This policy sets out:

(1) the information we collect about you when you visit our website, use our products or services, or otherwise interact

with us;

(2) how we use, share, store, and secure the information; and

(3) how you may access and control the information.

In this policy, "Ipseity Network" or "we" refers to Ipseity Network of Sunrise Industrial Bldg, 10 Hong Man St, 13/B, Chai

Wan, Hong Kong and "Platform" means our website at and our software, namely Ipseity


In this policy, "personal information" refers to any data, information, or combination of data and information that is

provided by you to us, or through your use of our products or services, that relates to an identifiable individual.

1 What information we collect about you

1.1 We collect the following types of information about you:

(a) account and profile information that you provide when you register for an account or sign up for our products or

services, for example User id will be created and collected through the administrative portal. Personal

information will be collected in the mobile application but the information will be owned by the end user. Ipseity

Network will not have access to such data. (collectively, "Account Data");

(b) information you provide through support channels, for example when you report a problem to us or interact with

our support team, including any contact information, documentation, or screenshots (collectively, "Support


(c) content you provide through use of our products or services, for example Personal data in encrypted form can

be shared on our platform. (collectively, "User Content");

(d) communication, marketing, and other preferences that you set when you set up your account or profile, or when

you participate in a survey or a questionnaire that we send you (collectively, "Preference Data");

(e) details of any transactions, purchases, or orders that you've made with us (collectively, "Transaction Data");

(f) payment information, for example No financial data will be collected from users (collectively, "Financial Data");

(g) information about your device or connection, for example Geolocation data, health related data, demographics

data will be collected on the mobile device application. and information we collect through cookies and other

data collection technologies (please read our Cookies Policy for details) (collectively, "Technical Data"); and

(h) Information about your use of or visit to our Platform, for example The administrative platform stores the public

key of the user. (collectively, "Usage Data").

1.2 We collect the above information when you provide it to us or when you use or visit our Platform. We may also

receive information about you from other sources, including:

(a) our business partners and service providers based in Hong Kong who provide technical, payment, delivery

services, advertising networks, analytics, market research, and search information services.

1.3 We do not collect sensitive data or special category data about you. This includes details about your race, ethnic

origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.

2 How we use information we collect

2.1 We only use your personal information where the law allows us to. We use your personal information only where:

(a) we need to perform the contract we have entered into (or are about to enter into) with you, including to operate

our products or services, to provide customer support and personalised features, and to protect the safety and

security of our Platform;

(b) it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests,

for example for research and development, and in order to protect our legal rights and interests

(c) you've given us consent to do so for a specific purpose, for example we may send you direct marketing

materials or publish your information as part of our testimonials or customer stories to promote our products or

services with your permission; or

(d) we need to comply with a legal or regulatory obligation.

2.2 If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw

your consent any time by contacting us (please refer to paragraph 9 for contact information), but please note this will

not affect any use of your information that has already taken place.

2.3 We do not share your personal information with any company outside our group for marketing purpose, unless with

your express specific consent to do so.

2.4 For visitors to or users of our Platform who are located in the European Union, we have set out our legal bases for

processing your information in the Legal Bases Table at the end of this policy.

3 How we share information we collect

3.1 We may share personal information on aggregated or de-identified basis with third parties for research and analysis,

profiling, and similar purposes to help us improve our products and services.

3.2 If you use any third-party software in connection with our products or services, for example any third-party software

that our Platform integrates with, you might give the third-party software provider access to your account and

information. Policies and procedures of third-party software providers are not controlled by us, and this policy does

not cover how your information is collected or used by third-party software providers. We encourage you to review

the privacy policies of third-party software providers before you use the third-party software.

3.3 Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of

these websites or submit information to them, your information will be governed by their policies. We encourage you

to review the privacy policies of third-party websites before you submit information to them.

3.4 We may share your information with government and law enforcement officials to comply with applicable laws or

regulations, for example when we respond to claims, legal processes, law enforcement, or national security


3.5 If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal

information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify

you if such transaction takes place and inform you of any choices you may have regarding your information.

4 How we store and secure information we collect

4.1 We use data hosting service providers based in Hong Kong, Singapore to host the information we collect.

4.2 We have adopted the following measures to protect the security and integrity of your personal information:

(a) information is encrypted using TLS/SSL technology;

(b) your account is password-protected;

(c) access to your personal information is restricted to personnel or service providers on a strictly need-to-know

basis, who will only process your information on our instructions and who are subject to a duty of

confidentiality; and

(d) our information collection, storage, and processing practices are reviewed regularly.

