Privacy Policy & GDPR Compliance

A Squared Ltd. - Data Privacy Policy - GDPR compliance

Last updated: 29 May 2018

Who We Are

This Privacy Policy applies to the A Squared Ltd. ("we" or "us") owned and operated websites and its subdomains (“Sites”) as well as to the services that we deliver such as providing (“Services").

Who You Are

- Visitor. You may be a visitor to our Sites and either provide us with information without purchasing our Services / Products or you may may contact us through our Sites seeking information about our Services.

- Customer. You may be a customer of our Services / Products. You may have an End User License Agreement that allows you to use our Services ("Services Agreement"). A Services Agreement may refer to this Privacy Policy.

Your Privacy Matters

We are responsible for determining the purpose and means of processing any Personal Data (see definition in the next paragraph) about you during your visit to our Site or through the use of our Services. We know that you care how data about you is used and shared. Please contact us at info@asquared.hk if you have any questions. This Privacy Policy is designed to help you understand our privacy practices and the choices available to you when you use our Site or Services.

This Privacy Policy describes how we protect your Personal Data, which is defined by the European Union, the U.S. government and many U.S. states in similar yet unique ways. For the purposes of this Site and our Services, we define "Personal Data" to be information that can be used to identify a person directly or indirectly and can include a name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, log in account number and associated password, date of birth, government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID), an IP address, location data or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

The European Union Global Data Protection Regulation ("GDPR") provides data subjects like you with certain rights that are enumerated in the Your Rights section below. We will provide these same rights to all of our customers regardless of where you live.

When this Privacy Policy Applies

This Privacy Policy explains what Personal Data we collect when you access the Sites or use our Services, how the Personal Data will be used, and how you can control the collection, correction or deletion of that data. The use of the Sites is possible without providing Personal Data; however, if you want to use Services via our Sites (e.g. make an enquiry about our products and services to which you would like us to reply), processing of Personal Data is necessary.

We will not use or share your data with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to data we collect by other means (including offline) or from other sources. The use of data collected through our Sites is limited to the purposes set out in this Privacy Policy and our Services Agreement. The processing of Personal Data will be in accordance with GDPR Principles.

We will process and store your Personal Data only for the period necessary to achieve the purpose of collection or as long as required by applicable law. Our legal basis for processing your Personal Data is either your consent indicated on this Site, that the processing is necessary for the performance of a contract to which you are party such as the Services Agreement, or in order to take steps at your request prior to entering into a contract.

Information You Share with Us

We may collect Personal Data when you visit our Site such as information related to your online device, including your IP address, referring website, what pages your device visited, and the time your device visited our Site. For more information on this, see the section below titled Cookies and Other Tracking Technology.

We will collect Personal Data when you register for an account to activate Services, when you provide your Personal Data to interact with other Site users, or send us customer service related requests. When you sign up for our Services, we will receive and store information you provide directly to us. For example, when setting up a new customer we collect Personal Data such as a name, email address, and password. If you choose to purchase Services from us, we or our third-party payment processors will collect your payment information.

We may send promotional or customer service related emails. If you no longer wish to receive these emails, you may opt out of them by clicking the unsubscribe link in the email communications we send.

How We Use Your Personal Data

We use your Personal Data when you visit our Site for the following purposes:

To administer the Site and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes.
To improve our Site to ensure that content is presented in the most effective manner for you and your device.
To analyze your use of the Site for trend monitoring, marketing and advertising purposes.
For purposes made clear to you at the time you submit the information such as to fulfill your request for a demo or to provide you with information you requested about our Services.
As part of our efforts to keep our Site safe and secure.

In addition to the purposes set forth above as applied to delivery of the Services, we use your Personal Data when you purchase or subscribe to our Services for the following purposes:

To set up a user account.
To provide, operate and maintain the Services.
To process and complete transactions, and send related information, including transaction confirmations and invoices.
To manage your use of the Services, respond to your inquiries, and to provide you with customer service and support.
To send you technical alerts, updates, security notifications, and administrative communications.
To investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities.
To store your projects in the cloud so you can access them from multiple devices.
To provide you with automatically emailed tutorials based on your usage of the Services.
For any other purpose about which we notify you.

We may also use your Personal Data to contact you via email, and possibly other means, regarding new services or events we think may be of interest to you if this is in accordance with your marketing preferences.

