Updated 16 April 2025
Introduction
At Expando®, we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, store, and protect your personal data in compliance with the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong and other Applicable Regulations. This policy applies to all users of our services, including customers, employees, and website visitors.
Definitions
"Applicable Regulations" means the Hong Kong Personal Data (Privacy) Ordinance and any other regulations applying to us.
"Do-not-call Registers" means a register comprising customers not wishing to be contacted for advertising purposes.
"Information" means details of a particular individual or company.
"Expando AI™" refers to the B2B marketplace and collaboration platform operated by Expando®.
"Website" means www.expando.ai and any other affiliated sites.
"You" or "Your" means the persons to whom this policy applies.
Types of Personal Data Collected
We collect the following types of personal data:
Identification Information: Name, address, contact details (e.g., phone number, email), and identification numbers (e.g., HKID, passport number).
Financial Information: invoices for partner payouts
Technical Data: IP address, device information, cookies.
We collect this data through various means, including online forms, website interactions, and third-party service providers.
Purposes of Data Collection
We collect your personal data for the following purposes:
Primary Purpose: To provide and improve our referral management services, process orders, and respond to inquiries.
Secondary Purposes: For marketing and analytics, but only with your explicit consent.
Legal Basis: Our legal basis for processing personal data includes consent, contractual necessity, and legal obligations.
Use of Personal Data
Your personal data may be used for:
Developing and Providing Services: Including research, planning, statistical analysis, and improving service quality and advertising strategies.
Assessing Applications: Processing applications, instructions, or requests.
Communicating with You: Providing updates on changes to services, responding to inquiries, and notifying you about changes to our services.
Managing Infrastructure: Managing business operations and complying with internal policies and procedures.
Contractual Obligations: Fulfilling obligations arising from contracts between you and us.
Marketing: Providing information about other services we offer, with your consent.
Website Administration: Administering our website, ensuring content is presented effectively, and keeping the website safe and secure.
Compliance: Complying with applicable laws, regulations, and requests from authorities.
Professional Advice: Seeking professional advice when necessary.
We may share your data with third-party service providers, such as payment processors, cloud service providers, and marketing agencies, to facilitate these activities. We ensure that these third parties comply with our privacy standards and legal requirements.
Data Security
We implement robust technical and organizational measures to protect your personal data, including:
Encryption and access controls.
Regular security audits and updates.
Firewalls and intrusion detection systems.
In the event of a data breach, we will notify affected individuals and the Privacy Commissioner, if required.
Data Access and Correction
You have the right to access and correct your personal data. To submit a request, please contact our Data Protection Officer at dpo@expando.ai. We will respond to your request within 40 calendar days.
Direct Marketing
We will only use your personal data for direct marketing with your explicit consent. You can opt out of receiving marketing communications at any time by clicking the "unsubscribe" link in our emails or by contacting us at dpo@expando.ai.
Use of Cookies and Tracking Technologies
We use cookies and similar technologies to improve your browsing experience, analyze usage, and personalize content. You can manage these cookies through your browser settings.
Session Authenticator:
Purpose: Keeps you logged in while using PocketBase, ensuring your session stays active.
Value: Session key
Language Preference:
Purpose: Remembers your preferred language setting for the application, allowing for a localized experience.
Value: Locale value (e.g., "en-US")
Sign-In Choice:
Purpose: Saves your preferred method for signing in, whether by email or password.
Value: Can be "email_signin" or "password_signin"
Active Session:
Purpose: Maintains your login status across different pages, so you don't have to log in repeatedly.
Value: Session value
These cookies help us provide a smooth and personalized experience. You can adjust your cookie preferences at any time through your browser settings.
Third-Party Links
Our website may contain links to third-party sites. We are not responsible for their privacy practices, and we advise you to review their privacy policies.
Children’s Privacy
Our services are not intended for children under the age of 13. We do not knowingly collect personal data from children without parental consent.
Updates to This Policy
We may update this privacy policy from time to time. The latest version will be posted on our website, and we will notify you of any significant changes.
Contact Information
For privacy-related inquiries or complaints, please contact our Data Protection Officer at dpo@expando.ai.
Do-Not-Call Registers
We respect your choice to opt out of marketing communications. If you do not wish to be contacted for advertising purposes, please let us know, and we will ensure your details are added to our Do-not-call Registers.
Data Storage and Transfer
Your data may be transferred to and stored at destinations outside Hong Kong. It may also be processed by staff operating outside Hong Kong who work for us or for one of our suppliers. We ensure that such transfers are made in full compliance with Applicable Regulations.