4.3 We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable

regulator of a breach where we are legally required to do so.

4.4 While we implement safeguards designed to protect your information, please note that no transmission of

information on the Internet is completely secure. We cannot guarantee that your information, during transmission

through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

4.5 We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for,

including for the purposes of satisfying any legal, accounting, or reporting requirements. After such time, we will

delete or anonymise your information, or if this is not possible, we will securely store your information and isolate it

from further use. We periodically review the basis and appropriateness of our data retention policy.

5 How we transfer information internationally

5.1 We collect information globally and primarily store that information in Hong Kong, Singapore. We transfer, process,

and store your information outside your country of residence where we or our service providers operate for the

purpose of providing our products and services to you.

5.2 Some of the countries in which our companies or service providers are located may not have the privacy and data

protection laws that are equivalent to those in your country of residence. When we share information with these

companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate

mechanisms to safeguard the transfer of information.

6 Your rights

6.1 You have the right to:

(a) be informed of what we do with your personal information;

(b) request a copy of personal information we hold about you;

(c) require us to correct any inaccuracy or error in any personal information we hold about you;

(d) request erasure of your personal information (note, however, that we may not always be able to comply with

your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal


(e) object to or restrict the processing by us of your personal information (including for marketing purposes);

(f) request to receive some of your personal information in a structured, commonly used, and machine readable

format, and request that we transfer such information to another party; and

(g) withdraw your consent at any time where we are relying on consent to process your personal information

(although this will not affect the lawfulness of any processing carried out before you withdraw your consent).

6.2 Our Platform enables you to update certain information about yourself, for example You may change your business

or personal information by updating your user profile or changing your user settings.

6.3 You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications, by

updating your preferences within your account on our Platform, or by contacting us. Please note, however, that even

if you opt out from receiving marketing materials from us, you will continue to receive notifications or information

from us that are necessary for the use of our products or services.

6.4 As a security measure, we may need specific information from you to help us confirm your identity when processing

your privacy requests or when you exercise your rights.

6.5 Any request under paragraph 6.1 will normally be addressed free of charge. However, we may charge a reasonable

administration fee if your request is clearly unfounded, repetitive, or excessive.

6.6 We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if

your request is particularly complex or if you have made a number of requests.

7 Changes to this policy

7.1 We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our

Platform after the changes come into effect, you agree to be bound by the revised policy.

8 Policy towards children

8.1 Our products and services are not directed to individuals under 16. We do not knowingly collect personal

information from individuals under 16. If we become aware that an individual under 16 has provided us with personal

information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or

unintentionally collected information from an individual under 16.

9 Contact us

9.1 Please contact us at or submit any written request to:

Ipseity Network

Sunrise Industrial Bldg, 10 Hong Man St, 13/B, Chai Wan, Hong Kong

Attn: Bill Lee

9.2 Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you

have the right to file a complaint with a data protection authority in the country where you live or work or where you

feel your rights have been infringed.

Last updated: 21 May 2019


Cookies are small text files that are placed on your device by a web server when you access our Platform. We use

cookies to identify your access and monitor usage and web traffic on our Platform to customise and improve our products

and services.

We use both persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us

when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session

lasts (usually the current visit to a website or a browser session).

We use the following types of cookies:

(a) Strictly necessary cookies - these are cookies that are required for the operation of our site. They include, for

example, cookies that enable you to log into secure areas of our website.

(b) Functionality cookies - these are used to recognise you when you return to our site.

You can block cookies by activating the setting on your browser that allows you to refuse the use of all or some cookies.

However, if you do so, you may not be able to access all or parts of our site.


Processing purpose Type of data processed Legal basis
To register you as a user on our
Account Data To perform our contract with you
To enable you to use our products
and services
Account Data, Transaction Data,
Support Data, Technical Data [and
User Content]
To perform our contract with you
To process your payments Account Data, Transaction Data,
Financial Data
To perform our contract with you
To collect overdue amounts Account Data, Transaction Data,
Financial Data
Legitimate interest to recover debts
due to us
To notify you about changes to our
products, services, or terms
Account Data To perform our contract with you
To administer and maintain safety
and security of our Platform
Technical Data To perform our contract with you
To study usage of our products or
Transaction Data, Support Data,
Technical Data, Usage Data
Legitimate interest to improve our
Platform, products, and services
To gather feedback on our products,
services, or features
Account Data Legitimate interest to improve our
Platform, products, and services
To provide information on products
or services that may be of interest to
Account Data, Preference Data Consent, which you may withdraw
any time