Cookies and Tracking Technology

Cookies. Cookies are small pieces of data sent by a website to a visitor's hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. We use cookies to remember your settings as well as for authentication purposes. We use cookies in analyzing trends, administering the Sites, tracking your movements around the Sites and to gather demographic data about our user base as a whole. We may also place cookies from third parties for functional and marketing purposes. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis. If you reject cookies, you may still use our Site, but your ability to use some features or areas may be limited.

The only way to completely “opt out” of the collection of any data through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical data for instructions on how to delete and disable cookies, and other tracking/recording tools (to learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.cookiecentral.com/faq/.)

You can also visit the U.S. government website to learn about disabling cookies at https://www.usa.gov/optout-instructions.

If you access the Services or Sites on your mobile device, you may not be able to control tracking technologies through the settings. For more information on third-party advertising- related cookies and interest-based advertising, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit www.aboutads.info/consumers.

Analytics Tools. The Sites use an analytics tools to track user activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases). In particular, we use Google Analytics, a web analysis service provided by Google, to better understand your use of our Site and Services. Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Pixel tags and similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with Services to, among other things, track your actions (including email opens and clicks), measure the success of our marketing campaigns and compile statistics about use of the Services and response rates.

Log File Information. Log file data is automatically reported by your browser or mobile application each time you access our Sites or the Services. For example, when you access our Sites, our servers automatically record certain data that your web browser sends whenever you visit any website. These server logs may include data such as your operating system, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and other such information. We do not intentionally connect this automatically-collected data to Personal Data but some Personal Data attributes may be present in the URL when it is logged into our system. We do not use this data from visitors for any purpose.

When We Share Your Personal Data with Third Parties

We will not rent or sell your Personal Data to others. We may share or disclose your Personal Data to third parties, often referred to as processors, as described below. Your Comments. Any Personal Data you elect to make publicly available on our Sites, such as posting comments on our blog page, will be available to others. If you remove Personal Data that you have made public on our Sites, copies may remain viewable in cached and archived pages of our Sites, or if other users have copied or saved that Personal Data. Your Testimonials: We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at info@asquared.hk.

Vendors, Consultants and other types of Processors: We may share your Personal Data with Processors such as vendors or consultants who are engaged to perform tasks on our behalf. These Processors include, for example, our payment processing providers, website analytic companies, help desk software providers, email service providers and others. These companies do not retain, share, store or use Personal Data for any other purposes unless we disclose that activity in this Privacy Policy.

Your Anonymous Data. We may share information that is not Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties. This data may be stored indefinitely.

Legal Disclosures. We will disclose your data where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (iii) to exercise or protect the rights, property, or personal safety of us, our users or others.

Business Transactions: We may sell our company or the Services. Your data such as customer names and email addresses, and other data related to the Services may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such data in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of our company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Behavioral Targeting / Re-Targeting / Re-Marketing. We may partner with third parties to display advertising on our Sites and manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather data about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests. Facebook. We use the Conversion Tracking Pixel service of Facebook, which allows us to display advertisements of our Services to you when you are on Facebook through a tool offered by Facebook called the Custom Audience Tool. This Facebook tool allows us to personalize our advertisements on Facebook and other sites based on your shopping experience with us. We share your shopping history with our Services with Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes in accordance with their Facebook Data Use Policy found at www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside of Facebook. In addition, a cookie will be saved onto your computer for these purposes. Please click here if you would like to revoke your permission: www.facebook.com/ads/website_customer_audiences/. Google Adwords. We use Google AdWords Remarketing to advertise our Services across the Internet. AdWords remarketing will display relevant advertisements tailored to you based on what parts of our Sites you have viewed by placing a cookie on your machine. This allows us to make special offers and continue to market our Services to those who have shown interest in our Sites. You can opt out of Google's use of cookies by visiting https://adssettings.google.com/authenticated. You can also opt out of any third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page at http://optout.networkadvertising.org.

Where We Store and Process Your Personal Data

Location. Your Personal Data may be stored and processed in the United States, Europe, or any other country in which we, our subsidiaries, affiliates or Processors maintain facilities. We may transfer your Personal Data to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Our own proprietary software applications that are used to deliver the Services store your Personal Data in the U.S. using industry standard Microsoft and Amazon web hosting services. Some of the third parties described in this Privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. We will protect your Personal Data in accordance with this Policy regardless of where it is processed.

