PRIVACY POLICY

Last updated: Jan 1, 2021  

 

Introduction 

Welcome to HomeBozz and AssetBozz! 

AssetBozz Limited (“AssetBozz”; “we”) of Room 804A, 8/F World Wide House, 19 Des Voeux Road, Central, Hong Kong SAR, a company incorporated under the laws of Hong Kong Special Administrative Region, operates and maintains the cloud-based HomeBozz and AssetBozz computerized maintenance management systems (the “Software”). Our services are made available to you (“User”, “you”) through our websites, including but not limited to https://www.homebozz.comhttps://online.homebozz.comhttps://www.assetbozz.comhttps://online.assetbozz.com (the "Websites") and our HomeBozz, HomeBozz for Business, and AssetBozz mobile apps (the "Apps"), Our Software, Websites and Apps together constitute our service (the "Service"). 

We take the privacy of your personal data very seriously. In order for us to provide you with personalized Service, we require you to provide certain Personal Data (as defined in this Policy) about yourself. In collecting your personal data, we comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the laws of Hong Kong. This Privacy Policy (“Policy”) describes the types of personal data we collect from you, how we use the personal data, with whom we share it, and the choices available to you regarding our use of your personal data. We also describe the measures we take to protect the security of your personal data and how you can contact us about our data privacy practices.  

Please read this Policy carefully. This Policy, together with our Terms of Use (“Terms”) as set out in the Websites, apply to your use of the Service. Unless otherwise specified, this Policy adopts the same nomenclature used in the Terms.  

The provision of your data is voluntary. You are free to choose which data you want to provide to us or whether you want to provide us with information at all. However, some personal data, such as your name(*mandatory), email address(*mandatory) and mobile phone number(*mandatory) may be necessary for the performance of our contractual obligations. Without providing this information, you will not be able to access part or all of the Service. By agreeing to provide such data using our Service you agree to the processing of your data in accordance with this Policy. If you do not agree to the processing of your data in the way this Policy describes, please do not provide your data and, where appropriate, stop using our Service.  

If you are using our Service on behalf of a company, association, partnership, government or other organisation (“your company”), you agree to notify your company’s relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Data we collect or you provide to us from time to time of the collection of their Personal Data, and you agree to obtain their consent to the processing of their Personal Data in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to "you", this includes you and any abovementioned persons of your company.  

This Privacy Policy addresses the following questions: 

1. What types of information do we collect? 

 The types of information we may collect include both:- 

(i) any information, or combination of information, that relates to you, that can be used (either alone or when connected with other information to which we may have access, you can be individually identified, either directly or indirect) to identify you (“Personal Data”) provided to us or collected by us.  

(ii) information that is not reasonably practicable to directly or indirectly identify you ("Non-Personal Data").  

The information we collect may include but not limited to:- 

(i) your title, name (including first name and last name), mobile phone number, email address; 

(ii) if you access our Service through a Company Subscription, your employer/company and your post;  

(iii) your username and password; 

(iv) payment information, such as credit card information, billing address, particulars of your Global Payments account. We may also collect your financial information from your payment service providers such as Global Payments and/or your card-issuing bank; 

(v) technical information, such as your IP address, MAC address, mobile carrier-related information, browser settings, and other internet log on information of your computer, mobile, or other electronic/communication devices;  

(vi) real-time geographic location data of you or your assets. Some of our location-enabled functions require such information to work. If you wish to use the particular features, you will be asked to consent to your geographic location data being used for this purpose. You can withdraw your consent at any time by disabling such functions but you may lose access to such functions; 

(vii) analytics of your general usage pattern of our Service, such as the date and time you access our Service, which services you use most frequently, browsing records, referring websites, and other internet log on information of your computer, mobile, or other electronic/communication devices;  

(viii) your preferences in receiving promotion from us (if any) and your communication preferences. 

Our Service, Apps and Websites are not intended for children and we do NOT collect Personal Data relating to children. 

