By using our website, providing personal information and/or using any of our Products and Services, you acknowledge that:
- we are not responsible for your own disclosure of your information to third parties through our Products and Services (for example, if you send your own contact information to another user through any platform operated by us);
- you, and you alone, are responsible for the content of any profile or registration you create and its accuracy.
- if you have provided information to us relating to any other person, you:
- have a right to provide that information;
- each such person has agreed to those terms.
What information does CyberMiles collect?
The type of information we may collect from you includes:
- personal information (“Personal Information”), including without limitation:
- personally, identifiable information, such as your name and date of birth;
- contact information, such as your email address, telephone number and postal address;
- social media handles and other social media profile information that you make available to us or to the public;
- third-party account credentials (such as your Facebook login credentials, Google login credentials)
- a user’s IP address when the user accesses or uses our Products and Services;
- demographic information such as information regarding your gender, nationality and occupation (“Demographic Information”);
- other information (“Other Information”) including without limitation:
- your public Ethereum key and/or similar information;
- financial information, such as credit card, bank account or other payment details;
- usernames and passwords that you create when registering for an account with us;
- details of any Products and Services that we provide to you;
- records of our communications with you, including any messages you send us;
paragraphs (a), (b) and (c), together “Information”.
We may collection Information through various forms and in various places within our Products and Services. To the extent we combine Demographic Information and/or Other Information with your Personal Information we collect from you, we will treat the combined data as Personal Information under this Policy.
How does CyberMiles collect your Information?
We collect information about you in the following ways:
Information you provide to us directly, including without limitation to:
- when you register for an account on our website, when you update your account details, when you open an email from us, or request or use our Products and Services;
- when you submit a query or request to us;
- device information – when you access our Products and Services via your mobile device or computer, we collect data about you including unique identification numbers associated with mobile devices or through its API (including, for example, a Unique ID for Advertisers (“IDFA”), Unique ID for Vendors (“IDFV”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, battery life, and, depending on the user’s mobile device settings, the geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the mobile device (“User Data”) that enables us to provide you with information, advertisements, or offers specific to your location and interests.
- Information collected automatically – whenever you interact with our Products and Services, we automatically receive and record Information on our server logs from your browser or device, which may include your IP address, device identification, “cookie” information, browser and/or device type, and the page or feature you requested;
- from third parties who are entitled to disclose that information – you may have the option of registering an account and logging into or otherwise linking to that account using a third-party account such as Facebook, Google or other account provided by a third-party site or application. If you choose to provide or log into your account using your credentials for a third-party platform, we may have access to certain information from that site, such as your name, contacts or friend’s lists, account information, public profile, and email address.
Consequently, if you provide your third-party account credentials, you acknowledge that the above-identified information, as well as other information for that account (collectively, “Third Party Account Information”) may be transmitted into your account with us if you authorise such transmissions. You further acknowledge that Third Party Account Information transmitted to us is governed by this Policy. When using some features of our Products and Services, certain information may be required from you to register an account with us. Also, we may, from time to time, combine information from other sources with Information we collect from you in order to enhance our ability to serve you, prevent fraudulent transactions, tailor our content to you, offer you opportunities to purchase products or services that we believe may be of interest to you, and for any other purposes described in this Policy;
In some cases, we may be required by law to collect certain types of personal information about you.
Where we collect personal information from you, we will generally do so ourselves. However, in some cases we may collect personal information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our Products and Services.
What does CyberMiles use your Information for?
We use the Information we collect about you for the following purposes:
- to verify your identity when you are dealing with us;
- to determine your eligibility for any of our Products and Services;
- to answer your queries and requests;
- to email you about your use of the Products and Services;
- to enable us to provide our Products and Services and personalise your experience by better responding to your individual needs;
- to improve our website(s) based on your information and feedback;
- to process transactions;
- to send periodic emails for keeping you informed of our activities, such as (the email address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving, occasional company news, updates, related product or service information, etc.);
- to comply with our legal and regulatory obligations and manage related risks;
- to manage and resolve any legal or commercial complaints or issues;
- to carry out market analysis and research; and/or
- to carry out planning and forecasting activities and other internal business processes.
You are free to opt out of receiving email communications from us by navigating to the settings page within our Products and Services. However, you may be unable to opt out of some administrative communications that are reasonably necessary for us to provide our Products and Services to you, such as order confirmations or service notifications.
