Privacy Policy

Effective date: 26th April 2023 

Welcome to Ambayo!

The Ambayo Limited (“Company”, “Ambayo”, “us”, “we”, or “our”) owns and operates www.ambayo.com and Ambayo mobile application (hereinafter referred to as “Service”).

The Company’s Privacy Policy governs your visit to www.ambayo.com (the “Website”) and Ambayo mobile application (the “App”) (together the “Platform”). The purpose of this agreement is to inform and explain how we collect, manage, use, safeguard and disclose Personal Information that results from your use of our Service, which is subject to the privacy principles set out in the Personal Data (Privacy) Ordinance (the "PDPO") 1996 and general law intended to protect your privacy, as amended from time to time, and where relevant by the European Union General Data P rotection Regulations (EU) 2016/679 (the GDPR), California Privacy Protection Act (the CalOPPA) and California Consumer Privacy Act (the CCPA).

Protecting our customer’s Personal Data and compliance with Applicable Laws is of the utmost importance to Ambayo and matter we take very seriously. We are committed to property managing, protecting, and processing your Personal Data in accordance with this Privacy Policy, which applies to all Personal Data we collect through our Platform and/or other channels.

We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“Agreement”).

DEFINITIONS

In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

“SERVICE”

means the www.ambayo.com website and Ambayo mobile application (together the “Platform”) operated by Ambayo Limited;

“PERSONAL DATA”

means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession);

“USAGE DATA ”

is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit);

“COOKIES”

are small files stored on your device (computer or mobile device);

“DATA CONTROLLER ”

means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data;

“DATA PROCESSORS (OR SERVICE PROVIDERS”

means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively;

“DATA SUBJECT”

is any living individual who is the subject of Personal Data;

“THE USER”

is any living individual who is the subject of Personal Data;

CONSENT

By accessing or using Ambayo, visiting the Site and/or the App, or using any of our other Services, you consent to this Privacy Policy and understand that your use of our Services is subject to this Privacy Policy and our Terms and Conditions, including applicable limitations on damages and the provisions regarding resolution of disputes. If you do not agree with this Privacy Policy, do not access or use any of our Services.

TYPES OF DATA COLLECTED

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:

  • icon Email address
  • icon First name and last name
  • icon ID card
  • icon Business registration number
  • icon Address
  • icon Phone number
  • icon Payment information
  • icon Social media
  • icon Cookies

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.

You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Usage Data

This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit,the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data
  1. We may use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
  2. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
  3. Cookies may also be used for other purposes on our Platform.
  4. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
  5. If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites than you may not be able to gain access to all of the content and facilities in those websites.
  6. Examples of Cookies we use:
    1. Session Cookies: We use Session Cookies to operate our Service.
    2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
    3. Security Cookies:  We use Security Cookies for security purposes.
    4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

USE OF DATA

The Ambayo uses the collected data for various purposes:
  • icon to provide and maintain our Service;
  • icon to notify you about changes to our Service;
  • icon to allow you to participate in interactive features of our Service when you choose to do so;
  • icon to provide customer support;
  • icon to gather analysis or valuable information so that we can improve our Service;
  • icon to monitor the usage of our Service;
  • icon to detect, prevent and address technical issues;
  • icon to fulfill any other purpose for which you provide it;
  • icon to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • icon to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.
  • icon to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  • icon in any other way we may describe when you provide the information;
  • icon for any other purpose with your consent.

RETENTION OF DATA

  • icon We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.
  • icon We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
  • icon We will also retain Usage Data for internal analysis purposes.
  • icon Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

TRANSFER OF DATA

  • icon Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
  • icon If you are located outside the Hong Kong and choose to provide information to us, please note that we transfer the data, including Personal Data, to the Hong Kong and process it there.
  • icon Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
  • icon The Company will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF DATA

We may disclose personal information that we collect, or you provide:
  • Disclosure for Law Enforcement.
    icon Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
  • Business Transaction.
    icon If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
  • Other cases. We may disclose your information also:
  • icon to our subsidiaries and affiliates;
  • icon to contractors, service providers, and other third parties we use to support our business;
  • icon to fulfill the purpose for which you provide it;
  • icon for the purpose of including your company’s logo on our Platform;
  • icon for any other purpose disclosed by us when you provide the information;
  • icon with your consent in any other cases;
  • icon if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
  • Disclosure for Law Enforcement.
    icon Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
  • Disclosure for Law Enforcement.
    icon Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

SECURITY OF DATA

  • icon The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.
  • icon While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

