Privacy Policy

Effective on: November 5, 2019

Introduction and Scope

Truly Scaled Limited (“Truly Scaled”, “we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Policy (the “Policy”) addresses data subjects whose Personal Data we may receive through our websites (collectively, the “Sites”).

Controllership

Within the scope of this Policy, Truly Scaled acts as a data controller for the Personal Data we process.

Basis of Processing

We may process your Personal Data on the basis of:

  • your consent;
  • our legitimate interests or those of a third party, such as our interest in marketing our Sites;
  • the need to comply with the law; or
  • any other ground, as required or permitted by law.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect processing performed on other lawful grounds.

How We Receive Personal Data

We may receive your Personal Data when:

  • you provide it directly to us as part of using our Sites;
  • you interact directly with our Sites or content on our Sites; or
  • our service providers provide it to us.

Categories of Personal Data

We may process the following types of Personal Data:

  • device information, such as IP address, device ID, and unique cookie strings;
  • location information, such as country, state, city, and latitude/longitude; and
  • contact information, such as name, mailing address, and email address.

Purposes of Processing

We may process your Personal Data for the purposes of:

  • serving targeted advertisements;
  • enabling the use of the Sites;
  • responding to your requests or questions; and
  • sending you email marketing communications about our business which we think may interest you.

Data Retention

We will delete all Personal Data of the data subject within fourteen (14) months of the purpose of processing the Personal Data being completed.

Sharing Personal Data with Third Parties

We may share Personal Data with our subsidiaries, affiliates, external partners, and customers as well as with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Sites or as required by law. Our service providers may provide:

  • application hosting services;
  • cloud storage services;
  • email software; and
  • web hosting and security services.

Other third parties we share Personal Data with may include ad exchanges, data aggregators and suppliers, and demand-side platforms.

Some of these third parties may be located outside of the European Union or the European Economic Area. In some cases, the European Commission may not have determined that the countries’ data protection laws provide a level of protection equivalent to European Union law. We will only transfer your Personal Data to third parties in these countries when there are appropriate safeguards in place. These may include the European-Commission-approved standard contractual data protection clauses or other approved cross-border transfer mechanisms used by our vendors.

Other Disclosure of Your Personal Data

We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our websites and Sites.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Some of the cookies placed on your device through our Sites are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Sites. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Sites’ features. For more information, please visit https://www.aboutcookies.org/.

You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Sites do not have the capability to respond to “Do Not Track” signals received from web browsers.

Data Integrity & Security

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.

Access & Review

If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data. You may also have the right to ask that we limit our processing of such Personal Data, as well as the right to object to our processing of such Personal Data. You may also have the right to data portability.

If we have received your Personal Data in reliance on the Privacy Shield, you may also have the right to opt out of having your Personal Data shared with third parties and to revoke your consent to our sharing your Personal Data with third parties. You may also have the right to opt out if your Personal Data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. To submit these requests or raise any other questions, please contact us by using the information in the “Contact Us” section below.

Privacy of Children

The Sites are not directed at, or intended for use by, children under the age of 13.

European Union Supervisory Authority Oversight

If you are a data subject whose Personal Data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.

Changes to this Policy

If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Effective” date. By continuing to use our Sites after we post any of these changes, you accept the modified Policy.

Contact Us

If you have any questions about this Policy or our processing of your Personal Data, please write to our Privacy Team by email at privacy@trulyscaled.com or by postal mail at:

Truly Scaled Limited
Room 607, Yen Sheng Centre
64 Hoi Yuen Road, Kwun Tong
Hong Kong

Please allow up to four weeks for us to reply.