Privacy Policy

Muse Atom Technologies Limited

1. Your Privacy

Muse Atom Technologies Limited (“MUSE ATOM”, “we “, “our” or “us”) respects your legal rights of privacy when collecting, storing, using, processing and transmitting Personal Data and this PPS explains our privacy practices. We are legally required to comply with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region when collecting, holding, using and/or processing your Personal Data. In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality.

Please read the following carefully to understand our policy and practices regarding how your Personal Data will be collected, treated and processed. By providing your Personal Data to us, you are consenting to this PPS and the collection, use, transfer, storage and processing of your Personal Data as described in this PPS.

If you are under the age of 18, you must have a legal representative such as a parent or guardian accepting this Policy on your behalf before providing any Personal Data to us.

If there is any inconsistency between the English and other language versions of this PPS, the English version shall prevail.

2. Collection of Personal Data

Depending on the types of goods and/or services we provide to you, we may collect two basic types of data from you, “Personal Data” and “Non-Personal Data”:

“Personal Data” means any personally identifying data which we may collect from you when you seek product(s) and/or service(s) from us and include without limitation names; email and postal addresses; gender, phone number; date of birth; payment information; occupation; your education level, from which it is practicable for the identity of an individual to be directly or indirectly ascertained.

“Non-Personal Data” includes aggregate and/or automatic information, which is data collected about the use of goods and/or services (including without limitation our websites and/or mobile applications), or about a group or category of users from which individual identities or other individually identifiable information has been removed. This PPS does not restrict or limit our collection, use and provision of Non-Personal Data.

2.1 Personal Data

The following are the common situations when we may collect and store your Personal Data, although these situations are not exhaustive:

(a)	registration for a membership, enjoying benefits or otherwise using our services as a member of our programmes, activities and/or other services;
(b)	using and/or browsing our websites and/or mobile applications;
(c)	purchasing and/or using our products and/or services, including without limitation to purchasing any travel tickets and/or subscribing to our communication materials;
(d)	entry and/or participating in any of our promotional, marketing or advertising activities;
(e)	posting, uploading, creating or otherwise generating any content and/or information, including any artistic, musical, literary, sound recording, film and/or any type of work on our websites and/or mobile applications; and
(f)	request for customer service or other assistance in connection with our products and/or services.

2.2 Non-Personal Data

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

(a)

information about your device that you use to access our websites and/or mobile applications. This information may include the device name, IP address, operating system and version, the type of network and mobile Internet browser you use, the browser’s type and configuration, the geo-location information and other unique device identifiers of the device, browsing preferences such as language settings and font size etc.; and

(b)

information about your use of the website and/or mobile application, including but not limited to the domain names you visit and the specific actions you take on the website and/or mobile application, the number of new or returning visits, statistics on the pages visited and referred, a reading history of the pages and sites you have visited and viewed, search terms used and search results, error and crash statistics, traffic data (such as time, duration and date of access).

The above Non-Personal Data are collected and used to measure traffic, gauge the popularity of various parts of our websites and/or mobile applications, to gain general knowledge about our audience and market our websites and/or mobile applications to advertisers with whom we may share summarized traffic data. We may also share to third parties (including without limitation to those specified under paragraph 4 below) these Non-Personal Data for customizing, enhancing, optimizing, maintaining and/or improving the quality of our websites and/or mobile applications, such as for determining the optimal screen resolution, language and font settings, etc. This Policy in no way restricts or limits our collection, use, handling and provision of Non-Personal Data.

3. Purposes for Which We Will Use Your Personal Data

The purposes for which we may use your Personal Data will vary depending on the type(s) of product(s) and/or service(s) you seek from us. Such purposes will be stated in the Personal Information Collection Statement (“PICS”), application form, terms and conditions, mobile application and/or webpage relevant to your provision of Personal Data to us. If you fail to supply the Personal Data required, we may be unable to provide the specific products / services in full to you.

4. Disclosure and Transfer of Personal Data

In cases where we do collect Personal Data from you, we will:

(a)

tell you (by way of a PICS or by a separate notification) that we are doing so and any purpose of use that we will make of such Personal Data we collect; and

(b)

where relevant, give you the opportunity to object to a particular use of your Personal Data. If a piece of personal data is necessary to fulfill a request from you, your provision confirms that you consent to our use of your data in order to fulfill that request. Or you can choose to withdraw your request, but we may not refund the amount you paid and reserve the right to pursue any fees incurred from you if you have been informed of the terms and confirmed them before.

We will to take all practicable steps to keep your Personal Data confidential but we may disclose, transfer and/or assign such data to the following parties:

(a)	if MUSE ATOM decides to sell, merge and/or re-organize any part of its business, to any actual or proposed assignee, transferee or successor of or to MUSE ATOM’s rights in respect of your Personal Data;
(b)	any agent, adviser, auditor, contractor or third-party service provider who provides administrative, telecommunications, computer, payment, fraud prevention, insurance, data processing and/or other services to us in connection with the operation of our business and/or the relevant product(s) and/or service(s) that you seek from us, and/or who otherwise processes Personal Data for and on our behalf; and
(c)	any person (including without limitation government authorities, regulatory or administrative bodies or law enforcement agencies) to whom MUSE ATOM is under an obligation to make disclosure under the requirement of any law binding on MUSE ATOM or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which MUSE ATOM is expected to comply, or such parties who are authorized by law to request information from MUSE ATOM.

We may also disclose and/or transfer your Personal Data in the manner as stated in the Personal Information Collection Statement and/or any terms and conditions relevant to the product(s) and/or service(s) you seek from us.

