Last updated October 25, 2016.

This Privacy Policy describes how WLHK (‘we’) handles your personal information.

This includes the information that WLHK collects from you when you sign up for, use, access or otherwise interact with any WLHK applications, products, services, or on websites or other media such as Apps (collectively, “Services”), how we use and share that information, including information we may obtain from other sources, and the choices we offer.

This Privacy Policy sets out the following:

  • Collection of Information

  • Third Party Advertising and Analytics

  • Use of Information

  • Sharing of Information

  • Security

  • Your Choices

This policy applies to all information we collect through our Services, even if you have not signed up for a WLHK account or downloaded one of our applications. This policy does not, however, describe the practices of third parties that may collect information from you when you interact with them, including sellers that use WLHK to make payment for goods or services (“Sellers”).  We encourage you to ask them about their privacy practices before providing any information to them.

WLHK, as a firm based in Hong Kong, acts in order to accomplish local Laws. See: http://www.legislation.gov.hk/blis_pdf.nsf/6799165D2FEE3FA94825755E0033E532/B4DF8B4125C4214D482575EF000EC5FF/$FILE/CAP_486_e_b5.pdf

We may change this policy from time to time. If we make changes, we will notify you by posting the updated policy and revising the “Last Updated” date above. We encourage you to review the policy whenever you use our Services to stay informed about our information practices and about the choices available to you.

Collection of Information.

Information you Provide.

We collect information you provide, such as when you sign up for an WLHK account, when you provide information as part of our identity verification process, in the course of a transaction, or when you request a digital receipt. We may collect, but are not limited to collecting, the following: basic user information, such as your name, email address, mailing address, phone number, photograph, birth date.

We also collect information when you upload or send information to or through the Services about your products and services (including inventory, pricing and other data), participate in contests or promotions offered by WLHK or our partners, respond to our surveys, or otherwise communicate with us.

Some of our services also allow you to connect with people you already know. For example, you may upload information from your address book through the WLHK app. We will match the information you provide to the information provided by other users of WLHK in order to provide and improve the Service, including making it easier to find friends to whom you may send or request payments and/or information.

Information We Collect from Your Use of the Services.

We collect information about you when you use our Services, including as follows:

  • Transaction Information. When you use our Services to make or accept payments or money transfers, we collect information about when and where the transaction occurred, a description of the transactions, the payment or transfer amounts, billing and shipping information, and information about the devices and payment methods used to complete the transactions.

  • Location Information. When one of our applications is open on your mobile device, we periodically receive information about the location of the device. We may also collect location information about your device if you are near a Seller with whom you have auto check-in enabled. For more information and to learn how to disable location information, please see “Your Choices” below.

  • Device Information. We collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device’s interaction with our Services. We may also identify other software running on the device (but will not collect any content from such software) for anti-fraud and malware-prevention purposes.

  • Usage Information. We collect information about how you use our Services, including you access times, browser types and language, and Internet Protocol (“IP”) addresses.

  • Information Collected by Cookies and Web Beacons. We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. We beacons are electronic images that may be used in our Services or emails. We may use we beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.

Information We Collect From Other Sources.

We may also collect information about you from third parties, including but not limited to third-party verification services, credit bureaus, mailin list providers, and publicly available sources.

Third-Party Advertising and Analytics.

We do not allow third parties to serve advertisements in connection with our Services and to provide analytics services.

Use of Information.

We use information about you to provide, maintain, and improve our Services and to deliver the information and support you request, including receipts, technical notices, security alerts, and support and administrative messages.

We also use information about you to improve and personalize the Services. To take just one example, when you sign up for a WLHK account, we may associate certain information with your new account, such as information about other accounts you have or had with WLHK and prior transactions you made through the WLHK Services.

We may use information we collect to send you news and information about our Services and to communicate with you about products, services, contests, promotions, incentives, and rewards offered by us and select partners.

We may also use information about you to track and analyse trends and usage in connection with our Services; to process and deliver contest and promotion entries and rewards; to protect our rights or property; to verify your identity; to investigate and prevent fraud or other illegal activities; and for any other purpose disclosed to you in connection with our Services.

We may, or we may use third-party service providers to, process and store personal information in Hong Kong and other countries around the world and you agree to this transfer, storing and processing.

Digital receipts.

If you choose to receive receipts via email or text message, we store the email address or phone number you provide. We use your email address or phone number to send you a receipt for your purchase and to automatically send you digital receipts for future purchases you make from other Sellers. Digital receipts may contain additional messages, offers, or links that may be of interest to you. For example, you may be able to submit feedback, share your experience on social media, view your purchase history, join programs, visit websites, or take advantage of promotions. When you submit or share information through a receipt (such as submitting feedback), we may share that information with Sellers or Collectors who may receive or collect information from you. We encourage you to ask them about their privacy practices before providing any information to them. If at any time you wish to opt out of receiving automatic digital receipts or change your preferences, you may do so by following the instructions in the “Your Choices” section of this policy.

Sharing of Information.

We may share personal information about you as follows:

  • With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention and verification services), and including financial institutions, processors, payment card associations, and other entities that are part of the payment or transfer process;

  • With others who have signed up for WLHK accounts in order to provide our Services. For example, we may share information when you make or accept a payment or transfer using our Services. We may also share information about you when you are located near an WLHK Seller with whom you have auto check-in enabled;

  • In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business;

  • If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; to enforce applicable agreements of policies; to protect the security or integrity of our Services; and to protect us, our Sellers, end users, or the public from harm or illegal activities; and

  • With your consent.

Security.

We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold personal information at our own premises and with the assistance of our service providers.

Your Choices.

Location Information.

When you first launch our mobile applications, you will be asked to consent to the application’s collection of location information. We currently require this location information in order to provide our Services, so if you do not consent to this collection, you cannot use our Services. If you initially consent to our collection of location information at any time by changing the preferences on your mobile device. If you do so, the WLHK application will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove WLHK applications from your device.

Cookies.

When you use the Services, we try to make your experience simple and meaningful. When you access or use the Services, our web server sends a cookie to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application, and which store and sometimes track information about your use of the Services. Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We use cookies to:

  • remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users;

  • customise elements of the promotional layout and/or content of our website or application; and

  • collect anonymous statistical information about how you use the Services (including the lenght of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf. Most we and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set. You also can learn more about cookies by visiting www.allaboutcookies.org , which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

Preferences.

  • Personal Information. You may change or correct information about yourself by logging into your WLHK account at any time or by emailing as at ewac.hongkong@gmail.com. You may also email us if you wish to deactivate your account. We may retain archived copies of information about you and your transactions for a period of time that is consistent with applicable law.

  • Digital Receipts. If at any time you wish to opt out of receiving automatic digital receipts or change your preferences, you may do so by following the instructions in your digital receipts.

  • Promotional Communications. You may opt out of receiving promotionals email or text messages from WLHK by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

Contact.

Please contact our Privacy Department with any questions or concerns regarding our policy.

WLHK

ewac.hongkong@gmail.com