Skyyer Travel Guide Mobile Application - Privacy Policy

This Privacy Policy (“Policy”) governs the processing of personal data in connection with your use of the Skyyer Travel Guide Mobile Application (the “App”) for mobile devices by Skyyer Mobile Limited and Sky Publishing Limited. Under the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”) and related laws and regulations, Skyyer Mobile and Sky Publishing Limited have certain legal obligations regarding the personal data that we collect from you. This Policy is designed to give you useful information about why we gather your personal data, the way we collect it, what we use it for, when we might disclose it and how you can manage your personal data.

By downloading and using the App, you are accepting our Terms of Use and our Policy. If you do not agree to the terms of this Policy, please do not download the App.

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on this Policy the date it was last updated and by sending you a notice regarding such changes by email, text or push notification, and you should review this Policy from time to time. Your continued use of the App following the posting of changes to these terms will mean you accept those changes. If you have any questions about this Policy, you should contact us at support@skyyer.com.

We will only collect and use your personal data for the purposes which are set out in this Policy.

What kind of personal data is collected?

We collect two basic types of data from you in conjunction with your use of the App, “Personal Data” and “Non-Personal Data”.

“Personal Data” is any information that can individually identify you and includes your name, e-mail address, user name, telephone number, postal address, credit card number, billing and contact information. Personal Data may be supplied to us when you register to use the App, enter a contest, upload content, or provide your e-mail address or personal information. We may also, and by using the App you agree that we may, access other Personal Data on your mobile device, such as your phone book, calendar or messages, as well as your profile and other information about you published on other social media platforms such as Facebook when you log in to use the App using Facebook or other social media accounts.

“Non-Personal Data” includes “aggregate” and/or automatic information, which is data collected about the use of the App or about a group or category of users from which individual identities or other individually identifiable information has been removed. This Policy in no way restricts or limits our collection, use and provision of Non-Personal Data.

Personal Data

The following are the most common situations when we may collect and store your Personal Data, and by using the APP you agree to us collecting through such means, although these means are not exhaustive:

  1. Registration to use the App;
  2. Browsing and use of the App;
  3. Entry in contests or promotions;
  4. Submission of user-generated content to the App;
  5. Request for customer service or other assistance;
  6. Collection of Personal Data from social media sites. When you log in to use the App using Facebook or other social media account, we may collect the personal data that is made available to us on that page or account including your account ID, profile and other information about you on Facebook and/or other social media accounts. However, we will endeavour to comply with the privacy policies of the corresponding social media platform and we will only collect and store such personal data that we are permitted to collect by these social media platforms.

Non-Personal Data

When you use the App, we may keep an activity log that does not identify you individually and cannot be used to identify the identity of any particular visitor of the App. Generally, we collect and store the following categories of Non-Personal Data:

  1. Demographic data such as age and gender;
  2. Device information about your mobile or other device that you use to access the App. This information may include the IP address of your device, your device’s operating system, the type of mobile Internet browser you use, the browser’s type and configuration, the geo-location information and other unique device identifiers of the device accessing the App, browsing preferences such as language settings and font size, etc;
  3. Information about your use of the App including the number of new or returning visits, statistics on the pages visited and referred, a reading history of the pages you have viewed, search terms used and search results, "traffic data" such as time of access and date of access.

We may collect, use and share these Non-Personal Data for customizing, enhancing and optimizing the quality of the App, and for maintaining and improving the App (e.g. determining optimal screen resolution, language and font settings, etc.). This Policy in no way restricts or limits our collection, use and provision of Non-Personal Data.

Collection of Your Source IP Address/Location Information

When you access the App, we may use GPS technology (or other technology) to determine and collect information about the current location of your device. This geo-location data is collected anonymously in a form that does not personally identify you. Advertisements and certain content may be directed to you as a result of this geo-location data. We use geo-location data for customizing, providing and improving our services and your browsing experience on the App. If you enable this feature, the current location of your device will be stored locally on your mobile device which will be used by the App to serve you certain contents tied to the relevant location. If you elect to have your location-based searches saved to your history, we will store such information on our servers.

