Date: [March 12, 2025]
This Privacy Statement is issued by We Sing (Hong Kong) Limited and its affiliated companies (collectively referred to as"TME," "we," "us," and"our") issue this, targeting individuals outside the organizations we interact with. Including customers, visitors to our website, users of our applications, and recipients of any of our other products or services (collectively referred to as"You").
We may update this Privacy Statement to reflect changes in our information practices. Unless otherwise specified, all changes shall take effect from the date of publication. We encourage you to regularly review this page for the latest information on our privacy practices.
1.Information on the collection of personal data
1.1 Personal data
Depending on how you use our Sites, Applications, products or services, we may collect or obtain Personal Data about you from the following sources:
Data you provide to us: We obtain Personal Data when you provide those data to us (e.g., when you register an account with us; where you contact us via email, telephone, or by any other means; or when you provide us with your business card).
Account creation details: We collect or obtain Personal Data when you register or create an account to use any of our Sites or Applications.
Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., when we provide a service to you).
Site or Application data: We collect or obtain Personal Data when you visit or use any of our Sites or Applications, or use any features or resources available on or through our Sites or Applications.
Content and advertising information: If you interact with any third-party content or advertising on our Sites and/ or Applications (including third-party plugins and cookies) we allow the relevant third party providers to collect your Personal Data. In exchange, we receive Personal Data from the relevant third-party provider relating to your interaction with that content or advertising.
Data you make public: We may collect the content you publish, or otherwise manifestly made public about us through our Apps and platforms, your social media, or any other publicly available platforms.
Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., single sign-on providers and other authentication services you use to connect to our services, third-party providers of integrated services, your employer, other customers, business partners, Processors, and law enforcement authorities).
Data automatically collected: We and our third-party partners automatically collect information you provide to us and information about how you access and use our Sites, Applications, products or other services when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
For more information on which data we collect, please also refer to the table in Annex I.
1.2 Data controller
The data controller pursuant to Art. 4 (7) GDPR is We Sing (Hong Kong) Limited, 9/F MW TOWER NO 111 BONHAM STRAND SHEUNG WANHK, crystalshen@tencent.com.
2.Creation of Personal Data
We also Process and retain Personal Data about you in certain circumstances, such as records of your interactions with us, details of your past interactions with us, and inferences or predictions about your characteristics or interests. We may also link Personal Data collected from any of our Sites, Applications, products, or services, including where those data are collected from different devices.
3.Categories of Personal Data We Collect and Process
When you first register an account, we may collect the following categories of Personal Data about you: username and password, email addresses and/ or phone numbers.
When using our Sites, Applications, products, or services, we may also collect and/or process the following categories of Personal Data about you:
To collect some of the Personal Data set forth above, we may need to request permission to access such Personal Data through your mobile device. You are in control of the permissions you grant us, and you may change your permission settings at any time in the setting dashboard of your device. Note that revoking permissions may affect the provision and performance of our Sites, Applications, products, and services.
4.Purposes of Processing
We may use the Personal Data we collect for the following purposes:
5.Legal Basis for Processing
The purposes for which we Process Personal Data, if you are Subject to the GDPR, and the legal bases on which we perform such Processing, are as follows:
You can find more information on the legal basis in the table in Annex I.
6.Disclosure of Personal Data
We may also share, transmit, disclose, grant access to, make available, and provide Personal Data with and to third parties, as described below.
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud or other criminal activity; or
- as otherwise required by applicable law.
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. Please note that third parties and business partners may process your Personal Data in accordance with their own privacy policies and terms of service.
7.Cookie
7.1 General information about cookies
We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. Cookies or tags are bits of code that allow our technology partners to collect information that usually does not directly identify you. If required by law, we will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes. As described below, we will not use cookies or similar tracking technologies that process your personal data, unless you opt-in, i.e. consent, by using the cookie banner or consent manager found on our Site. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Sites and services.You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the website footer.
7.2 Cookies.
Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.
Generally, we use joox.top and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
We use the following types of cookies on our Services:
Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, You will be able to keep items in your shopping cart while browsing the website. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.
Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
7.3 Your Choices
You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to block cookies, and when cookies will expire. If you block all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.
7.4 Web Pixels .
To see how successfully our marketing campaigns or other goals of the Services are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.
7.5 Analytics.
We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .
7.6 Behavioral Remarketing
We also use remarketing services to advertise on third-party websites to you after you visited our Services. For this purpose, visitors are grouped by certain actions on our Services, e.g., by duration of a visit. This enables us to understand your preferences and to show you personalized advertising even if you are currently surfing on another website that also participates in the Google advertising network.
We use the following tools and services for these purposes:
Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: https://www.google.com/settings/ads .
If Google Ads is structured to collect personal data, the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland.
Bing Ads is a service operated by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Please read Microsoft’s privacy statement for more information on how Microsoft processes your information https://privacy.microsoft.com/en-US/ . When you access our Site via advertisements on Bing Ads, a cookie is set on your computer. In addition, a Universal Event Tracking tag is integrated on our Site. This is a code that, in combination with the cookie, stores data about the use of the Site, e.g. length of time spent on the Site, areas accessed, and ads used to reach the Site. In addition, Microsoft may track your usage patterns across multiple of your electronic devices through so-called cross-device tracking. The information collected is transferred to a Microsoft server in the United States. If Bing Ads is structured to collect personal data, the cookie banner on our Services will provide you the opportunity to consent to Bing Ads.
