Effective Date: 29^th November 2024

1. Introduction

GB Software Limited ("we", "our", "us") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and protect your personal data in compliance with Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and global privacy standards, including the General Data Protection Regulation (GDPR). If there are any discrepancies between the English and Chinese versions, the English version shall prevail.

2. Data Collection

We may collect and process the following categories of personal data:

• Contact Information: Name, email address, phone number, postal address.
• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Usage Data: Information about how you use our website, products, and services.
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

3. How We Collect Your Data

We use different methods to collect data from and about you including through:

• Direct Interactions: You may provide us with your identity and contact data by filling in forms or by corresponding with us by post, phone, email, or otherwise.
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns.

4. Use of Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To perform the contract we are about to enter into or have entered into with you.
• To comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• To send you marketing communications, where we have obtained your explicit consent.

5. Disclosure of Personal Data

We may share your personal data with third parties under the following circumstances:

• Service Providers: We may share your data with third-party service providers who perform functions on our behalf, such as IT and system administration services.
• Compliance with Legal Obligations: We may disclose your data to comply with legal obligations or respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

6. International Transfers

Your personal data may be transferred to and processed in countries outside of Hong Kong and the European Economic Area (EEA). We ensure that your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules."

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent at any time where we are relying on consent to process your personal data.

10. Changes to this Privacy Policy

We may update this privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on our website.

11. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact us at:

GB Software Limited

8/F, Cheung Hing Industrial Building, 12P Smithfield, Kennedy Town, Hong Kong SAR.

sales@gbsoftware.asia

+852 5348 7519