We may share the geo-location data of your device with other users of the App or our partners for customizing, providing and improving our services and your browsing experience on the App. When this type of Non-Personal Data is shared with our partners for the above purposes, the data do not individually identify you, and the other parties do not have access to your personally identifiable information.

Use of cookies

You should be aware that when you use the App, we may collect information by using cookies, web beacons or unique device identifiers to identify your device that is accessing the App. Cookies are small text files that are stored on your mobile device when you access the App and certain online pages. They record your preferences and actions when accessing the App. We use cookies to track use of the App. We may also use cookies to monitor traffic, to maintain and improve the App, and to customize, enhance and optimize your browsing experience on the App so to make it easier and/or relevant for your use. Cookies do not recognize you personally and are not harmful to your device. None of the cookies that we use contain information such as your real name or address, so you cannot be identified personally by them.

You may occasionally get cookies from companies advertising on our behalf. We do not control these cookies, and these cookies are not subject to this Policy.

Most browsers are initially set up to accept cookies. You can manage and adjust your cookies setting by changing the browser setting for your device. However, if you choose to decline or disable cookies on your device, the features and functionality of the App will not work properly.

How do we use your data?

We may use your Personal Data and Non-Personal Data in the following ways:

  1. Register, verify and manage your account on the App;
  2. Facilitate your log-in access to the App, e.g. establish and maintain your logged-on identity in the App so that you can conveniently browse, access and use the App without being repeatedly requested to log-on;
  3. Communicating with you about your account and sending you information about and/or features of the App;
  4. Monitoring, customizing or improving the use of the App;
  5. Facilitate our performance of our services offered on the App;
  6. Customizing the advertising and content of the App;
  7. Administering contests and promotions including informing you of a prize you have won;
  8. Posting your user-generated content to the App;
  9. Managing and responding to comments submitted on our message boards, blogs and other such user-generated content facilities;
  10. Enabling you to share our content with other users;
  11. Communicating with you about changes to our policies or terms;
  12. Detecting, investigating and preventing activities that may violate our policies or be illegal;
  13. Compile, process and generate statistics reports for the App, and performing statistical, demographic, and marketing analyses of users of the App;
  14. Compile, maintain and update our database of account holders and users on the App;
  15. Use for our internal management or administrative purposes in relation to the App.

Direct Marketing

We also intend to use your personal data in direct marketing. However, we may not do so unless we receive your consent (which includes an indication of no objection) for this purpose in accordance with the requirements of the PDPO.

Direct marketing will include but are not limited to communication by post, telephone, email or SMS about the App and products, services, events, offers and promotions connected with the travel guide services provided by Skyyer Mobile Limited and Sky Publishing Limited.

The personal data that will be used for our direct marketing purposes will be your name, user name, email address, mailing address and phone number.

When you first register to use the App, if you do not want your personal data to be used for direct marketing purposes, please indicate your objection by ticking the box at the end of the Terms of Use before you proceed to install or use the App.

You may also change your mind and request that we stop sending you direct marking materials/communications or to cease using or providing your personal data for any direct marketing purposes at any time by emailing us at support@skyyer.com. We will, at no cost to you, act on your request within 30 days and ensure that you are not included in future direct marketing promotions.

We do not share, sell, transfer, provide, rent or trade personal information with third parties for their direct marketing purposes unless we have obtained your consent in accordance with the requirements under the PDPO. We also do not allow advertising companies to collect personal data through our services for ad-targeting.

Who do we provide your data to?

