Privacy Policy

This Privacy Policy outlines the manner in which the Service Provider collects, uses, maintains, and discloses information collected from users (each, a “User”) of its online platform and related services (collectively, the “Service”). This policy applies to the Service and all products and services offered by the Service Provider.

The Service Provider is committed to safeguarding the privacy of the User’s personal information. The collection, use, and disclosure of personal information by the Service Provider will be conducted in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of the laws of Hong Kong and any other applicable privacy laws.

By using the Service, Users agree to the collection and use of information in accordance with this Privacy Policy. The Service Provider may update this policy from time to time, and Users are encouraged to review it periodically to stay informed of any changes.

For the purposes of this Privacy Policy, the following terms shall have the meanings ascribed to them:

• “Personal Data” means any data relating directly or indirectly to a person, from which it is practicable for the identity of the person to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.
• “Processing” means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

The Service Provider collects Personal Data from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features, or resources we make available on our Service. Users may be asked for, as appropriate, name, email address, mailing address, phone number, credit card information. Users may, however, visit our Service anonymously.

The Service Provider will use the Personal Data collected for the purpose of providing and improving the Service, processing transactions, sending periodic emails, and for other purposes to which the User has consented.

Users have the right to request access to and correction of their Personal Data held by the Service Provider. Requests for access or correction of Personal Data should be directed to the Service Provider’s designated data protection officer.

This Privacy Policy, including the Privacy Statement, forms part of the Terms and Conditions of using the Service.

Limitation of Liability

To the fullest extent permitted by law, the Service Provider shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from: (i) your access to or use of or inability to access or use the Service; (ii) any conduct or content of any third party on the Service, including without limitation, any defamatory, offensive, or illegal conduct of other users or third parties; (iii) any content obtained from the Service; or (iv) unauthorized access, use, or alteration of your transmissions or content.

Notwithstanding any other provision of these Terms, the Service Provider’s liability to you for any cause whatsoever, and regardless of the form of the action, will at all times be limited to the amount paid, if any, by you to the Service Provider for the Service during the period of three (3) months prior to any cause of action arising.

This limitation of liability section applies whether the alleged liability is based on contract, tort, negligence, strict liability, or any other basis, even if the Service Provider has been advised of the possibility of such damage.

Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitations or exclusions may not apply to you. In such jurisdictions, the Service Provider’s liability will be limited to the greatest extent permitted by law.

Indemnification

The User agrees to indemnify, defend, and hold harmless the Service Provider, its affiliates, officers, directors, employees, agents, licensors, and suppliers from and against all losses, expenses, damages, and costs, including reasonable attorneys’ fees, resulting from any violation of these Terms, or any activity related to the User’s account (including negligent or wrongful conduct) by the User or any other person accessing the Service using the User’s account.

This indemnification obligation will survive the termination of these Terms and the User’s use of the Service.

Reporting inappropriate content

The Service Provider disclaims any liability for hosting or enabling inappropriate content, such as:

• Content that promotes offers unlawfully in certain jurisdictions.
• Content directed at individuals under the legal age.
• Content that breaches consumer protection, data protection, or advertising laws.
• Unsolicited electronic messages (spam).
• Content that infringes on trademarks.
• Content placed on pages with unlawful or inappropriate material.
• Content misleading about the publisher’s identity.

If you encounter any inappropriate content, please report it immediately to the Service Provider. You can do this by contacting our support team through the link “DSA Report” on our website. Please include specific information about the content and its location on the Service to enable us to address the issue promptly. The Service Provider is committed to maintaining a respectful and safe environment for all users and will take appropriate action in accordance with our policies and applicable laws.

Termination

This Termination clause applies to the Terms and Conditions governing the use of the Service provided by the Service Provider to you (“User”).

Either party may terminate these Terms by providing the other party with thirty (30) days’ written notice. Upon termination, the User must cease all use of the Service and delete all copies of any software or content provided under these Terms.

