Privacy Statement

‍

We take user's data privacy regarding the use of our Predict Beta Google Sheets and Google Data Studio ("Add-on") very seriously. We ask that you read this privacy statement ("Privacy Statement") carefully as it contains important information about how we will use your personal data. This Privacy Statement forms part of the Terms governing your use of the Add-on (including any products and services that may be provided to you through the Add-on).

1. Data processor

The Add-on is provided by More Champ Limited (trading as gini) (" we", "our" or "us"). Our registered office is 2/F, Henan Building, 90-92 Jaffe Rd, Wan Chai, Hong Kong.

2. Collection of personal data

1. We may collect and process personal data (as defined in the Personal Data (Privacy) Ordinance ("PDPO")) about you when you register for, install, download, access or use the Add-on, or contact us in relation to the Add-on. 

2. We may seek your consent to this Privacy Statement and our use of your personal data in a number of ways depending on the medium in which you interact with us, such as via your signature to confirm you have read our Privacy Statement, verbal consent over the telephone, via an online checkbox or by registering an account for, or installing the Add-on. You acknowledge that failure to provide personal data requested might prevent you from registering for, using and continuing to use the Add-on.

3. We will only use your personal data, as set out below, in accordance with the PDPO, and while we are not based in the European Economic Area ("EEA"), we comply with the European Union's General Data Protection Regulation 2016/679 ("GDPR") as a matter of best practice as far as possible:

a. When you install and use the Add-on, we collect the following personal data:

      ■  Your email address; and

      ■  Personal data that is linked with your Google Account (such as your name, Gmail and your billing information).

b. When you use the Add-on, we may also collect the following personal data, depending on what information you would like to process with the Add-on:

      ■ Financial details belonging or relating to you and your use of the Add-on;

      ■ Details of transactions made by you; and

      ■ Any other personal data, whether it comes from you or is collected and/or processed on behalf of any other third party by you, that you voluntarily input, post, transmit, stream or upload when using the Add-on. 

c. By inputting, posting, transmitting, streaming or uploading and processing personal data of your own or other third party you act on behalf of in the Add-on, you warrant that you have the legal right to provide such personal data and give us consent to process such data in a manner in accordance with this Privacy Statement.

d. We will use the personal data for the following purposes:

      ■  to help us identify you and any accounts you have installed our Add-on;

      ■  to provide you with goods and services via the Add-on (such as using your personal details to authenticate you as the person who could use the Add-on);

      ■  to communicate with you;

      ■  to customise the Add-on and its content to your particular preferences;

      ■  to inform you with special offers on other products or services we think you might like;

      ■  to carry out research and statistical analysis and create market reports on an anonymised or aggregated basis (which means that we will not identify you individually for the purpose of such research, analysis or reports) to help us better understand our users, and to enhance and develop our Add-on and its content, products and services; and

      ■  to notify you of any changes to the Add-on or to our services that may affect you.   

e. We will not use your personal data for any unlawful purpose. 

f. You agree that all personal data provided by you to us may be used and retained by us for the purposes as stated in clause 2(a)(iv) above or as required by any applicable laws and regulations from time to time. If we intend to use your personal data for any new purpose not listed in clause 2(a)(iv) above, we will inform you in advance and you will have an opportunity to refuse to allow us to do so.

g. When you use the Add-on, we collect and store the sources of data you input, post, transmit, stream or upload, for the purpose of creating forecast(s) for you from the data or to provide the intended service.  

h. We will get access to and use meta level data generated during the creation of your sources, datasets, models, forecasts, and predictions for the sole purpose of improving our service over time. Where this data contain personal data, we will take steps to anonymise it before using it for improving our service.

i. We do not collect and strongly discourage users from inputting, posting, transmitting, streaming or uploading and processing special category personal data as defined in the GDPR, i.e. personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, trade union membership, genetic and biometric data, or data concerning health, sex life or sexual orientation ("Special Data"). Nevertheless, if you voluntarily input, post, transmit, stream or upload and process such Special Data, whether it comes from you or a third party you act on behalf of, you give us consent to process such data in a manner in accordance with this Privacy Statement.

3. Disclosure of personal data to third parties

1. We may disclose and/or transfer your personal data, from time to time, to:

a. other companies within our group, for the purposes set out at clause 2 above; 

b. our trusted agents, contractors or vendors ("Service Providers");

c. actual or proposed assignees or transferees of our rights ("Successors"); and

d. law enforcement and/or regulatory agencies as may be required by law.

2. In general, where personal data is to be disclosed to a third party, we will take steps to ensure that such data would be anonymised as far as possible before sending them to a third party. Keys to unlock any anonymised personal data would stay with us. Where this is not possible, we will require that the recipient of the personal data keeps it confidential at all times and subject to a privacy statement and/or terms and conditions no less restrictive than this Privacy Statement and the Terms.

3. We may disclose and/or transfer your personal data (whether in Hong Kong or abroad) to our Service Providers, provided that they are under a duty of confidentiality to us. Contractual obligations would be imposed on them to ensure that they can only use your personal data to provide services to us and to you but not any other third parties. Such Service Providers may provide administrative, data processing, research and marketing, distribution, telecommunications, shipping, financial, consultancy, professional or other similar services to us to enable us to better fulfil customer orders, manage, store and enhance customer data, and comply with postal regulations. 