YOUR RIGHTS

You have the following rights in relation to your Data:
  • icon Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information, we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  • icon Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
  • icon Right to erase - the right to request that we delete or remove your Data from our systems.
  • icon Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
  • icon Right to data portability - the right to request that we move, copy or transfer your Data.
  • icon Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
  • icon To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@ambayo.com
  • icon If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.
  • icon It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA PRIVACY PROTECTION ACT (CalOPPA)

  • icon CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
  • icon According to CalOPPA we agree to the following:
  • icon users can visit our site anonymously;
  • icon our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
  • icon users will be notified of any privacy policy changes on our Privacy Policy Page;
  • icon users are able to change their personal information by emailing us at info @ambayo.com
  • icon Our Policy on “Do Not Track” Signals:
  • icon We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place.Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
  • icon You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

  • icon If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
  • icon What personal information we have about you. If you make this request, we will return to you:
  • icon The categories of personal information we have collected about you.
  • icon The categories of sources from which we collect your personal information.
  • icon The business or commercial purpose for collecting or selling your personal information.
  • icon The categories of third parties with whom we share personal information.
  • icon The specific pieces of personal information we have collected about you.
  • icon A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
  • icon A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
  • icon Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
  • icon To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
  • icon To stop selling your personal information. We don't sell or rent your personal information to any third parties for any purpose. You are the only owner of your Personal Data and can request disclosure or deletion at any time.
  • icon Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.
  • icon To exercise your California data protection rights described above, please send your request(s) by one of the following means:
  • icon By email: info@ambayo.com
  • icon Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

SERVICE PROVIDERS

  • icon We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
  • icon These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
  • icon We may use third-party Service Providers such as:
  • ShuftiPro

  • icon ShuftiPro is an AI-powered identity verification solution enable to verify and identify in a matter of seconds with the utmost levels of accuracy and security.
  • icon For more information on the privacy practices of ShuftiPro, please visit the ShuftiPro Privacy Terms web page: https://shuftipro.com/privacy-policy/
  • Utopia Analitics

  • icon Utopia is a fully automated moderation tool that protects online community and brand from abusive user-generated content, fraud, cyberbullies and spam.
  • icon For more information on the privacy practices of Utopia, please visit the Utopia Privacy Terms web page: https://utopiaanalytics.com/utopia-analytics-privacy-policy/

PAYMENTS

  • icon We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).
  • icon We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
  • icon The payment processors we work with are:
  • Stripe:
    icon Their Privacy Policy can be viewed at https://stripe.com/en-gb/privacy

LINKS TO OTHER SITES

  • icon Our Service may contain links to other sites that are not operated by us.
  • icon If you click a third-party link, you will be directed to that third party's site.
  • icon We strongly advise you to review the Privacy Policy of every site you visit.
  • icon We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

BEHAVIORAL REMARKETING

  • icon The Ambayo uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
  • Google Ads (AdWords)
  • icon Google Ads (AdWords) remarketing service is provided by Google Inc.
  • icon You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
  • icon Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
  • icon For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?
  • YouTube
  • icon YouTube is a global online video sharing and social media platform, is provided by Alphabet Inc. headquartered in San Bruno, California, United States.
  • icon For more information on the privacy practices of YouTube, please visit the YouTube Privacy Policy web page: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/
  • Facebook
  • icon Facebook remarketing service is provided by Meta Inc.
  • icon You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
  • icon To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
  • icon Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
  • icon For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
  • Instagram
  • icon Instagram remarketing service is provided by Meta Inc. For more information on the privacy practices of Instagram, please visit the Instagram Privacy Terms web page: https://www.instagram.com/519522125107875?helpref=page_content.
  • Twitter
  • icon Twitter remarketing service is provided by Twitter Inc.
  • icon You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
  • icon You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

CHILDREN’S PRIVACY

  • icon Our Services are not intended for use by children under the age of 16 (“Children”).
  • icon You must be at least 16 years old, and if you are below the age of 16, you must have obtained the consent of your parent or legal guardian to open a Ambayo Account and use the Service.
  • icon The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 16 years of age.
  • icon We do not knowingly collect or solicit personally identifiable information from children under 16 years of age; if you are a child under 16 years of age, please do not attempt to register for or otherwise use the Ambayo Services or send us any personal information.
  • icon If we learn we have collected personal information from a child under 16 years of age, we will delete that information as quickly as possible.
  • icon If you believe that a child under 16 years of age may have provided us personal information, please contact us at  info@ambayo.com

CHANGES TO THIS PRIVACY POLICY

  • icon We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
  • icon We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
  • icon You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

  • icon If you have any questions about this Privacy Policy, please contact us:
  • icon By email: info@ambayo.com

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