We do NOT collect any sensitive Personal Data about you, including details about your race or ethnicity, religious or philosophical beliefs, trade union membership, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

 

2. What does this Policy apply to? 

This Policy applies to Personal Data provided to us or collected by us in the course of your use of our Service, as well as any services accessible on the Websites, the Apps and the Software but it does NOT apply to Personal Data that you disclose to: - 

(i) any third parties, including any other User or any maintenance service providers, you may have access to through our Service (for example through SMS or through our in-app instant messaging service). Please consider carefully what you communicate to third parties through our Service, which we will not be responsible for; 

(ii) companies, organisations or individuals displayed on the Software, the Websites and/or the Apps by virtue of your action or a User’s actions.  

(iii) companies, organisations, individuals or Users that advertise products or services (if any) on the Software, the Websites and/or the Apps. 

Our Service, Websites and/or Apps may contain links to third party websites or services. Please note that these websites and any services that may be accessible through them may have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check their privacy policies (if any) before you submit any personal data to these third-party websites or use these third-party services. 

 

3. How do we collect information? 

You may need to provide some Personal Data when you :-  

(i) subscribe for a User Account and/or when we verify your identity;  

(ii) login to our Websites and/or the Apps to access the Service; 

(iii) install our Apps; 

(iv) contact other Users via our Service, including when you use our in-app instant messaging services; 

(v) contact us whether in person, by phone, by email or by our in-app instant messaging services to make enquires or provide information or make complaints or give us feedbacks; or 

(vi) subscribe to our marketing or promotional materials, when they are available for subscription. 

From time to time, we may automatically record information that your browser and/or your device sends whenever you use our Service via cookies, server logs and other similar technologies. Please refer to section 10 on “What are cookies and how do we use them?”).  

We may also obtain Personal Data about you from other sources, for example: - 

(i) if you access our Service through a Company Subscription, we might have collected your names and/or contact particulars through your Account Administrator;  

(ii) if you are a maintenance service provider, your customers might have entered your name and/or contact particulars into our system. Under such circumstance, the User concerned should have obtained your consent for the use of your Personal Data by us;  

(iii) your contact particulars, financial and transactional data may be provided by payment service providers such as Global Payments or card-issuing banks; 

(iv) if you subscribe to our Service through a reseller, we might have collected your data from said reseller; 

 (v) your data may be provided by analytics providers, search information providers;  

(vi) your identity and contact particulars may be located from publicly available sources. 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your pattern of use to calculate the percentage of Users using a specific function of our Services. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data and it will be governed by this Policy. 

 

4. Why do we collect Personal Data? 

 

Your Personal Data may be used for one or more of the following purposes (“Purposes”): 

(i) Creating and administering your User Account;  

(ii) Verifying your identity and/or your User Account; 

(iii) Providing you with our Service; 

(iv) Identifying Users using our Service and auditing Users’ use of our Service; 

(v) Processing billing and payment, verifying financial transaction in relation to payments you have made, transferring such information to financial institutions for processing payments; 

(vi) Providing service job alerts and notifications; 

(vii) Providing in-app chat service linked to your User Account or where you have been designated by a User as a service provider contactable via your mobile phone number; 

(viii) Backing up your User Data for retrieval;  

(ix) Allowing two factor authentication to log in to your User Account and/or to view service jobs and requests; 

(x) Enabling our team to communicate with you, and/or to provide you with customer service or support service; 

(xi) Handling and responding to your inquiries, suggestions or complaints, gathering your feedbacks on how we can improve our Service; 

(xii) Conducting analysis to help us better understand our customers and to improve our Service; 

(xiii) Notifying you of changes to our Terms or this Policy; 

(xiv) Providing you with our marketing materials;  

(xv) Fulfilling our obligations to maintain records; 

(xvi) Detecting, investigating and preventing fraud and other illegal activities 

(xvii) Meeting legal, regulatory or compliance requirements, dealing with enquires from law enforcement or regulatory bodies or for the purpose of obtaining legal advice; and 

(xviii) For any other purposes directly related to any of the above Purposes. 

We will only use your Personal Data for the Purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original Purposes.  