The Service Provider may also terminate these Terms immediately, without notice, if the User breaches any provision of these Terms, engages in any fraudulent or illegal activity, or fails to pay any fees due under these Terms.

Upon termination for any reason, the rights and licenses granted to the User under these Terms will immediately cease, and the User must cease all use of the Service. Any provision of these Terms that, by its nature, should survive termination will survive termination, including, but not limited to, ownership provisions, warranty disclaimers, indemnity, and limitations of liability.

In the event of termination, the Service Provider will delete or return any Personal Data of the User in its possession in accordance with applicable data protection laws.

Governing Law

This Agreement and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of Hong Kong.

Without prejudice to any other rights or remedies that the parties may have, the parties hereby irrevocably submit to the exclusive jurisdiction of the courts of Hong Kong for the purpose of settling any dispute or claim that arises out of or in connection with this Agreement or its subject matter or formation (including non-contractual disputes or claims).

Dispute Resolution

In the event of any dispute, controversy, or claim arising out of or relating to these Terms, or the breach, termination, or invalidity thereof (“Dispute”), the parties shall first attempt to resolve the Dispute amicably through negotiation. If the Dispute cannot be resolved through negotiation within thirty (30) days, the parties agree to submit the Dispute to mediation in accordance with the Hong Kong International Arbitration Centre (HKIAC) Administered Mediation Rules. If the Dispute is not resolved through mediation within sixty (60) days of the commencement of mediation, the Dispute shall be referred to and finally resolved by arbitration in Hong Kong under the HKIAC Administered Arbitration Rules in effect at the time of arbitration. The arbitration tribunal shall consist of one arbitrator to be appointed in accordance with the said rules. The language of the arbitration shall be English.

The decision of the arbitrator shall be final and binding upon the parties, and the parties agree to be bound thereby and to act accordingly. The costs of the arbitration, including administrative fees, the arbitrator’s fees, and all other expenses of the arbitration, shall be borne by the losing party, unless otherwise determined by the arbitrator. Each party shall bear its own costs and expenses of legal representation.

Amendment and Modification

The Terms may be amended or modified by the Service Provider at any time without prior notice to the User. However, the Service Provider will endeavor to notify the User of any significant changes to the Terms by posting a notice on the Service’s website or through other reasonable means. It is the User’s responsibility to review the Terms periodically to be aware of any amendments. The continued use of the Service by the User after any amendment to the Terms constitutes acceptance of the amended Terms.

Entire Agreement

This Agreement constitutes the entire agreement between the User and the Service Provider and supersedes all prior understandings, agreements, representations, and warranties, both written and oral, with respect to the Service. No amendment, modification, or waiver of any of the provisions of this Agreement shall be effective unless in writing and signed by both parties.

Severability

If any provision of these Terms, or the application thereof to any person or circumstance, is found to be invalid, illegal, or unenforceable to any extent, the remainder of the Terms and the application of such provisions to other persons or circumstances shall not be affected thereby and shall be enforced to the greatest extent permitted by law. Each provision of these Terms is intended to be severable. If any provision hereof is held invalid or unenforceable in whole or in part in any jurisdiction, such provision shall, as to such jurisdiction, be ineffective to the extent of such invalidity or unenforceability without in any manner affecting the validity or enforceability thereof in any other jurisdiction or the remaining provisions hereof in any jurisdiction.

Waiver

The failure of the Service Provider to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. Waivers of any rights under these Terms must be in writing and signed by the party waiving its rights.

This clause does not affect any statutory rights that the User may have as a consumer in the jurisdiction of Hong Kong. Any waiver of these Terms shall not be considered a waiver of any other term or the same term on any other occasion.

Privacy Statement

Introduction

This Privacy Statement explains how Bridgepoint Ventures Management Ltd. (“we”, “us”, or “our”) collects, uses, discloses, and protects the personal data of individuals (“you”) in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong. By accessing or using our services, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Statement.