The parties to whom we disclose and/or transfer your Personal Data may be situated outside of Hong Kong where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Personal Data (Privacy) Ordinance.

5. Notice to UK and EU Residents

Please note that the “personal information” referenced in this PPS means “personal data” as that term is defined under the European Union (“EU”) General Data Protection Regulations (“GDPR”) and its United Kingdom (“UK”) GDPR counterpart. MUSE ATOM is a data controller for the personal information collected from all categories of data subjects listed above, with the following exceptions: MUSE ATOM may process data on behalf of its Customers. In such case, MUSE ATOM is a data processor. In addition, MUSE ATOM is a data processor for any of the content provided by Customers and End Users through the Services that transits, or in some cases, is stored on, the MUSE ATOM network. Where MUSE ATOM is a data processor, MUSE ATOM processes data on behalf of its Customers pursuant to their data processing instructions.

If you are an individual from the European Economic Area (the “EEA”), the UK or Switzerland, please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, MUSE ATOM will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object by emailing us at [email protected].

6. Links to Other Websites

If you use our websites or mobile applications, there may be advertisements or hyperlinks linking to another website (e.g. Linked Sites). If you click on any of these advertisements or hyperlinks, you will leave our websites or mobile applications for another location. At any other website, the protection of your privacy, Personal Data and your exposure to cookies are not our responsibility, and you are advised to refer to the privacy policy of that other location (if any).

Some of our websites and/or mobile applications may allow you to link and/or connect to third-party social networking sites. If you choose to link and/or connect to these third-party social networking sites, we may be able to collect certain Personal Data from your social networking profile provided to us by the social networking site. In that case, we will collect and use such Personal Data only for the purpose of providing you with the connection to the social networking site.

7. Cookies

Some of our websites use “cookies” to authenticate users, prevent fraud, protect you as you interact with a service, and help us analyze how users use those websites. A cookie is a small text file that is stored on your device (e.g. on your computer) when you visit or access a website. A cookie can be used to identify a computer or a mobile device. It, however, is not used to collect any personal information and does not recognize you personally. In other words, it does not have the function of identifying an individual user of our websites.

Within our websites, cookies are used to track the use of and monitor traffic on our websites, as well as to improve, customize and enhance your browsing experience, for example:

(a)	Strictly necessary cookies are used to indicate your active session of our websites and remember the information you’ve entered in a form or details about a payment you want to make. Without them, the information would be lost every time you move to a new page;
(b)	Performance cookies are used to collect anonymous information about how you use our websites, such as which pages you visit on our websites. We use this aggregated information to improve our websites; and
(c)	Functional cookies are used to record information about choices you’ve made and to recommend contents of our websites that are relevant to you and your interests.

On some pages, we feature embedded “share” buttons or widgets that enable you to connect to other social networking sites such as Facebook and Twitter. These sites may set cookies which can identify you as an individual when you are logged in to their services. We do not control these cookies and you should check the relevant third-party website to see how your information is used and how to opt-out.

If you use or continue using our websites, we will assume that you are happy for us to set cookies. You may choose to reject all or some cookies at any time by changing the setting of your web browser on your device. Please visit www.allaboutcookies.org to find out how to manage cookies. However, please be aware that if you choose to delete or restrict cookies, you will not be able to use some of the functions of our websites.

8. Security and Storage

Except as mentioned in paragraph 4 above, your Personal Data, however stored, will be accessed only by our employees or contractors who are authorized to do so. Where Personal Data is stored electronically, it will be kept on a secured server and will be encrypted and/or password-protected (or under some equivalent form of protection) and accessible only by authorized personnel of MUSE ATOM or its contractors. The network transmission of Personal Data will also be protected by using the SSL protocol. Personal Data are treated as confidential information by MUSE ATOM, and all employees and contractors designated to handle Personal Data will be instructed to do so only in accordance with this PPS.

9. Use of Personal Data in Legal Proceedings

If it becomes necessary that we have to take action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the Personal Data provided by you can be relied upon in identifying and taking legal action against you.

10. Your Right to Access and Correct Personal Data

You may at any time request access to and correct Personal Data relating to you in any of our records. You may also ask us to delete you or your Personal Data from any active mailing or distribution list. To exercise any of your rights, mark your communication “Confidential“ and contact us at the address below or email us. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days. We may also charge you a reasonable fee for complying with any data access request.

Personal Data Privacy Officer

Any requests (a) for access to data or correction of data; (b) for general information regarding our policies and practices with respect to Personal Data; and (c) about the kinds of Personal Data that we hold; and/or general questions and complaints relating to this PPS should be addressed to the person below:

Muse Atom Technologies Limited
Address: Room 702 Kowloon Building
555 Nathan Road
Kowloon
Hong Kong

Attention: Personal Data Privacy Officer
(Marked Confidential)
Email: [email protected]

11. Retention of Personal Data

Personal Data provided by you are retained for as long as the purposes and any directly related purposes for which such data were collected continue. Once it is not necessary to use the Personal Data to fulfil such purposes (and directly related purposes), they are then destroyed within a reasonable time unless their retention is required to satisfy legal, regulatory or accounting requirements or to protect the MUSE ATOM’s interests.

This PPS is subject to change. Any changes will be posted on this page. Your continued use of our websites and/or mobile applications after the posting of such changes indicates your acceptance of those changes.

In the event that there is any inconsistency between the English and other language versions of this PPS, the English version shall prevail.

Last update: December 17, 2023