Top Professionals Technology Company Limited(collectively "we", the "Company", "TOPPROT" )wholly owned this website and mobile application, respect the privacy rights of visitors to theplatform and of individuals who participate in, access or sign up to any of the Company's services,activities or online content (collectively referred to as "Services"). We endeavor to ensure that allour collection, transmission, storage and usage of personal data shall be carried out in compliancewith the Personal Data (Privacy) Ordinance, Cap 486 of the laws of the Hong Kong Special Administrative Region ("PDPO").

The term "personal data" shall have the meaning ascribed to it by PDPO.

PURPOSE OF COLLECTION AND USE OF PERSONAL DATA

You need not supply any personal data in order to access the website and application. When youparticipate in, access or sign up to any of the Services, personal data is collected from you toenable us to provide you with the Services. You may decline to provide us with the requested personal data, but in such case we may not be able to provide the Services to you. By submittingyour personal data you consent to the use of that data as set out in this Privacy Policy Statement.

Personal data collected from you may be used by the Company for:

identifying you and any accounts you hold with us

enabling the provision of the Services to you

conducting identity verification and/or credit checks

processing of payment instructions or collection of amounts outstanding from you in relation to the provision of the Services

order processing, billing and fulfilment direct marketing of the Services

direct marketing of the products and services of the Company’s business partners

designing services for you

conducting research, statistical analysis and behavioral analysis

conducting program viewership survey and analysis

customer profiling and analysing your purchasing preferences

customising the Company’s website and its content to your particular preferences

provisioning of customer services

handling your complaints and account enquiries

fraud prevention and detection

auditing

making such disclosures as required by applicable laws, rules and regulationsany other purposes directly related to the purpose for which the personal data were originally collected

TYPES OF PERSONAL DATA COLLECTED

Types of personal data collected by the Company may include:

1. Your personal information and contact information such as your name, gender, date of birth,identity card number, telephone number, social media contact, email address, residential address,mailing address, and billing address;

2. Your business information such as business registration number (if applicable), company name and business title;

3. Your account details, including account numbers, or user accounts;

4. Your house hold income range, and personal interest; and

5. IP address, real-time geographic location data, browser settings, browsing records, and/orother Internet log information of your computer or mobile device.

CONFIDENTIALITY, DISCLOSURE AND SECURITY OF PERSONAL DATA

The Company does not trade your personal information and contact information for gain withoutyour written consent. All personal data collected and held by the Company will be kept confidential, but where disclosure is necessary for the Company to comply with any statutory obligations orrequirements, or for the Company to provide the Services to you or to carry out the originalpurpose, or a directly related purpose, for which the personal data were collected, those data maybe provided to the following parties (whether within or outside Hong Kong): Competent court of law, law enforcement agencies, or other governmental or statutory authorities,institutions or organisations; Company’s associated companies, contractors, agents, sellers or suppliers of the goods/services, or other service operators, who are involved in the sale and marketing, administration or provisionof the Services; Any other person under a duty of confidentiality to the Company including a member of its group ofcompanies, IT consultants, data processors, auditors, accountants, or lawyers, which hasunder taken to keep such information confidential; andBanks, financial institutions, credit card issuing companies or debt collection agencies.Any questions, comments, suggestions or information other than personal data sent or posted to our website, or any part of the site by you will be considered as voluntarily provided to the Company on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce,disclose, transmit, publish and/or post elsewhere such information freely, including passing it toany associated company for example, in connection with the development and marketing of services and to meet user needs.

All reasonable efforts are made to ensure that any personal data held by the Company is stored ina secure and safe place.All personal data which we collect is kept confidential to the best of our ability. You will appreciate however, that we cannot guarantee the security of transmission.

TRANSFER OF PERSONAL DATA OUTSIDE HONG KONG

If necessary, the Company may transfer the personal data to places outside the Hong Kong Special Administrative Region for carrying out the purposes, or the directly related purposes, forwhich the personal data were collected. All the transfer of those personal data will be carried out incompliance with the requirements of the PDPO.

RETENTION OF PERSONAL DATA

Unless there is a mandatory legal requirement for us to keep your personal data for a specifiedperiod, we will only retain your personal data for as long as is necessary to fulfill the purpose forwhich the personal data were originally collected.

DIRECT MARKETING

The Company intends to use the personal data collected from you in direct marketing and theCompany requires your consent for that purpose. Your name, telephone number, email address,contact address, social media contact, products and service portfolio information, transactionpattern and behavior, browsing records, content viewing habits, and personal interest held by the Company may be used by the Company in direct marketing of the Services and the followingclasses of products or services offered by the Company’s business partners or the register edmerchants of website and application, including, but not limiting to, mother and baby, beauty and health, electronics, fashion, food and beverage, household, lifestyle, sports, telecommunications,media and entertainment, which may be of interest to you.We may contact you by mail, telephone, social media, SMS, text/picture/video message, fax,email. If you prefer not to receive any direct marketing communications from us, you can opt out atany time by updating your preferences through your registered account or a unsubscribe linkprovided. Upon receipt of your request, we shall cease to so use your personal data without chargeto you.

USE OF COOKIES

A cookie is a small text file which is placed onto your computer (or other electronic device) whenyou access the Company’s website. We use cookies on our website to:

recognise you whenever you visit this websiteobtain information about your preferences, viewing and browsing behavior, online movements anduse of the Internetkeep track of the items stored in your shopping basket and take you through the checkout processcarry out research and statistical analysis to help improve our Services and to help us betterunderstand our visitor and customer requirements and intereststarget our marketing and advertising campaigns and those of our business partners andadvertisers more effectively by providing interest-based advertisements that are personalised toyour interestsmake your online experience more efficient and enjoyableenable tighter security

The information we obtain from our use of cookies may not contain your personal data. Althoughwe may obtain information about your computer or other electronic device such as IP address,browser settings, browsing records, and/or other Internet log information, this may not be able toidentity you personally. To the extent that non-personal data is combined with personal data, wetreat the combined data as personal data for the purposes of this Privacy Policy Statement. Incertain circumstances we may collect personal data about you, but only where you voluntarilyprovide it by completing an online form, or where you purchase goods from our website or use theServices.

If you want to disallow the use of cookies, you can do so on your own web browser. If you disablecookies, you acknowledge that you may not be able to use some of the functionality of our website.

LINKS

This Privacy Policy Statement only applies to the Company’s Website and mobile application. Ourwebsite may contain links to other sites and pages. By activating a link, such as for example byclicking on the banner of an advertiser, you leave our website and the Company does not exercisecontrol over any personal data or any other information you give to any other entity after you haveleft our website. Access to and use of such other websites is at your own risk.

DATA ACCESS AND CORRECTION

If you have any query in relation to the Company’s privacy policy or you wish to access or correct your personal data held by us, you may contact us by writing to the following address:

Top Professionals Technology Company Limited

10/F, New Hennessy Tower, 263 Hennessy Road, Wan Chai, Hong Kong 

For the attention of: Personal Data Officer

The Company reserves the right to charge you a reasonable fee for complying with a data access request as permitted by the PDPO.