If we need to use your Personal Data for a purpose unrelated to the above Purposes, we will notify you and obtain your consent. You are free to deny your consent and the denial will have no negative consequences for you. You are also free to withdraw your consent at any time. If you have granted us consent to use your Personal Data, we will use it only for the new purposes you have consented to. If you wish to have further explanations, please contact our Data Privacy officer at privacy@assetbozz.com

 

5. Where do we process or store your Personal Data? 

Our servers are located in Hong Kong. We also have support, engineering and other teams that support the provision of Service to you who may be located around the world. Your data may be accessed from such locations.  

We may transfer the Personal Data we collect about you to countries other than the country in which the information was originally collected (including but not limited to Hong Kong) and your Personal Data may be processed and stored outside your country of residence. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy. 

 

6. What information do we share and how do we share them? 

Protecting the privacy and security of your Personal Data is our utmost priority at AssetBozz. Except as described here, we do not share, rent, or sell, or otherwise disclose Personal Data we collect about you.  

However, as may be required for the performance of the Purposes discussed in earlier sections, we may share your Personal Data on a confidential basis with our licensors, licensees, service providers (who may or may not be located outside Hong Kong) who perform services on our behalf based on our instructions. We do not authorize these licensors, licensees, service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card or Global Payment payments, service providers that provide web or server hosting, SMS service providers, translation service providers, providers of location and tracking data, etc. 

In addition, we may disclose information about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials;  (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; (iv) to enforce our agreements with you; (v) with your express consent; or (vi) to seek professional advice from our legal advisors, auditors and accountants.  

To the extent permitted by law, we reserve the right to transfer Personal Data we have about you in the event we sell or transfer all or a portion of our business or assets or if we are involved in any merger, acquisition or corporate reorganization. Should such a sale, transfer, merger, acquisition or restructuring occur, we will use reasonable endeavour to direct the transferee to use your Personal Data you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of that information.  

 

7. How long do we keep hold of your Personal Data? 

We may retain and use your Personal Data for as long as necessary to fulfill the Purposes set out above and in a manner compatible with the required laws and regulations. We will endeavour to keep your information secured, accurate and up to date, and not keep it for longer than is necessary. We cannot remove your data when there is a legal storage requirement such as bookkeeping rules (such as keeping invoices and receipts for tax and bookkeeping purposes), or when there is a legal ground to keep the data, such as when you have a live Subscription or other on-going contractual relationships with us. 

Generally speaking, subject to any legal, statutory, regulatory or accounting requirements which may require us to keep certain data for a longer period of time, we will endeavour to completely delete or anonymize your Personal Data 2 months after the expiry or termination of your Subscription.  

 

8. How do we protect your Personal Data? 

We implement appropriate administrative, technical and physical safeguards to maintain the safety of your Personal Data and to protect them against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use, such as firewalls, data encryption, two factor authentication, etc. 

However, although we do our best to protect your Personal Data, no security system is perfect, and we cannot promise that your Personal Data will remain secure in all circumstances, including the security of your Personal Data during transmission to us or the security of data on your mobile device. Any transmission of Personal Data is at your own risk. 

 

9. What rights do you have? 

You have the right to request a copy of the Personal Data that we hold about you and, if the Personal Data that we hold about you that is inaccurate or incomplete, to correct those data. We will seek to deal with your data access or data correction requests without undue delay. In the event that we are unable to comply with your requests to have access to or correction of your Personal Data, we will provide you with a reason as to why.  

To make a request, please send an email to our Data Privacy Officer at privacy@assetbozz.com specifying what Personal Data you seek to obtain or to correct. We may not be able to comply with your request if not sufficient information is given. Please note that we may need to verify your identity and/or authority before we can handle your request. We reserve the right to charge reasonable expenses in complying with your requests.   

Kindly note that not all data we store about you is Personal Data. You have no right to, and we have no obligation to comply with, requests for and request of correction for Non-Personal Data. Please refer to our Terms of Use if you are minded to obtain copies or backups of Non-Personal Data you have stored with us.  

 

10. What are cookies and how do we use them? 

Cookies are small bits of information which asks for permission to be placed on your computer's hard drive or your mobile device’s storage. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.   

We use traffic log cookies to identify which pages of the Websites and/or Service are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to your needs. Overall, cookies help us provide you with a better experience, by enabling us to monitor which parts of our Service you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.  

