Privacy Policy

1. Introduction

1.1. This Privacy Policy explains how Xtrari Limited (“Xtrari Limited”, “Data User”, “we,” “our” or “us”) collects, uses, discloses, and transfers personal data that has been provided to us. Personal Data about individuals (collectively, “data subject” “your” or “you”) means any information relating to an identified or identifiable natural person.

1.2. Our Privacy Policy is prepared in accordance with the Hong Kong Personal Data (Privacy) Ordinance (“Xtrari Limited”) and must be read together with any terms and conditions which may be available on other pages of our website.

This Privacy Policy applies to all visitors and users of our platform, including our website https://xtrari.com, and other individuals whose Personal Data we process in connection with the provision of our services.

1.3. For any questions, you can contact us at [email protected].

2. Definitions

• “Data User” means a person who or public body which, alone or jointly with other persons, controls the collection, holding, processing or use of the data.
• “Data Subject” means an identified or identifiable individual (hereinafter referred to as “your” or “you”) who is the subject of the data.
• “Personal Data” means any information relating (a) directly or indirectly to a living individual, (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and (c) in a form in which access to or processing of the data is practicable.
• “Processing” means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person authorized in writing by the Data User to collect, hold, process, or otherwise use data either (i) under the direct control of the Data User, or (ii) on behalf of the Data User.
• “Third party” means a person or public body other than the Data Subject, the Data User, or the Processor, that is authorized to process Personal Data.

3. Personal Data we collect and hold about you

3.1. We collect and process different categories of your Personal Data from you as described below.

We will obtain your consent before using your Personal Data for other purposes, unless otherwise permitted by applicable law.

3.2. Where we engage Third-Party Service Providers, agents, or subcontractors to process Personal Data on our behalf, we will take reasonable steps to ensure, through contractual or other appropriate means, that such providers implement appropriate security measures and protect Personal Data against unauthorised or accidental access, processing, erasure, loss, or use. Such parties will process Personal Data only in accordance with our instructions, for the purposes for which the Personal Data was collected or provided, and in compliance with applicable data protection requirements.

3.3. We may also collect Personal Data about you from third-party sources. These sources include:

• Third-Party Service Providers, including payment service providers and payment schemes,
• Other third parties that help us comply with legal obligations.

3.4. Our services are not intended for, or directed to, individuals who have not reached the minimum age required to independently enter into legally binding contracts under the law applicable to them. We do not knowingly collect, use, or otherwise process Personal Data relating to such individuals in connection with the provision of our Services.

4. Sharing your Personal Data

4.1. We do not rent, sell, or share your Personal Data with third parties except as described in this Privacy Policy.

4.2. We may transfer or disclose Personal Data to the subcontractors to provide the services you have requested and to fulfill our contractual obligations to you, and to fulfill legal and regulatory requirements.

4.3. We may share your Personal Data with third parties who process Personal Data on our behalf to provide you or us with services for the purposes outlined above. These third parties include:

• Professional advisers, including lawyers, insurers, auditors, and tax advisers
• IT service providers, including hosting and cloud services providers
• Other suppliers and providers of services that provide services to you or us, including banks, payment service providers, our subcontractors, agents, etc.

4.4. We may disclose Personal Data or any information you submit via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:

• Comply with any applicable law, regulation, legal process, or governmental department’s request,
• Enforce our policies (including our agreement), including investigating potential violations thereof,
• Prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal purposes, when we consider disclosure necessary or appropriate,
• Prevent, detect, investigate, or take action regarding any fraud, illegal activities, or other criminal activity,
• Establish or exercise our rights, or defend against legal claims,
• Prevent harm to rights, property, or safety,
• Cooperate with law enforcement agencies and/or enforce intellectual property or other legal rights when we find it necessary,
• Enforce our website terms, or
• In the event of a substantial corporate transaction, such as the sale of our business, merger, or consolidation.

5. Cross-Border transfers of your Personal Data

5.1. Where we transfer your Personal Data outside Hong Kong, we will take reasonable steps to ensure that such Personal Data is protected and handled in accordance with the requirements of the applicable data protection laws and regulations.

5.2. In the course of providing our services, we may transfer, store, or process your Personal Data using Third-Party Service Providers, including web hosting providers, cloud service providers, and other technology providers, which may be located outside Hong Kong. Any such transfer or processing will be carried out in accordance with applicable data protection requirements and subject to appropriate contractual, technical, and organisational safeguards.

6. Retention of your Personal Data

6.1. We retain your Personal Data for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some Personal Data for a longer time, taking into account factors including:

• legal obligation(s) under applicable law to retain records for a certain period of time,
• maintain business records for analysis and/or audit purposes,
• defend or bring any existing or potential legal claims.

7. Protection of your Personal Data

7.1. We take the security of our physical premises, our servers, and the Website seriously. We take all appropriate technical measures using recognized security procedures and tools in accordance with best industry practice to protect your Personal Data.

7.2. We use technical and organizational security measures to protect the Personal Data under our control against accidental or intentional manipulation, loss, destruction, and access by unauthorized persons.

8. Your Rights

8.1. Your rights in relation to the personal data include:

• Right to Access: You may request access to the Personal Data we hold about you and request correction of any Personal Data that is inaccurate. We may require you to verify your identity and provide additional information necessary to process your request. Subject to applicable laws and regulations, we will provide access to your Personal Data within the applicable timeframe and may charge a reasonable fee for complying with a data access request where permitted by law. Where we are unable to comply with your request, we will inform you of the reasons for our decision, except where we are not required to do so under applicable law. Please note that, in certain circumstances, we may not be able to provide access to Personal Data, including where an applicable exemption under the Personal Data (Privacy) Ordinance applies or where we are not the relevant data user. In such cases, where appropriate and where the relevant data user can be identified, we will direct your request to the appropriate party.
• Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete Personal Data that we hold about you. If we have shared this Personal Data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete Personal Data. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right to Withdraw Consent: If we process your Personal Data on the basis of your consent, you may withdraw that consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose. In which case, we will inform you of this condition. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

8.2. If you want to exercise your rights or should you have any questions regarding the processing of your Personal Data, you may write to the following email address: [email protected] or you can write to the address below: Unit A2-33, 3/F., Hang Fung Industrial Building, Phase 2, 2G Hok Yuen Street, Hunghom, Hong Kong.

8.3. Your requests can be sent to us in a free form (in the body of a letter, scan, etc.) to [email protected] with your full name and contact information for a quicker processing of your request. In case of doubt of your identity, we may ask you to verify your identity by providing a copy of any identity document.

9. Changes to this Privacy Policy

9.1. The website and/or any other information displayed on the website may change from time to time. As a result, at times it may be necessary for us to make changes to the website and this Privacy Policy.

9.2. You may request a copy of this privacy policy from us using the contact details set out above. If we change this privacy policy, the updated version will be posted on our website in a timely manner.

10. Contact us

If you have questions, complaints or concerns regarding the way in which your Personal Data has been used, please contact: