1.Privacy generally

This privacy policy applies to the handling of personal data by Jupiter Fifths Technology Limited (Jupiter Fifths, we, us, our). We understand the importance of protecting an individual’s personal data. This privacy policy sets out how we aim to protect your personal data, your rights in relation to your personal data if you provide to us and how we collect, hold, use, disclose, and otherwise manage, your personal data when we provide you with our products and services, and when you access our websites. In collecting, holding, using, disclosing and otherwise managing your personal data, we will comply with the Personal Data (Privacy) Ordinance (Cap. 486) and the Personal Data (Privacy) (Amendment) Ordinance (Applicable Laws). We will regularly review our policies and procedures regarding personal data and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on the Jupiter Fifths website, https://www.jup-tech.com, or can otherwise be obtained by contacting us and requesting a copy.

2.Kinds of personal data collected

Personal data means information relating directly or indirectly to a living individual; from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and in a form in which access to or processing of the data is practicable.

We operate the business of game development and publishing as well as provide game marketing services to our clients. In conducting this business, or as a result of our other interactions or dealings with you, we may collect your personal data.

The kinds of personal data that we collect will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal data we collect may include:

your contact information such as your name, telephone number and email address;
your preference information regarding our products and services;
details regarding the transactions you undertake in respect of our business; and
other information necessary to provide you with information regarding our products or services or undertake any transactions or dealings with you.

We may also hold other kinds of personal data as permitted or required by law or other kinds of personal data that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.

3.How we collect personal data

Generally, we collect your personal data directly from you. For example, we may collect your personal data:

when you register or apply for an account with us, request information or services from us, or otherwise provide us with your details;
where you enter into, or propose to enter into, a transaction with us, including the provision of our products or services;
where you use our websites, applications, products or other online services or otherwise interact with us; or
if you post information to our website, application or any of our social media sites or otherwise interact with us.

There may be occasions when we collect your personal data from someone other than you, for example:

from our other service providers that help us provide our services;
from our related entities, including but not limited to holding companies or affiliated companies;
from third parties you authorise to disclose your information to us;
from a publicly maintained record or other publicly available sources of information including social media and similar websites; or
from third parties if you connect to our services or register an account with us using an external third-party application, such as Facebook or Google.

Generally, we will only collect your personal data from sources other than you if it is unreasonable or impracticable to collect that personal data from you.

4.Purposes for which personal data is used

Generally speaking, we collect, hold, use or disclose personal data so that we can maintain, improve and provide you with our products and services.

Some examples of the purposes for which we collect, hold, use and disclose your personal data include to:

determine your eligibility for or products and services, including verifying your identity;
administer services and products to you;
communicate with you, including informing you of changes and updates to our policies, terms and conditions, and other administrative information;
help us to manage the services we provide to you, including personalising your experience with our services;
provide you with marketing, advertising and promotional information, materials and/or documents relating to game-related services that may be of interest to you or for which you may be eligible (as detailed in paragraph 5 below);
enforce obligations owed to us;
respond to your queries and provide you with information you request from us;
conduct our business and facilitate the supply of our services to you;
contact you to obtain your feedback regarding our products or services or to conduct other market research;
administer, manage and process any transactions you enter into, or propose to enter into, with us;
conduct investigations in cases of fraud, credit or data security risks;
analyse the information we collect so that we can administer, support, improve and develop our business and the services we offer (including by monitoring or recording our interactions with you for training purposes);
establish, exercise or defend a legal right or to participate in any legal or administrative proceedings; and
comply with the obligations of Jupiter Fifths under any applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities.

In addition to the purposes listed above, we may use your personal data for purposes related to the above purposes, other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.

Where personal data is used or disclosed, we take steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal data to us. However, without certain information from you, we may not be able to provide services or information to you or may be limited in how we can interact with you.

5.Use of personal data for marketing purposes

In addition to the purposes outlined in paragraph 4 above, we may use and disclose your personal data in order to inform you of promotions, competitions, giveaways, events, goods or services that may be of interest to you. This may include we disclosing the information to our related companies or other entities with which we have a commercial relationship or arrangement for the purpose of the other entity contacting you for such marketing purposes. We may also use your personal data to invite you to participate in marketing research, surveys and other similar activities.

You can choose to receive marketing and other promotional materials through various modes including but not limited to email, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In respect of sending telemarketing messages to your telephone number via short message service, telephone calls (voice or video), facsimile and other mobile messaging services, we will do so only if You have provided your clear and unambiguous consent in writing or other recorded form for us to do so.

If you do not wish to receive such communications, you can opt-out by contacting us via the contact details set out in paragraph 13 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you

6. Disclosure of personal data

We disclose your personal data for the purpose for which we collect it. As a result, generally, we may disclose your personal data for a purpose set out in paragraphs 4 and 5 of this privacy policy, to the following persons. This may include disclosing your personal data to:

our related companies;
service providers and contractors and other third parties and their respective officers, employees, agents or subcontractors who provide goods or services to us (including our technology service providers, our business consultants, risk, credit, compliance and identification verification companies, legal and accounting firms, auditors, insurers and other professional advisers or administration service providers);
other third parties that are integral to the provision of our services;
people or entities considering acquiring an interest in Jupiter Fifths or any business or assets of Jupiter Fifths;
other parties who invest in or acquire an interest in Jupiter Fifths or any business or assets of Jupiter Fifths;
relevant regulatory bodies, government, tax authorities, law enforcement agencies or other administrative, self-regulatory or statutory agencies, or stock exchange or clearing house where required by law; and
any other party to whom you authorise us to disclose your personal data to.