Scope and Purpose

This Privacy Statement applies to all personal data collected, stored, and used by Bridgepoint Ventures Management Ltd. (“the Data Controller”) from data subjects (“You”). The purpose of collecting, storing, and using personal data under this Privacy Statement is to provide and improve services offered by Bridgepoint Ventures Management Ltd., to comply with applicable legal and regulatory requirements in Hong Kong, and to ensure the security of our services.

Personal data refers to any information related to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Data Collection and Use

This Privacy Statement outlines the practices of Bridgepoint Ventures Management Ltd. (“Data Controller”) regarding the collection, use, and protection of Personal Data from You (“Data Subject”) in accordance with the laws of Hong Kong. “Personal Data” refers to any information related to an identified or identifiable natural person.

The Data Controller is committed to:

• Streamlining systems for addressing customer complaints and managing opt-outs.
• Managing suppression lists for email and SMS affiliates to maintain regulatory compliance.
• Providing third-party physical opt-out addresses to support customer relations.
• Implementing stringent data privacy measures in line with global standards.

These practices are designed to ensure the protection and respectful treatment of your Personal Data.

Hosting Solutions and Compliance Management

Bridgepoint Ventures Management Ltd. (“Data Controller”) is committed to protecting the privacy and security of your Personal Data. As part of our commitment, we provide comprehensive hosting solutions that include the setup, maintenance, and optimization of marketing platforms to ensure the effective management of your Personal Data.

In addition to our hosting solutions, we offer compliance management services to ensure that all operational activities, including the processing of Personal Data, adhere to the highest industry regulations and standards. This includes compliance with the General Data Protection Regulation (GDPR), the CAN-SPAM Act, and other relevant data protection laws applicable within Hong Kong and beyond. Our goal is to ensure that your Personal Data is handled in a manner that is secure, respectful of your privacy rights, and in compliance with all applicable legal requirements.

Marketing and Operational Compliance

In compliance with applicable laws and regulations, including but not limited to the General Data Protection Regulation (GDPR) and the CAN-SPAM Act, Bridgepoint Ventures Management Ltd. (the “Data Controller”) commits to ensuring that all marketing activities and operational workflows involving the processing of Personal Data of You (the “Data Subject”) are conducted in a lawful, fair, and transparent manner. The Data Controller will:

• Ensure that all marketing contracts are drafted and implemented in a way that complies with legal requirements.
• Provide strategic guidance to optimize marketing strategies and operational workflows, ensuring they align with applicable laws and ethical practices.
• Obtain explicit consent from the Data Subject prior to sending any marketing communications, as required by the GDPR and other relevant laws.
• Include an easy and accessible method for the Data Subject to withdraw consent and opt-out of receiving marketing communications at any time.
• Ensure that all marketing communications clearly identify the sender, contain a valid physical postal address, and comply with other requirements set forth by the CAN-SPAM Act.

This commitment to compliance protects the rights of the Data Subject and ensures that the processing of Personal Data is done with respect for the individual’s privacy and autonomy.

Performance Monitoring and Analytics

In the course of providing services, Bridgepoint Ventures Management Ltd. (“Data Controller”) may engage in performance monitoring and analytics involving the processing of Personal Data of the Data Subject (“You”). Such processing activities are designed to enhance the operational performance and provide actionable insights for informed decision-making.

The Data Controller commits to ensuring that all performance monitoring and analytics activities involving Personal Data are conducted in compliance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR) and the CAN-SPAM Act, as well as any other relevant legislation in Hong Kong.

Explicit Consent from You will be obtained before any Personal Data is processed for performance monitoring and analytics purposes. You have the right to withdraw your consent at any time, in accordance with the procedures set forth by the Data Controller.