There may be instances where we will use your Information to send you marketing materials, for example, we may send promotional email offers to you about our Products and Services that we think you may be interested (including in some cases products and services that are provided by a third party). We may not use your Personal Information unless we have received your consent. You can opt-out of receiving marketing communications from us by contacting us at email@example.com.
We may use your following Personal Information for the purpose of direct marketing:
- identifying information, such as your name;
- contact information, such as your e-mail address, mailing address or phone number; and/or
- products and services portfolio information and demographic data held by us from time to time.
We may use your Personal Information to market the following products and/or services to you, in each case subject to our legal and regulatory obligations:
- purchasing and/or trading digital assets;
- providing, managing or accessing mobile wallets for holding digital assets; and
- other products or services related to digital assets.
If we use your Personal Information in any direct marketing communications, you have the right to request that we provide you with the source of that Personal Information. There is no fee for requesting this information. We will provide you with the source of the Personal Information, unless it is impracticable or unreasonable to do so.
Please indicate your consent to receiving information relating to the above by contacting us at firstname.lastname@example.org or by registering your interest and providing your contact details through our website.
We may also use and disclose your Information for other purposes in accordance with your requests or instructions.
Through cookies we place on your mobile device or browser, we may collect information about your online activity after you leave or log out from our Products and Services. Just like any other usage information we collect, this information allows us to improve our Products and Services and to customise your online experience, and otherwise as described in this Policy. Cookies are unique identifiers that we transfer to your device to enable our systems to recognise your device and to improve your overall user experience. For instance, cookies allow us to preserve our users’ preferences and record session information, such as what pages a visit or items the user looks at, recognise the user’s browser or device type, and determine which pages and/or features are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from using some features or functionality of our Products and Services.
Your browser may offer you a “Do Not Track” option which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Currently our Products and Services do not monitor, support or take any action with respect to “Do Not Track” requests, signals or mechanisms, which means that we may collect information about your online activity both while you are using and after you have finished using our website(s), Products and Services.
Is your Information secure?
Protecting your privacy is important to us, which is why we endeavour to protect the security of your privacy and personal information using commercially reasonable security measures to protect the confidentiality and security of the Information that we hold, and we update these from time to time to address new and emerging security threats that we become aware of.
We also take steps to monitor access to and modification of your Information by our staff members, and ensure that they are aware of and are properly trained in their obligations for managing your data privacy.
No website or Internet transmission is completely secure. Therefore, we cannot guarantee that your Information will never be hacked or that your Information is free from unauthorised access, data loss, or other breaches. In other words, your use of CyberMiles’ Products and Services is at your own risk. We encourage you to exercise caution when using our Products and Services by keeping your password safe and not sharing it with other individuals.
How do we store your Information and how long do we keep it?
We generally store the Information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of your Information in physical storage facilities.
Your Personal Information will not be kept longer than required. We may retain your Personal Information for a period of 12 months. We may be required (by law or otherwise) to retain your account information or any other information associated with it and not delete it (or to keep this information for a certain period of time, in which case we are only be able to comply with your deletion request only after we have fulfilled such requirements). Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Information after you update or delete it, but not in a manner that would identify you personally.
We do not sell or trade your Personal Information to any third parties. We may share your Information with third parties as described in this section:
- your representatives, advisers and others you have authorised to interact with us on your behalf;
- our staff members who need the information to discharge their duties;
- our affiliated entities within the same corporate group – in certain situations, businesses or third-party websites we are affiliated with may sell or provide products or services to you through or in connection with the Products and Services (either alone or jointly with us). You can recognise when an affiliated entity is associated with such a transaction or service, and we will share your Information with that affiliated entity only to the extent that it is related to such Products and Services or their related transaction.
Please remember that the manner in which third party services use, store and disclose your information is governed solely by the policies of such third-party service providers. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to a website of an affiliated entity or business, please review all such business’ or websites’ policies.
- our agents and service providers that assist us in operating our website, providing Products and Services to you, or otherwise conducting our business, for example, we may:
- employ other companies and people to perform certain tasks or services on our behalf, such as hosting services, and may share your Information with them to provide Products and Services to you; for example, we may use a payment processing company or financial institution to receive and process your credit card transactions or payments for us;
- employ companies to call or email you to in order to provide better services to you, such as to welcome you when you sign up with us, to notify you of your transaction information, to remind you of your account inactivity, to provide codes for you to refer your friends to our Products and Services, or to notify you of an offer that you may be interested in. By providing the relevant communication means to us, you agree that we may, to the extent permitted by applicable laws and regulations, contact you for the above-mentioned purposes.