Facebook Ads. Using Facebook Business Tools , we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences in addition to the Your Choices section below. We do not share any of your personal information with Facebook. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the “lookalike” audience, unless they choose to click on one of our advertisements.
7.7 Other Tracking Technologies .
We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
7.8 Do Not Track.
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
7.9 Location Information.
You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings
8.Transfer of data to third parties
8.1 Transfer only where allowed by law
We only forward your data if this is allowed by German or European law. We work particularly closely with certain service providers, for example in the area of customer service (e.g. hotline service providers), with technical service providers (e.g. running computer centres) or with logistics companies (e.g. postal companies such as HONGKONG YUNEXPRESS LOGISTICS LIMITED). These service providers may generally only process your data on our behalf under special conditions. Where we use them to process orders, the service providers only receive access to your data in the scope and for the time period required for provision of the relevant service. If you shop with one of our partners, we forward particular shopping data regarding you to the partner (e.g. your name and your delivery address), so that the partner can send you the goods ordered.
8.2 Technical service providers
We work with technical service providers in order to be able to provide our services. These service providers include, for example, SHOPLINE.If they process your data outside the European Union, this may mean that your data is transmitted to a country with a lower data protection standard than the European Union. In such cases we will ensure that the relevant service providers contractually or otherwise guarantee an equivalent data protection level.
8.3 Payment service providers and credit agencies
We use Airwallex as our payment collection platform. For this purpose, payment data can be transferred to payment service providers with whom we work with.You can find more details about processing of personal data by payment service providers in their privacy policies:
8.4 Authorities and other third parties
If we are obliged by an official or court decision or it is for prosecution purposes, we will if necessary forward your data to prosecution authorities or other third parties.
9.Retention and erasure of data
We will store your personal data as long as is necessary for the purposes named in this Privacy Notice, especially for the fulfilment of our contractual and legal obligations. We may also store your personal data for other purposes if or as long as the law allows us store it for particular purposes, including for defence against legal claims.
If you close your customer account, we will delete all the data we have stored regarding you. If it is not possible or necessary to completely delete your data for legal reasons, the relevant data will be blocked for further processing. If data is blocked, technical and organisational measures are used to ensure that only a few employees can access the relevant data, based on need to know and only for select purposes (e.g. in the event of a tax audit).Blocking will occur, for example, in the following cases:
(A) Your order and payment details and perhaps other details are generally subject to various legal retention obligations, such as those in the Handelsgesetzbuch (HGB - Commercial Code) and the Abgabenordnung (AO - Tax Code). The law obliges us to retain this data for tax audits and financial audits for up to ten years. Only then can we finally delete the relevant data.
(B) Even if your data is not subject to any legal retention obligation, we may refrain in the cases allowed by the law from immediate deletion and instead carry out initial blocking. This applies especially in cases where we may need the relevant data for further contractual processing or prosecution or legal defence (e.g. in the event of complaints). The decisive criterion for the duration of the blocking is then the legal limitation periods. After the relevant limitation periods expire, the relevant data will finally be deleted.
Deletion may be waived in the cases allowed by law if the data is anonymous or pseudonymous and deletion would rule out or seriously hinder processing for scientific research or statistical purposes.
10.How is my personal data protected?
We use technical and organisational measures to secure our systems. With regard to your order and your customer login, we transmit your personal data securely using SSL encryption (Secure Socket Layer).
11.Your rights
11.1 Your rights against us as data controller
You have the following rights against us as a data controller in respect of personal data relating to you:
(A) right to information,
(B) right of rectification or erasure,
(C) right to restriction of processing,
(D) right to object to processing,
(E) right to data portability.
(F) right to withdraw consent (in case consent is the basis for data processing).
11.2 Information requests
In order to ensure that your data is not disclosed to third parties in the course of requests for information, please attach sufficient proof of identity to your request.
11.3 Withdrawal of consent.
If you have given your consent to the processing of your data, you may revoke this consent at any time. Such revocation affects the permissibility of the processing of your personal data after you have expressed it to us. The permissibility of the processing of your data up to the time of your revocation remains unaffected.
11.4 Objection in case of processing on the basis of balancing of interests
(A) Insofar as we base the processing of your personal data on a balancing of interests, you may object to the processing. This is the case if the processing is not necessary, in particular, for the fulfilment of a contract with you, which is shown by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data in the way we have done. In the event of your objection, we will review the situation and either cease or adjust the data processing or show you our compelling legitimate grounds for continuing the processing.
(B) Of course, you can object to the processing of your personal data for advertising and data analysis purposes at any time. The best way to exercise your advertising objection is to contact us using the contact details provided above.
You also have the right to complain to a data protection supervisory authority about our processing of your personal data. The competencies of the supervisory authorities depend on the seat of the data controller. You may, however, contact any data protection authority in any member state of the European Union, in particular at your place of residence, which will forward your complaint to the competent authority.
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