Privacy Policy

This Privacy Policy (“Policy”) explains how information about you is collected, used and disclosed by Adequate Systems HK Limited and its subsidiaries and affiliated companies (“Adequate Systems HK Limited”, “we”, “us”, “our”). It also describes the choices available to you regarding the use of, your access to, and how to update and correct your Personal Information. “Personal Information” is any information relating to an identified or identifiable natural person.

For purposes of this Policy, “process” or “processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

This Privacy Policy applies to Personal Information we collect when you use or access adequatelimited.com, Adequate Systems HK Limited and its third party applications, and other services or programs offered by Adequate Systems HK Limited that link to or reference this policy (together, with any and all future online and offline offerings operated by or on behalf of Adequate Systems HK Limited, the “Services”).

Types of Information We Collect

As you interact with the Services, we may collect Personal Information from you. The types of Personal Information we may collect (directly from you or from third-party sources) depend on the nature of the relationship you have with Adequate Systems HK Limited and the requirements of applicable law, as described below.

Information You Provide to Us

We collect information you provide directly to us. When you use the Services or engage in certain activities, such as registering for an account, requesting Services or information, verifying your identity through our Services, posting messages to our forums, or contacting us directly, we may collect information from you such as your name, user name and password, email address, telephone number(s), mailing address, government issued identification documents (e.g., passports, driver's license, etc.), selfie image, biometric information, IP Address, utility bills, and statements to prove your current residence (e.g., bank statements), and any other information you choose to provide.

Facial Biometric Identity Verification

Facial biometric identity verification is performed by comparing two or more captured images of faces. For example, we may compare the face on a government-issued photo ID against a “selfie” that you capture and send to us. The biometric identifiers used to perform this comparison are derived from the photographs that you submit.

Information Collected by Cookies and Similar Technologies

We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

• Cookies: Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Analytics: We may also use analytics tools to collect information regarding visitor behavior and demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit Google’s policy. You can opt out of Google's collection and Processing of data generated by your use of the Services by going to Google’s opt-out page.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary: Technologies that are necessary to the operation of our sites, services, applications, and tools.
• Performance Related: Technologies to assess the performance of our websites, applications, services, and tools.
• Functionality Related: Technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Information We Collect From Other Sources

We may also collect information about you from additional online and offline sources including commercially available third-party sources for the purposes of verifying your eligibility to participate in various programs we may offer. We may combine this information with the personal and other information we have collected about you under this Privacy Policy.

Use of Information

We acquire, hold, use, and process Personal Information for a variety of business purposes, including:

• To provide products, services, or information requested
• Administrative purposes
• Other uses as disclosed at the time you provide Personal Information or with your consent

Third-Party Sites and Social Media Platforms

Our Services may contain links to other websites and other websites may reference or link to our Services not controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Sharing of Information

We may share information about you as described in this Privacy Policy, including with vendors and service providers, to verify your identity, comply with legal requirements, or in connection with a merger or sale. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Retention

Adequate Systems HK Limited retains the Personal Information we receive for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

Communications Preferences

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding Services you have requested. We may also send you certain communications regarding Adequate Systems HK Limited and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy).

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether Adequate Systems HK Limited is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend, or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to support@adequatelimited.com or use any of the methods set out in this Policy to request access to, receive (port), restrict processing, seek rectification, or request erasure of Personal Information held about you by Adequate Systems HK Limited. Such requests will be processed in line with local laws.

Cookies and Interest-Based Advertising

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Privacy Policy Changes

We may revise this Privacy Policy in our sole discretion, so we encourage you to review it when you interact with us. If you continue to visit or use Adequate Systems HK Limited Services made available to you after such changes have been made, you hereby provide your consent to the changes.

Children's Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of our Services are directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal Information without your consent, you may alert us at support@adequatelimited.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child's account.

International Users

By using the Services, Adequate Systems HK Limited may transfer data to Hong Kong or other jurisdictions. By choosing to visit or utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the Hong Kong SAR and the adjudication of any disputes arising in connection with Adequate Systems HK Limited or the Services will be in accordance with the Terms of Use.

Contact Us

If you have questions or concerns about this Privacy Policy, please contact us via the contact page or at support@adequatelimited.com.