All data collected through performance monitoring and analytics will be treated with the highest level of confidentiality and security. The Data Controller will implement appropriate technical and organizational measures to ensure the protection of your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Data Sharing and Transfer

In compliance with the data protection laws applicable within Hong Kong, including but not limited to the Personal Data (Privacy) Ordinance (Cap. 486), Bridgepoint Ventures Management Ltd. (‘Data Controller’) may share the Personal Data of the Data Subject (‘You’) with third parties and/or transfer it outside of Hong Kong under the following conditions:

1. The Data Controller ensures that any third party to whom Personal Data is transferred will provide a standard of protection to such data that is comparable to the protection under Hong Kong’s data protection laws.
2. Personal Data may be transferred to countries or territories outside Hong Kong only if:
o Such countries or territories ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
o The Data Subject has provided Explicit Consent to the transfer, after having been informed of the possible risks of such transfers for the Data Subject due to the absence of an adequate level of protection and appropriate safeguards.
3. The Data Controller will take all steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Statement and no transfer of Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

This clause does not override any rights the Data Subject has under the GDPR, CAN-SPAM Act, or any other applicable data protection laws and regulations.

Data Security Measures

In compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, Bridgepoint Ventures Management Ltd. (“Data Controller”) commits to implementing and maintaining comprehensive data security measures to protect the Personal Data of the Data Subject (“You”). These measures are designed to prevent unauthorized access, disclosure, alteration, and destruction of Personal Data.

• Encryption of Personal Data during transmission and while at rest.
• Strict access controls to ensure that only authorized personnel have access to Personal Data.
• Regular security assessments and audits to evaluate the effectiveness of the data security measures.
• Implementation of incident response protocols to promptly address any data breaches or security incidents.
• Training for employees on data protection best practices and the importance of maintaining the confidentiality and security of Personal Data.

The Data Controller will regularly review and update these security measures in accordance with the latest technological developments and regulatory requirements to ensure the ongoing protection of Personal Data.

Rights of Data Subjects

In accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, and to ensure the protection and respect of privacy, the Data Subject, referred to as “You,” has the following rights concerning their Personal Data, which is managed by the Data Controller, Bridgepoint Ventures Management Ltd.:

1. Right to Access: You have the right to request access to and obtain a copy of your Personal Data that is being processed.
2. Right to Rectification: You have the right to request the correction of inaccurate Personal Data concerning you.
3. Right to Erasure: You have the right to request the erasure of your Personal Data when it is no longer necessary for the purposes for which it was collected or otherwise processed.
4. Right to Restriction of Processing: You have the right to request a restriction on the processing of your Personal Data under certain conditions.
5. Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the Personal Data have been provided.
6. Right to Object: You have the right to object to the processing of your Personal Data based on particular grounds related to your specific situation.
7. Right to Withdraw Consent: Where the processing of Personal Data is based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
8. Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant data protection authority if you believe that the processing of your Personal Data infringes on your rights under the Personal Data (Privacy) Ordinance (Cap. 486).

The Data Controller shall provide information on action taken on a request pertaining to these rights without undue delay and in any event within one month of receipt of the request. This period may be extended by two further months where necessary, taking into accountthe complexity and number of the requests. The Data Controller will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Amendments to the Privacy Statement

Bridgepoint Ventures Management Ltd. (“Data Controller”) reserves the right to amend this Privacy Statement at any time. Any changes will be effective immediately upon the posting of the revised Privacy Statement on our website. Where applicable laws require, we will seek your consent for significant changes to the Privacy Statement that materially affect the use of your Personal Data. We encourage you to review our Privacy Statement periodically to be informed of how we are protecting your information.

By continuing to use our services after these changes are posted, you agree to the revised terms. If you do not agree to the revised Privacy Statement, you have the option to discontinue the use of our services. For significant changes, where required by law, we will also notify you by email or other direct communication methods to seek your Explicit Consent to the changes.

Governing Law and Jurisdiction

This Privacy Statement shall be governed by and construed in accordance with the laws of Hong Kong. Any disputes arising out of or in connection with this Privacy Statement, including any questions regarding its existence, validity, or termination, shall be referred to and finally resolved by the courts of Hong Kong. The parties expressly agree to submit to the exclusive jurisdiction of the courts of Hong Kong for the purpose of resolving any dispute relating to this Privacy Statement.