Your Rights
You have the right to:
Check whether we hold your personal data.Request access to your personal data.
Make corrections to personal data held by us.
Object or restrict the use or processing of your information in some circumstances.
Please contact our Data Protection Officer for details on how you may exercise these rights.
Sale of Personal Data
We will never sell your personal data without your prior written consent. If we sell any business or assets, we will request your prior written consent to disclose your personal data to the prospective buyer. In the absence of your consent within five (5) days following our request, we will erase your personal data before the potential transfer of such business or assets.
Subcontracting
Expando AI reserves the right, which is accepted by the CLIENT, to subcontract all or part of the services, purpose of the SUBSCRIPTION, or to call upon the particular skills or experience of third parties, experts or service providers.
Advertising
Expando AI is authorized to quote the name of the CLIENT as reference among its clients list.
Assignment
The SUBSCRIPTION is concluded in consideration of the person of the CLIENT.
In this regard, it will not, without having obtained the prior written consent of Expando AI, be the subject of a total or partial assignment, whether in return for a fee or free of charge, due to the CLIENT.
This clause also applies in the event of a project of assignment of full ownership or of a split-up property of the business goodwill or of the securities of the CLIENT's company, lease management, contribution to a company, merger, demerger, partial assignment of assets, modification in the person of the legal representative or of the partners or shareholders.
However, as an exception to the principle stated above, the CLIENT may carry out such an assignment or transfer of the Contract to another entity controlling it or which would be under its control. This assignment or transfer of the Contract will be admitted after prior notification to Expando AI. The CLIENT will then remain guarantor of the obligations of the transferee entity for the entire duration of the SUBSCRIPTION and its possible renewals.
In this context, in the event of assignment of the CLIENT or the SUBSCRIPTION as defined above, Expando AI will be entitled to terminate the SUBSCRIPTION based on this clause.
On the other hand, Expando AI reserves the right to freely assign or transfer the SUBSCRIPTION to a third party, which the Client accepts.
Modification of the Terms and Conditions
Taking into account the possible evolutions of the WEBSITE and the SOLUTION, Expando AI reserves the possibility of adapting or modifying these Terms and Conditions at any time.
The Terms and Conditions then in force will be applicable to all orders placed as from the moment they are posted on the WEBSITE. Regarding the ongoing SUBSCRIPTION, the modified Terms and Conditions will be submitted to the CLIENT where applicable. In the event of refusal to validate the new Terms and Conditions, those in force at the time of the Order shall remain applicable until the end of the current SUBSCRIPTION. The new version shall only be applicable as of the tacit renewal.
In the event that any one of the provisions of the Terms and Conditions is considered illegal or unenforceable by a court decision, the other provisions shall remain in force.
Agreement on Evidence
The Client's “clicks” made by the Client as part of the acceptance of these Terms and Conditions, but also as part of the order and payment, constitute acceptance of the Contract.
The computerized registers stored in the computer systems of Expando AI, will be stored under reasonable conditions of security and will be regarded as the proof of the communications, orders and payments occurred between the parties.
The archiving of orders and invoices is carried out on a reliable and durable media which can be produced as proof.
Applicable Law – Election of Jurisdiction
These Terms and Conditions are subject to Hong Kong domestic law, excluding any international convention.
In the event of a dispute relating to these Terms and Conditions, as well as to the commitments they govern, the Parties shall try as far as possible to resolve their dispute amicably, within one month of notifying the other Party by registered letter with acknowledgment of receipt, either directly or by calling upon a mediator appointed by mutual agreement.
IN THE EVENT OF FAILURE, THE LITIGATION WILL HAVE TO BE BROUGHT, EVEN IN THE EVENT OF SUMMARY PROCEEDINGS AND NOTWITHSTANDING PLURALITY OF BODIES OR PARTIES, OR GUARANTEE CLAIM, BEFORE THE COMPETENT COURTS OF HONG KONG, PLACE OF THE REGISTERED OFFICE OF Expando AI, TO WHICH THE PARTIES ELECT JURISDICTION, EXCEPT IN THE CASE WHERE ANOTHER JURISDICTION WOULD BE DESIGNATED COMPETENT BY THE RULES OF PUBLIC ORDER IN PARTICULAR OF THE RIGHT OF LITERARY AND ARTISTIC PROPERTY.
Translation
This Contract is executed in English. In the event this Contract is translated into a language or languages other than English, this version in English shall be controlling on all questions, interpretations or performance, and the English language text shall in any event prevail.