4. We may also provide your personal data to Successors with respect to you in connection with a merger, sale or transfer (whether of assets or shares) involving us. In such event, we will ensure the personal data would still be subject to this Privacy Statement and the confidentiality of your personal data under the hands of the Successors. We will notify you in advance if your personal data will be subject to a private policy different from this Privacy Statement under the Successors. 

5. Other companies may also forward to us additional personal data, (such as, for example, names, mailing addresses and email addresses, as well as demographic and other usage information), when we have news or product offerings that may be of special interest to those individuals ("Marketing"). We work to ensure that these companies have obtained prior consent from those individuals before they pass such personal data on to us. Please inform us if you believe we have acquired your personal data in this way and you have not given your consent to the companies for Marketing, as it is not our intent to make use of personal data which has not been legitimately acquired or to collect and process your personal data without your prior consent.

6. We do not disclose your personal data (whether your name, email address) to any other third parties other than those expressly set out above.

4. Storage of personal data

1. We may store your personal data in the following locations or with with the following services:

a. Amazon Web Services Hong Kong, Singapore and Tokyo;

b. Google Server;

c. Our offices or other companies within our group; and

d. Service Providers.

2. Please note that we are (and some of our Service Providers may be) based outside the EEA and your personal data may be transferred to locations which do not have the same standards of data protection law as within the EEA. Nevertheless, we will ensure the holding and transfer of your personal data complies with a higher standard of data protection as far as possible and in any event no less restrictive than the PDPO to ensure the privacy and security of your personal data. Your consent to this Privacy Statement confirms that you agree that your personal data may be transferred outside of Hong Kong and outside of the EEA accordingly.

3. We implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which it was collected. The retention period applied to various types of personal data that we hold varies depending on the respective data collection/usage purpose and relevant legal requirements. We will keep your personal data while you make use of our services or the Add-on and while you have an account with us. Once you close your account with us, we will keep your personal data for as long as is necessary to respond to any questions, complaints or claims that may be made by you or on your behalf, to show that we treated you fairly, and/or to keep records as required by law. Any personal data which is no longer necessary for us to retain will be deleted and/or anonymised.

5. Keeping your data secure

1. We will use technical and organisational measures to safeguard your personal data, for example:

a.  access to your account is controlled by your Google account;

b.  we encrypt your personal data; and

c. any personal data that we process or store is done on secured servers.

2. All processing of your personal data shall be conducted according to the data protection principles as follows:

a. personal data must be processed lawfully, fairly and transparently;

b. personal data must be accurate and kept up to date with every effort to erase or correct; and

c. personal data must be processed in a manner that ensures the appropriate security.

3. In addition, we have appropriate security measures in place to prevent personal data from being accidentally or unlawfully lost, used or accessed. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so and/or if there is a risk to your rights and freedoms.

6. Personal data of third parties provided by you

1. If you give us personal data on behalf of someone else, either directly or indirectly (for example when you input, post, transmit, stream or upload it using the Add-on), you are deemed to confirm that you have acquired prior consent to act for that person on his/her behalf and he/she has agreed that you can:

a. give consent on his/her behalf to the processing and transfer of his/her personal data in a manner in accordance with this Privacy Statement; 

      ■  receive on his/her behalf any notices relating to data protection; and

      ■  exercise on his/her behalf his/her data privacy right pursuant to clause 7 below.

2. We are not liable to any third party for any unauthorized use of that party's personal data provided to us.

7. Your rights

1. You have the following rights, which you can exercise free of charge and at anytime:

a. Right of access: you have the right to know whether we hold your personal data and to access any personal data held by us. You also have the right to access supplementary information in relation to any personal data held by us, including the purpose for which your personal data is being processed and with whom the personal data is shared. 

b. Right to rectification: you have the right to correct any inaccuracies of your personal data held by us.

c. Right to be forgotten: you have the right to require us to delete your personal data and any other third party's personal data that you voluntarily submitted to us.

d. Right to restrict processing: you have the right to require us to restrict processing of your personal data in certain circumstances, such as if you contest the accuracy of the data.

e. Right to data portability: you have the right to receive the personal data you provided to us in a structured, commonly used and machine-readable format and/or to instruct us to transmit that data to a third party.

f. Right to object: you have the right to object at any time to your personal data being processed for direct marketing and in other certain circumstances, such as if we change our legitimate interests from the basis on which we initially collected and processed your personal data or processed your personal data for a purpose different from the initial one we informed you.

g. Right not to be subject to automated individual decision-making: while we do not subject your personal data to decisions based solely on automated processing that produces legal effects concerning you or otherwise significantly affecting you, should we ever engage in such processes, we will first notify you and you will have the right to object to such processing.

2. If you wish to exercise any of the above rights, or make any related complaint or request in relation to your personal data, please contact us in writing at: predict.help@gini.co or at gini, 2/F, Henan Building, 90-92 Jaffe Rd, Wan Chai, Hong Kong.

8. Our contact details‍

We welcome your feedback and questions. If you wish to contact us, please send an email to predict.help@gini.co or you can write to us at gini, 2/F, Henan Building, 90-92 Jaffe Rd, Wan Chai, Hong Kong.

9. Changes to this Privacy Statement‍

We may change this Privacy Statement from time to time. Your rights under this Privacy Statement will not be reduced unless we receive your consent. Any changes will be posted on our website or notified by us to you (by email or post, for example).

10. Questions‍

If you have any questions regarding this Privacy Statement, please contact us and we will do our best to answer them.