy Policy or your Personal Data, you can email us at [email protected]

Last updated: 08/01/2023