We may also disclose your personal data for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.

If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

7.Overseas disclosures

We may transfer your personal data to countries/territories outside Your area where any of our related companies or service providers may be located. To the extent that we may need to transfer your personal data overseas, we will protect the personal data so transferred and ensure that we provide a standard of protection that is comparable to the protection under Applicable Laws. We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal data in a way that is inconsistent with the obligations imposed under Applicable Laws.

8.Links to other websites

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including websites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website has its own privacy practices, as described in that website’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that website. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot be and are not responsible for any information that you may submit to that website.

9.Cookies

When you visit our websites or other online services, we will generally leave a ‘Cookie’ in the memory of your web browser. The website or other online service may only function properly if Cookies are enabled. Our websites and online services may use persistent Cookies to authenticate you as a user and display content that is relevant and specific to you.

Cookies are very small files that store information about your visit to and use of a website. Most major commercial Internet sites use them and they make your Internet surfing more useful and less time-consuming because they store information that is reusable each time you visit our website, such as birthday and other preferences you have chosen to share with us.

Cookies cannot access and read the files on your hard drive. They do allow us to provide information and products that are more meaningful to you without asking you the same questions every time you visit us. You may get Cookies from our advertisers. We cannot pre-screen these Cookies since they come directly to you from other sites. We hope you will want the better service that Cookies allow, but if you prefer, you can set your browser to refuse Cookies. However, by doing that, your access to our website, may be compromised or limited. This may also affect the provision of certain services through our website.

10.Security of personal data

We take steps reasonable in the circumstances to ensure that the personal data it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

We hold personal data in electronic forms in secure databases on secure premises, accessible only with the appropriate passwords by authorised staff, contractors or agents on a “need to know” basis and is disclosed or shared using secured methods (personal data is encrypted when necessary). Where personal data is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.

The processes and systems we use to secure your personal data include:

a)the use of identity and access management technologies to control access to systems on which information is processed and stored;
b)the implementation of strict internal security standards and confidentiality policies when sharing of personal data between our related companies;
c)requiring all employees to comply with internal information security policies and keep information secure;
d)requiring all employees to complete training about information security; and
e)monitoring and regularly reviewing our practice against our own policies and against industry best practice.

We have in place procedures for training our employees about their obligations under this privacy policy, disciplining them for failure to follow this privacy policy. We also have in place internal procedures to confirm general company compliance with this privacy policy.

We will destroy or de-identify personal data in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.

11.Access and correction

We take steps reasonable in the circumstances to ensure any personal data it holds is accurate, up-to-date, complete, relevant and not misleading.

In addition, under Applicable Laws, you have a right to seek access to and correction of your personal data that is collected and held by us. If at any time you would like to access or correct the personal data that we hold about you, or you would like more information on our approach to privacy, please contact us using the details set out in paragraph 13 below. We will grant access to the extent required or authorised by Applicable Laws or other laws and take steps reasonable in the circumstances to correct personal data where necessary and appropriate.

To obtain access to your personal data:

a)you will have to provide proof of identity to ensure that personal data is provided only to the correct individuals and that the privacy of others is protected;
b)we request that you be reasonably specific about the information you require; and
c)we may charge you a reasonable administration fee, which reflects and will not exceed the cost to us for providing access in accordance with your request.

We will endeavour to respond to your request to access or correct your personal data within 30 business days from your request. If we refuse your request to access or correct your personal data, we will provide you with written reasons for the refusal and details of complaint mechanisms.

If you are dissatisfied with our refusal to grant access to, or correct, your personal data, you may make a complaint to the Office of the Privacy Commissioner for Personal Data.

12.Personal data related to minors

We attach great importance to the protection of the personal data of minors, and minors under the age of 18 are not allowed to use our services without the consent of their legal guardians. If you are the legal guardian of a minor under the age of 18, you should supervise and control the minor’s use of our services and ensure that the minor has obtained your express consent before providing personal data to us.

In the event that we collect personal data from a minor with the consent of a legal guardian, we will only use or publicly disclose this information as permitted by law, with the express consent of the legal guardian, or as necessary to protect the minor.

If a minor uses our services without the consent of his/her legal guardian, the minor’s legal guardian has the right to contact us and request us to delete the minor’s personal data, which we will do immediately after verification.

If we discover that we have collected personal data from a minor without obtaining the prior consent of a verifiable legal guardian, we will endeavour to delete the relevant data as soon as possible.

13.Contact us

For further information or enquiries regarding your personal data, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact us using any of the following contact details:

Email: jupiterfifthstech@gmail.com

14.Privacy complaints

Please direct all privacy complaints to us. At all times, privacy complaints:

will be treated seriously;
will be dealt with promptly;
will be dealt with in a confidential manner; and
will not affect your existing obligations or affect the commercial arrangements between you and us.

We will acknowledge your complaint within 14 business days of receipt and endeavour to resolve it within 30 business days, unless we inform you otherwise and seek your agreement in writing.

We will commence an investigation into your complaint. You will be informed of the outcome of your complaint following the completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which we will resolve it, you may refer the complaint to the Office of the Privacy Commissioner for Personal Data.