We only use this information for statistical analysis purposes and then the data is removed from the system. 

We use the following cookies:- 

(i) Strictly necessary cookies.  These are cookies that are required for the operation of the Service, and include, for example, cookies that enable you to log into secure areas of the Service.   

(ii) Analytical/performance cookies.  These cookies allow us to recognize and count the number of visitors and to see how visitors move around and use our Service. This helps us to improve the way our Service work, for example, by ensuring that users are finding what they are looking for easily. These cookies are also used to help us understand what interests our Users; 

(iii) Functionality cookies.  These are used to recognise you when you return to the Service. This enables us to personalise our content for you, greet you by name and remember your preferences, for example, your choice of language or region or currency, etc.;   

(iv) Location-based cookies. These cookies are used to identify your location or location of your assets and send location-based push notifications to you; and 

(v) Targeting cookies. These cookies record your visit to the Service, the pages you have visited and the links you have followed. We will use this information to make our Service and any material displayed on it more relevant to your use. 

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to notify you and/or to decline cookies if you prefer. However, if you disable cookies, you may not be able to create an AssetBozz profile correctly, and therefore you may not be able to receive all the benefits of our Service or to use all features of our Service. Also, by not using cookies, features within our Service may not function properly. 

Please note that some cookies on the Service may be managed by third parties, including, for example, Google. These cookies are likely to be analytical/performance cookies or targeting cookies. You should refer to the third parties’ own cookie and privacy policies for information about how they may use your information. 

Apart from cookies, we may also collect information by automated means, such as web server logs, tracking URLs, etc. 

 

11. Marketing 

When you register to our Service, you may be given the option to subscribe to our product related news. By subscribing to our product news, you grant us your consent to use your Personal Data (such as your name, email address) to send you marketing and/or promotional materials about the services provided by us from time to time.  

You may withdraw your consent for us to use your Personal Data in our direct marketing activities at any time and/or request us to stop contacting you for marketing purposes by:- 

(i) indicating your preference where appropriate (including opting out from receiving marketing information from us); or 

(ii) unsubscribing to our newsletters at any time; or  

(iii) contacting our Data Privacy Officer at privacy@assetbozz.com

We will not provide, sell, distribute or lease your Personal Data to third parties for direct marketing or other unrelated purposes without your consent. 

 

12. Your duty to inform us of changes to your Personal Data 

 It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your Subscription. You may change your Personal Data at the “My Account” page or contact our Data Privacy Officer at privacy@assetbozz.com

 

13. Updates and Changes to this Policy 

We keep this Policy under regular review to accommodate new technologies, industry practices, regulatory requirements or for other purposes. Please revisit our Privacy Policy to stay updated on any changes. Our Policy may change and if it does, these changes will be posted on this page and, where appropriate, notified to you in writing. The new Policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Apps, the Websites and/or the Service. Please revisit our Privacy Policy to stay updated on any changes. 

 

14. Enquiries 

Any enquiries regarding this Policy or our personal data privacy practice may be addressed to our Data Privacy Officer at privacy@assetbozz.com.  

 

15. Section applicable to Users or visitors based in the European Economic Area (“EEA”) 

If you are a User or visitor in the EEA, this section is also applicable to you in addition to the other sections in this Policy: - 

A. AssetBozz Limited of Room 804A, 8/F World Wide House, 19 Des Voeux Road, Central, Hong Kong SAR will be the data controller of your Personal Data. 

B. Our servers are located in Hong Kong. Hence all Personal Information which you provide will automatically be transferred to us in Hong Kong. Your Personal Data will be accessed, transferred or stored outside the EEA, including in countries which may have a lower level of data protection than under European Union law.  When we do so, we will use appropriate safeguards such as contractual terms to protect any Personal Data being transferred. 

C. We will only use your Personal Data when the European Union law allows us to do so. Most commonly we will use your Personal Data in the following circumstances:-   

(i) where you have consented before the processing (“Consent”);  

(ii) where we need to perform a contract we are about to enter or have entered with you (“Contract Performance”);  

(iii) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”); 

(iv) where we need to comply with a legal or regulatory obligation (“Legal Obligations”).  