Unless we tell you differently, our agents do not have any right to use the Information we share with them beyond what is necessary to assist us;
- prospective purchasers or successors of all or part of our business or shares in our company or a related entity – We may choose to buy or sell assets, and may share and/or transfer user information, including the Information, in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Information could be one of the assets transferred to or acquired by a third party. We may also share your and of your Information, including usage information with our patent, subsidiaries and affiliates;
- government authorities who ask us to disclose that information in order to:
- comply with laws and regulations, court orders, or government requests;
- assist in any investigations or legal proceedings (including to respond to claims of alleged violations of any third-party rights); and/or
- protect the rights, property, or safety of 5miles, our employees, our users, or others; and
- professional advisers who we engage to provide advice on our business.
We may share your User Data with our third-party partners.
In some situations, transferees to whom we disclose your Information may be located overseas. Further, we may have servers located overseas. The jurisdictions in which these people and/or servers are likely to be located include the United States, Japan, and China. There may not be in place data protection laws which are substantially similar to, or serve the same purposes as the applicable data privacy laws in Hong Kong. This means your personal information may not be protected to the same or similar level in Hong Kong.
De-identifying your Information
We may de-identify your Information (so that you are not identified) and provide that Information to our business partners and/or affiliated entities. We may also provide aggregate usage information to our business partners and/or affiliated entities (or allow them to collect that Information from you), who may use such Information to understand how often and in what ways people use our Products and Services, so that they, too, can provide you with an optimal online experience.
You can opt out of the Google Analytics by visiting http://tools.google.com/dlpage/gaoptout.
Accessing and modifying your Information
If any Information you provided to us has changed, you should inform us. You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information. You may be able to access most of your Information via the Products and Services, for example, the Information you provided during the account registration process (i.e. your name, email address, password, etc.) can be accessed by logging into your account and navigating to account settings. Through your account settings, you may access, and, in some cases, edit or delete the following information you have provided to us:
- your nickname;
- avatar photo;
- phone number;
- email address; and
- digital wallet information
You may be able to add, update, or delete Information. However, we may maintain a copy of the unrevised information in our records. This means your Information is not permanently removed from the system.
In any event, you may request deletion of your account by contacting us by email at email@example.com.
To protect the integrity and security of the Information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases, we may charge you an administration fee for providing you with access to the Information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know why we cannot comply with your request.
Even if you do not request access to and/or correct your personal information held by us, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.
Your choices about our collection of your Information
You can always opt not to disclose Information to us. However, without the Information, we may not be able to provide you with our Products and Services (or with some of the features and functionality offered by our Products and Services) or to respond to queries or request that you submit to us.
Third party links and tracking
Please be aware that third parties may continue to track your online activities even after you have left our Products and Services, and those third parties may not honour “Do Not Track” requests you have set using your browser or device.
Children and CyberMiles
Our Products and Services are intended to be used by adults, as defined under any applicable law in each specific case. If you are under 18 years old, you are not authorised to use our Products and Services. We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Products and Services or send any Information about yourself to us. If we discover that we have collected Information from a child under age 18, we will delete that Information as quickly as possible. If you believe that a child under 18 may have provided us Information, please contact us at firstname.lastname@example.org.
Will we change this Policy?
We are constantly trying to improve our Products and Services. We may also change this Policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations.
If you have opted not to receive notice emails from us (or you have not provided us with your email address), those notices will still govern your use of the Products and Services, and you are still responsible for reading and understanding them. If you use the Products and Services after any changes to this Policy have been posted, that means you agree to all of the changes.
Additionally, we may use Google Analytics to grow our business, to improve our Products and Services, for our technical administration, to increase the functionality and user-friendliness of our Products and Services, and to verify that users have the authorisation needed for us to process their requests. To learn more about the privacy of Google Analytics, visit: http://www.google.com/intl/en/analytics/privacyoverview.html
You can opt out of the Google Analytics by visiting: http://tools.google.com/dlpage/gaoptout
What should I do if I have a concern?
We try to meet the highest standards in order to protect your data privacy. However, if you are concerned about the way in which we are managing your Information and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our privacy compliance team using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Hong Kong Privacy Commissioner for Personal Data.
What if I have questions about this Policy?