We may share your personal data with others for various purposes. Except as expressly set forth in this Policy, we do not share, sell, transfer, provide, rent or trade personal information with third parties for their promotional purposes unless we have obtained your consent in accordance with the requirements under the PDPO:

  1. We may disclose or transfer your Personal Data to our related companies (including our holding companies and/or affiliated companies) or any third party service providers, whether within or outside Hong Kong, as necessary on a need-to-know basis;
  2. We may share Non-Personal data such as demographics and usage statistics and the geo-location data of your device with our advertisers, sponsors or other organizations. When this type of non-personal data is shared, those data do not individually identify you and also cannot be used to identify the identity of any particular visitor of the App, and the other parties do not have access to your personally identifiable information;
  3. We may transfer, sell or assign any of the information described in this Policy to any third parties as a result of a sale, merger, acquisition, consolidation, change of control, transfer of assets, reorganisation of our business, liquidation, or sale or dissolution of assets;
  4. We may be required to disclose your personal data pursuant to a subpoena, court order or legal process, or to comply with any applicable laws or regulations, or lawful request from government authority, which may be without notice to you; or
  5. Transfer your personal data to our service providers or suppliers engaged to provide us with information technology support or conduct server maintenance of our data banks, or process data on our behalf.

Children’s privacy

We do not knowingly collect personal information from children aged under 13. If you believe that we have inadvertently collected such information, please contact us at support@skyyer.com so that we can promptly obtain parental consent or remove the information.

Security

This App and the computers that supply data to the App incorporate reasonable safeguards to protect the security, integrity, completeness, accuracy and privacy of the personal data that we may collect and we have put into place reasonable precautions to protect such information from loss, misuse and alteration. We take reasonable administrative, physical and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which encrypts the personal data and information you input, and storing your information in encrypted form behind a firewall designed to block access from outside our network.

However, while we try our best to safeguard your personal data once we receive it, no security or encryption method can be guaranteed to protect information from hackers or human error, and no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

Storage or processing of data

The information that we collect may be stored or processed on computers or servers located in any country where we do business. By providing us with your personal data or by accessing and using the App, you consent to the transfer of your personal data outside Hong Kong to our facilities as described in this Policy. The personal data protection laws of the other countries might not be as comprehensive as those in Hong Kong, but we will take all reasonable steps to ensure the protection of your privacy and will only collect and use your personal data for the purposes which are set out in this Policy.

Your Obligation to Keep Your Access Rights Secure

You are entirely responsible for ensuring and protecting the security and confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur under your account and we shall not be held liable for any claims, loss or damage resulting from a breach of the foregoing or any unauthorized use of your account.

Retention of data

We will retain your Personal Data and Non-Personal Data for as long as it is necessary to fulfill the purposes for which they are to be used and erase any of your Personal Data and Non-Personal Data that we have stored as soon as reasonably practicable, subject to, or where otherwise required by law or permitted by law.

Links to other websites?

This Policy applies only to this App. When you are on the App, you could be directed to other sites beyond our control. These other websites may send their own cookies to you, independently collect data or solicit personal data. If you visit a website that is linked to our App, you should consult that site’s privacy policy before providing any personal data and we shall not be liable in relation to the activities of such sites.

Contests and promotions

Contests or promotions run via the App will be subject to a set of rules. The rules for each contest/promotion will specify how the information gathered from you for entry will be used and disclosed, if it is different to what is described in this Policy.

Access to and update of personal data

You can sign into your account to access and update any personal data that we have stored, such as your name, email, address and phone number. You have the right to know whether we hold your personal data, what type of personal data is held and request access to, and correction of, any of your personal data held by us. If you wish to have access to your personal data or to correct any personal data relating to you which is inaccurate, to obtain information in relation to relevant policies, you may send such requests or inquiries to support@skyyer.com.

Controlling your personal data

You can stop all collection of information by the App easily by uninstalling the App or deleting your account. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. We will remove personally identifiable information and other preferences associated with your account promptly after you delete your account on the App.

You may always opt-out of receiving communications from us. We provide you with the opportunity to opt-out of receiving communications at the point where we request information about you or you can send us a message at support@skyyer.com.