We rely on the following basis for collecting and processing your Personal Data:-

 

 

 

 

 

 

Purpose/Activity 

 

 

Creating and administering your User Account; 

Verifying your identity and/or your User Account 

 

 

 

Providing you with our Service 

Identifying Users using our Service and auditing Users’ use of our Service; 

Processing billing and payment, verifying financial transaction in relation to payments you have made, transferring such information to financial institutions for processing payments 

 

 

 

Providing service job alerts and notifications 

 

 

 

 

Providing in-app chat service linked to your User Account or where you have been designated as a service provider contactable via your mobile phone number by a User 

 

 

 

Backing up your User Data for retrieval 

 

Allowing two factor authentication to log in to your User Account and/or to view service jobs and requests 

 

 

Enabling our team to communicate with you, and/or to provide you with customer service or support service;  

Handling and responding to your inquiries, suggestions or complaints, gathering your feedbacks on how we can improve our Service 

Conducting analysis to help us better understand our customers and to improve our Service 

 

Conducting analysis to help us better understand our customers and to improve our Service 

Notifying you of changes to our Terms or this Policy 

 

 

 

 

Providing you with marketing materials 

Fulfilling our obligations to maintain records 

Detecting, investigating and preventing fraud and other illegal activities 

 

Meeting legal, regulatory or compliance requirements, dealing with enquires from law enforcement or regulatory bodies or for the purpose of obtaining legal advice

 

 

 

 

 

 

Lawful basis for processing 

  • Contract Performance 

  • Legitimate Interest (to allow us to perform our obligations and provide services to you) 

  • Consent 

  • Contract Performance 

  • Legitimate Interests (to allow us to perform our obligations and provide services to you) 

  • Consent 

  • Legitimate Interests (to recover debts due to us) 

  • ​Contract Performance 

  • Legitimate Interests (to allow us to perform our obligations and provide services to you) 

  • Contract Performance 

  • Legitimate Interests (to allow us to perform our obligations and provide services to you) 

 

 

  • ​Contract Performance 

  • Legitimate Interests (to allow us to perform our obligations and provide services to you) 

 

  • Legitimate Interests (to help us to protect the security of User’s data) 

 

 

  • Contract Performance 

  • Legitimate Interests (to allow us to correspond with you in connection with our Service) 

  • Legal Obligation 

  • Consent 

 

  • Legitimate Interests (to allow us to improve our Service) 

  • Contract Performance 

  • Legitimate Interests (to notify you of your rights and our rights) 

  • Legal Obligation 

  • Consent 

 

  • Legal Obligation 

  • Legitimate Interests (to maintain our business operation) 

  • Legal Obligation 

  • Legitimate Interests (to allow us to guard against fraud and other unlawful activity) 

  • Legal Obligation 

  • Legitimate Interests (to maintain our business operation, to allow us to guard against fraud and other unlawful activity) 

D. In addition to the rights outlined in section 9 of this Policy, you also have the rights under the General Data Protection Regulation (GDPR) to, in certain circumstances:- 

(i) to request erasure of your Personal Data, i.e. you may ask us to delete or remove personal data where there is no good reason for us continuing to process it;  

(ii) to object to our processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) as its lawful basis and if you believe your fundamental rights and freedoms outweigh our legitimate interests; 

(iii) to ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it ported directly to a third party; 

(iv) to request us to suspend processing of your Personal Data where you want us to establish the data’s accuracy; or where our use of the data is unlawful but you do not want us to erase it; or where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; 

(v) to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide part or all of our Service to you; and 

(vi) to ask for certain automated decisions (if any) to be reconsidered by our staff manually. 

You may exercise your rights by contacting our Data Privacy Officer at privacy@assetbozz.com. Please note that we may need to verify your identity and/or authority before we can handle your request. We reserve the right to charge reasonable expenses in complying with your requests. Please however note that we may not always be able to comply with your requests for specific legal reasons, in which case you will be notified in writing. We will seek to deal with your data requests without undue delay and within 30 days. 

E. You also have a right to lodge a complaint with your national data protection supervisory authority at any time. However, we encourage you to first contact us.