User Privacy Notice
This User Privacy Notice (the “Privacy Notice”) supplements our Terms of Service and explains how we handle information collected and received in the course of your use of our website(s) and services (collectively, the “Services”) provided by our online platform “TLive” which is developed and operated by TechTure Limited (“TLive”). It also governs the collection, use and disclosure of your information and tells you how you can access and update your personal data and make certain choices about how your personal data are used.
This Privacy Notice covers both our online and offline data collection activities, including personal data that we collect through our various channels such as website(s), third-party social networks, points of sales and events. Please note that we might aggregate personal data from different sources (website(s) and offline event(s)). As part of this, we combine personal data that were originally collected by us or our business partners. Please see Section  “Accessing and Updating Your Information” for further information on how to object to this.
2. Information Collected and Received by Us
We may collect and receive information from you in the following situations:
(a) when you register for an account with us (“Account”);
(b) when you choose to connect your Account with an external third-party service or application, such as Facebook, Google and/or other third-party service providers;
(c) when you use the features and functions available on our Services, for example, by transacting with merchants on TLive, live streaming or interacting with other users;
(d) when you interact with our advertisements (e.g. if you interact with one of our advertisements on a third party website, we may receive information about that interaction); or
(e) if you contact us, for example, with an enquiry or to report a problem.
You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you.
By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent and warrant to us that you have obtained the consent of the third party to provide us with their information for the respective purposes.
3. Your Interactions with Others Users
[Our Services may from time to time offer features which allow users to connect and communicate in groups which are public or semi-public, and to share information with each other.] Please use common sense and exercise good judgement when sharing information in these groups or with others. We generally do not monitor or remove the information which you share and such information may remain available on our Services after your Account has been deactivated, terminated or is otherwise closed. You are responsible for the information you choose to share in these groups or with other users.
4. How We Use the Collected Information
We may use the information collected and received from you for the following purposes:
(a) to verify your identity, update our records and generally maintain your Account with us;
(b) to provide our Services and customise the content shown to you;
(c) to develop, operate, improve, deliver and maintain our Services;
(d) to answer your enquiries and resolving complaints;
(e) to carry out polls, surveys, analysis and research on how our Services are being used and how we can improve them;
(f) to update you on our Services (e.g. new offers, new feedback, new comments). [These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates at any time through the "Remarketing" under your personal profile page];
(g) to send you marketing and/or promotional materials on the latest products and services of TLive or carefully selected third parties. [These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates through the "Remarketing" under your personal profile page. These updates may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods];
(h) to send you service-related messages including, without limitation, a welcome/confirmation email when you register your Account and to enforce our Terms of Service and other policies. These messages are not promotional in nature. [These messages will be sent by email and/or through push notifications and you may not opt-out of receiving service-related messages from TLive, unless you deactivate your account];
(i) to perform direct marketing of the Services and other products and services (you may refer to Section  “Direct Marketing” for more information); and
(j) to perform functions or services as otherwise notified to you at the time of collection.
5. Who We Share Your Information with
We may share information about you in the following ways:
(a) when you register for an Account, the certain information which you make available on your profile may be viewed by other users of our Services, such as your user name and user description. Other users of our Services would also be able to view the content which you upload and share on our Services;
(b) we may share the information with our affiliates and with our business partners and third-party service providers who assist us in performing certain aspects of our Services on our behalf, such as processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks. Such business partners and service providers will only have access to your personal information to the extent necessary to perform their functions;
(c) we may share the information with our potential business partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business; or
(d) we may disclose your personal information if required to do so by law, upon the request of any law enforcement agency or government department, or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property or personal safety of any person.
We respect your privacy and we will not sell your personal information to any third party. We may disclose data and aggregate statistics about users of our Services and sales to prospective business partners, advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted advertisements or for other lawful purposes, but these data and statistics will not include information which can be used to identify you.
6. Transfer of Information
By using our Services, you authorise us to use your information in Hong Kong and other countries/regions where TLive operates for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Notice and protected in accordance with applicable laws on personal data protection.
7. Protecting Your Information
The security of your information is important to us. We have security measures in place to protect against the loss, misuse, unauthorized access and alteration of information under our control. We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. [For example, we use firewalls and data encryption as well as physical access restrictions for our data centers and authorization controls for data access. Sensitive information (such as credit card numbersemail addresses) are encrypted using secure socket layer technology (SSL).] However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
It is important that you protect against unauthorised access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).
8. Storage Duration and Erasure
Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this Notice (you may refer to Section  “How We Use the Collected Information” for more information on the processing purposes). Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take all practicable steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes). As far as legally permissible or required, we restrict the processing of your data instead of deleting it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the execution of the contract or for the assertion of or defense against legal claims, or where such retention is otherwise required or permitted by law. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be deleted after the relevant limitation or retention periods have expired.
9. Direct Marketing
From time to time, TLive may use your personal data to send you news, offers, promotions and joint marketing offers and TLive requires your consent for that purpose. We may contact you by email, in-app notifications, social media, SMS, text/picture/video message, telephone or mail.
Your name, email address, telephone number, contact address, social media contact, date of birth, services portfolio information, transaction patterns and behaviors, browsing and purchasing records, content viewing habits and personal interests held by TLive may be used by TLive in direct marketing of the Services and the products and services appearing on the website(s) of TLive [and solicitation of donations or contributions for charitable, cultural, philanthropic or recreational purposes], which may be of interest to you.
[If you prefer not to receive any direct marketing communications from us, you can opt out at any time by updating your preferences through the "Remarketing" under your personal profile or an unsubscribe link provided or by sending an email to us to the contact details in Section  “Contact Us” below. Upon receipt of your request, we shall cease to so use your personal data as soon as possible without charge to you.]
10. Accessing and Updating Your Information
You may access, review and update your information within our Services through your personal profile.
Where you provide personal information about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.
In certain circumstances, you may need to provide to us personal information about someone other than yourself. If so, we rely on you to inform these individuals that you are providing their personal information to TLive, to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Notice.
If you wish to:
(a) apply for a copy of the information we hold about you; or
(b) withdraw consent you previously provided to us to use, collect or disclose the information we hold about you;
[please contact our Personal Data Protection Officer at the contact details set out in Section  “Contact Us” below.]
Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so.
Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.
(a) recognise you whenever you visit this website;
(b) obtain information about your preferences, viewing and browsing behavior, online movements and use of the Internet;
(c) keep track of the items stored in your shopping basket and take you through the checkout process;
(d) carry out research and statistical analysis to help improve our Services and to help us better understand our visitor and customer requirements and interests;
(e) target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests;
(f) make your online experience more efficient and enjoyable; and
(g) enable tighter security.
12. Changes to this Privacy Notice
We reserve the right to make changes to this Privacy Notice at any time and all changes will be posted here. [If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by email.] You are responsible for reviewing the changes which we make this Privacy Notice. Your continued use of our Services constitutes your acceptance of the updated Privacy Notice.
13. Third Party Sites and Resources
Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You are advised to review the privacy policies of these sites and resources operated by such third parties and understand how your information may be used by them.
14. Contact Us
If you have any questions, complaints, concerns or comments on our Privacy Notice, we welcome you to contact us by [sending an email to our Personal Data Protection Officer at email@example.com].
This document is originally written in English and may be translated into other language and in event of any conflict arising, the English version shall prevail.
Last updated on 8 AUG 2023