How We Protect Your Personal Data

Security. We are concerned with protecting Personal Data and use appropriate technical, organizational and administrative measures to protect the Personal Data we hold in our records from unauthorized access, loss, misuse, disclosure, alteration or destruction. However, no method of transmission over the internet, method of electronic storage, or process that is subject to human error is 100% secure. When you enter your log in credentials or other information into our Service on our registration or order forms, we encrypt that data using secure socket layer technology (SSL). You can also prevent unauthorized access to the Personal Data in your account with us by protecting your password appropriately and limiting access to your device and browser by signing off after you have finished using our Service. Security Incident In the event that your Personal Data is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

Your Rights

General Rights. You can always decide not to disclose your Personal Data to us, but that may limit your ability to use our Services or take advantage of some of the features of the Site. You can opt-out of receiving certain marketing communications from us at any time by using the unsubscribe link in the email communications we send. If you retain any account for Services, we will still send you non-promotional communications related to your Services. You can exercise these and any of the following rights to your Personal Data by contacting us at info@asquared.hk and we will respond in a reasonable time in accordance with applicable law.

Access. You have a right to access the Personal Data held by us. We may charge for a request for access in accordance with applicable law.

Amendment. You have the right to request that we update any inaccurate Personal Data. To update your Personal Data, you may contact us at the email address set forth above or by amending your Personal Data stored on our website for delivery of the Services. Withdrawal of Consent. Where we process Personal Data based on consent, you have a right to withdraw consent at any time.

Erasure (Right to be Forgotten). Subject to applicable legal limitations, you have the right to request the erasure of your Personal Data. We will endeavor to erase your Personal Data from as many locations in our Services as possible. When this happens, you will lose all access to the Services.

Restriction of Processing. You have the right to request restriction of the processing of your Personal Data on the grounds that the (i) accuracy of the data is contested; (ii) processing is unlawful but you oppose erasure; (iii) the data is no longer needed for the purposes of processing but you require the data for exercise or defense of a legal claim; and (iv) you have objected to processing as per GDPR Article 21 and such objection is pending. Object. You have the right to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process Personal Data for this purpose. You also have the right to object to processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. Data Portability. We will provide you with a copy of your Personal Data in a structured, commonly used and machine readable format.

Complaints. We hope that you won't ever need to, but you can complain about our use of your Personal Data. We will investigate and respond to you. You also have the right to lodge a complaint with the supervisory authority responsible for data protection in the EU member state or the state attorney general in the country or US state of residence, your place of work or the place of the alleged infringement.

Please remember that we may still use any aggregated and de-identified Personal Data that does not identify you and may also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Children and Our Services

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit Personal Data from anyone under the age of 16. In the event that we learn that we have collected Personal Data from a child under age 16, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under 16, please contact us at info@asquared.hk.

Notification Procedures

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email, written or hard copy notice, or through conspicuous posting of such notice on the Service, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

Links to Other Web Sites

We are not responsible for the practices employed by websites or services linked to or from the our Service or Sites, including the data or content contained therein. Please remember that when you use a link to go from our Services or Sites to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

Social Media Widgets

Our Site includes social media features, such as Facebook, Instagram, YouTube and Google+ and other widgets, that run on our Site. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the organization providing it.

Do Not Track Disclosure

"Do Not Track" ("DNT") refers to an HTTP header used by Internet web browsers to request a web application disable its tracking or cross-site user tracking. When DNT is enabled, a user's web browser adds a header to content requests indicating that the user does not want to be tracked. Some U.S. state laws require us to disclose how we respond to web browser DNT signals. We do not respond to or take any action with respect to a DNT configuration set in your internet browser, and therefore, do not disable tracking. For data about Do Not Track, visit www.allaboutdnt.org.

In addition, we deploy cookies, tracking pixels, web beacons, and other technologies on our websites and those of our customers. Those tools may be used by us, our customers, and third parties to collect data about you and your internet activity, even if you have turned on the Do Not Track signal.

Changes to Our Privacy Policy

All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the ‘effective date’ at the top of this page.

If you have any questions about this Privacy Policy, please contact us at:

Email: info@asquared.hk

Phone: +852 8191 7646