Privacy Policy

Privacy Policy

Privacy and Cookie Policy

Cualia Website Application

Effective date July 31 2024

This policy applies to the collection of personal data, as well as to the use of "cookie" files and similar technologies on the Cualia Website Application (the “Website”). The Website is operated by Cualia.io, with its registered office at Office 2101, 21st Floor, Euro Trade Centre, 13-14 Connaught Road Central Hong Kong (“We” or “Our”).

We are committed to safeguarding the privacy of our Website users; in this policy, we explain how we will treat personal information. Please let us know if the personal information that we hold about you needs to be corrected or updated. In no event, we will sell, rent, or otherwise disclose your personal data, except as outlined in the Privacy and Cookie Policy, provided that we have an appropriate legal basis for such a disclosure (your consent or a legal obligation). We are the controller of your personal data and take appropriate steps to ensure the security of your data.

By your continued use of our services following the posting of this Privacy Policy, you agree to this Privacy and Cookie Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version.

This Privacy Policy forms part of and should be read in conjunction with our Terms of Use and any additional applicable terms on our Services.

We may update this policy from time to time by publishing a new version on our Website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email.

1. Children's privacy

  1. We do not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register on the Website. Website and its content are not directed at children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18 without parental consent, we will delete that information as quickly as possible.
  2. If you believe that we might have any information from or about a child under 18, please contact us.

2. Collecting personal information

  1. We may collect, store, and use the following kinds of personal information:
    • (a) Information about your IP address, geographical location, operating system, referral source, length of visit, page views, and navigation paths;
    • (b) Information that you provide to us when registering on our Website including your name and email address, credit card details;
    • (c) Information that you provide when completing your profile on our Website including your name, profile picture, phone number;
    • (d) Information that you provide to us when using our Website, or that is generated in the course of the use of the Website including the time-of-using, frequency, and pattern of service use;
    • (e) Information that you post to our Website for publication on the internet including your user name, your profile pictures, and the content of your posts;
    • (f) Information contained in or relating to any communication that you send to us or send through our Website including the communication content and metadata associated with the communication; and
    • (g) Any other personal information that you choose to send to us.
  2. Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

3. Using personal information

  1. Personal information submitted to us through our Website will be used for the purposes specified in this policy.
  2. We may use your personal information to:
    • (a) Administer our Website and business;
    • (b) Personalize our Website for you;
    • (c) Enable your use of the services available on our Website;
    • (d) Send you non-marketing commercial communications;
    • (e) Send you email notifications that you have specifically requested;
    • (f) Send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
    • (g) Keep our Website secure and prevent fraud; and
    • (h) Verify compliance with the Terms of Use governing the use of our Website.
  3. If you submit personal information for publication on our Website, we will publish and otherwise use that information in accordance with the license you grant to us.

Your rights

  1. You may instruct us to provide you with any personal information we hold about you, as well as the right to data portability and to restriction of processing - provision of such information will be subject to:
    • (a) The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport plus an original copy of a utility bill showing your current address).
  2. We may withhold personal information that you request to the extent permitted by law.
  3. You may instruct us at any time not to process your personal information for marketing purposes.
  4. You also have the right to request that we correct or delete your data.
  5. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
  6. We process your personal data only for as long as necessary for the purposes for which it was collected. In establishing the appropriate retention period for your personal data, we take into account, among others, the following criteria: (i) whether you express continuous interest in our services, (ii) whether you still have an account with us and if you use it, (iii) whether there are specific legal obligations to retain your data (e.g. for accounting and tax purposes).
  7. We share your personal data with payment service providers for the purpose of processing your payments. The transfer is made based on our legitimate interest and because it is necessary for the performance of the contract with you. We may also be obliged to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).
  8. If you have any questions with regard to the processing of your data by us or if you wish to exercise your rights, you can contact us at support@cualia.io. You also have the right to file a complaint with the data protection authority.

5. Disclosing personal information

  1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
  2. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
  3. We may disclose your personal information:
    • (a) To the extent that we are required to do so by law;
    • (b) In connection with any ongoing or prospective legal proceedings;
    • (c) In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
    • (d) To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
  4. Except as provided in this policy, we will not provide your personal information to third parties.

6. Changing or deleting your information

  1. All our members may review, update, correct, or delete the Personal Information in their registration profile by logging into their account and changing the user preferences associated with their account. If you completely delete all such information, your account may be deactivated. We may retain an archived copy of your records as required by law or for legitimate business purposes.

7. Our Website uses cookies

  1. Our Website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
  4. We use both session and persistent cookies on our Website.
  5. The names of the cookies that we use on our Website, and the purposes for which they are used, are set out below:
    • (a) We use both session and persistent cookies to recognise a computer when a user visits our Website, track users as they navigate the Website, improve the Website's usability, administer the Website, prevent fraud and improve the security of the Website, personalise the Website for each user, validate authenticated users sessions.
  6. Most browsers allow you to refuse to accept cookies; for example:
    • (a) In Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
    • (b) In Firefox (version 47) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
    • (c) In Chrome (version 52), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
  7. Blocking all cookies will have a negative impact upon the usability of many Websites.
  8. If you block cookies, you will not be able to use all the features on our Website.
  9. You can delete cookies already stored on your computer; for example:
    • (a) In Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
    • (b) In Firefox (version 47), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and
    • (c) In Chrome (version 52), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".
  10. Deleting cookies will have a negative impact on the usability of many Websites.
  11. We use Google Analytics’ third-party users data such as age range, gender and interests to better understand the behavior of Website user and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. User may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/.

8. Behavioral advertising and online privacy

  1. A guide to behavioral advertising and online privacy has been produced by the internet advertising industry which can be found at http://youronlinechoices.eu. The guide contains an explanation of the IAB’s self-regulatory scheme to allow you greater control of the advertising you see.
  2. Using browser settings to manage cookies:
    • The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the Website of its manufacturer.
    • However, because cookies allow you to take advantage of some of the Website’s essential features, we recommend you leave them turned on. For example, if you block or otherwise reject cookies you will not be able to add items to your Shopping Basket, proceed to Checkout, or use any of our products and services that require you to Sign in. If you leave cookies turned on, remember to sign off when you finish using a shared computer.

9. Third-party Websites

  1. Our Website could include hyperlinks to, and details of, third-party Websites.
  2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. International data transfers

  1. Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
  2. Personal information that you publish on our Website or submit for publication on our Website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

11. Security of personal information

  1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
  2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
  3. All electronic financial transactions entered into through our Website will be protected by encryption technology.
  4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
  5. You are responsible for keeping the password you use for accessing our Website confidential; we will not ask you for your password (except when you log in to our Website).

12. Contact

You can contact us by email using support@cualia.io.