A Legal Disclaimer
Embracy Limited trading as "Embracy" (BRN: 72335453) ("we," "us," or "the Company") is committed to privacy protection. At [https://embracy.com] ("this site"), we understand the importance of keeping personal information private and secure. This privacy policy ("Privacy Policy") describes generally how we manage personal information and safeguard privacy. If you would like more information, please don't hesitate to contact us.
This Privacy Policy forms part of, and is subject to the provisions of, our Website Terms of Use at [https://embracy.com/terms-and-conditions].
We care about your privacy:
We will never rent, trade, or sell your email address to anyone.
We will never publicly display your email address or other personal details that identify you.
The Hong Kong Privacy Principles
We will treat all personal information in accordance with any and all obligations that are binding upon us under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") of Hong Kong. The PDPO outlines six key Data Protection Principles (DPPs) in relation to the collection and treatment of personal data:
Collection: Personal data must be collected for a lawful purpose and in a fair manner, with the knowledge and consent of the individual.
Accuracy and Retention: Personal data must be accurate, up-to-date, and retained only as long as necessary.
Use: Personal data may only be used for the purpose for which it was collected or a directly related purpose, unless consent is given.
Security: Reasonable steps must be taken to protect personal data from unauthorized or accidental access, processing, or use.
Openness: Policies and practices regarding personal data must be transparent and accessible to individuals.
Access and Correction: Individuals have a right to access and correct their personal data.
Processing merchant information
Personal information held by the Company may include your:
Name and date of birth;
Residential and business postal addresses, telephone/ mobile/fax numbers and email addresses;
Bank account and/or credit card details for agreed payment purposes;
Any information that you provided to us by you during your account creation process or added to your user profile;
Preferences and password for using this site and your computer and connection information; and
Any information that you otherwise share with us.
How we may collect your personal information
At this site, we only collect personal information that is necessary for us to conduct our business as a facilitator of digital and physical payment.
Information that you provide to us
We may collect personal information that you provide to us about yourself when you:
Use this site, including (without limitation) when you:
Create a user account;
Add information to your user profile;
Select any services through this site;
Add reviews, forum or chat room messages or comments in any elements of this site that permit user-generated content;
Register for access to premium content or request certain premium features; or
Complete an online contact form to contact us;
Provide information to us by telephone or through marketing or competition application forms; or
Send us an email or other communication.
IP addresses
This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes. The Company may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.
Cookies
This site uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this site: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. The Company extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.
Why we use cookies
This site uses cookies in order to:
Remember your preferences for using this site;
Manage the signup process when you create an account with us;
Recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;
Facilitate e-commerce transactions, to ensure that your payment details are remembered between pages during the confirmation process;
Show relevant notifications to you (eg, notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and
Remember details of data that you choose to submit to us (eg, through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).
Third party cookies
In some cases, third parties may place cookies through this site. For example:
Remember your preferences for using this site;
Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies to collect de-identified data about how long users spend on this site and the pages that they visit;
Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
Third party social media applications (eg, Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this site.
Contacting us about privacy
If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us by email at [email protected] or by post.
How we may use your personal information
Your personal information may be used in order to:
Verify your identity. As we are in the business of facilitating payments and are subject to regulatory requirements, we cannot provide payment processing services to you on an anonymous basis;
Assist you to make payments through this site;
Make changes to your account;
Respond to any queries or feedback that you may have;
Conduct appropriate checks for credit-worthiness and for fraud;
Prevent and detect any misuse of, or fraudulent activities involving, this site;
Conduct research and development in respect of our services;
Deliver our services and comply with regulatory requirements, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
Gain an understanding of your information and communication needs or obtain your feedback or views about our services in order for us to improve them; and/or
Maintain and develop our business systems and infrastructure, including testing and upgrading of these systems,
and for any other purpose reasonably considered necessary or desirable by the Company in relation to the operation of our business. From time to time we may email our customers with news, information, and offers relating to our own services or those of selected partners. Your personal information may also be collected so that the Company can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease acquiring products and services from us. If you would prefer not to receive promotional or other material from us, please let us know and we will respect your request. You can unsubscribe from such communications at any time if you choose.
When we may disclose your personal information
In order to deliver the services you require or for the purposes set out above, the Company may disclose your personal information to organisations outside the Company. Your personal information may be disclosed to these organisations only in relation to this site, and the Company takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These organisations may carry out or provide:
Customer enquiries;
Mailing systems;
Information technology services;
Marketing, telemarketing, and sales services;
Market research; and
Website usage analysis.
In addition, we may disclose your personal information to:
Your authorised representatives or legal advisers (when requested by you to do so);
Credit-reporting and fraud-checking agencies;
Credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision, and financing);
Our professional advisers, including our accountants, auditors, and lawyers;
Government and regulatory authorities and other organisations, as required or authorised by law;
Organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
The police or other appropriate persons where your communication suggests possible illegal activity or harm to others.
Contacting us about privacy
If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us by email at [email protected] or by post.
Access to your personal information
In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.
In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:
Be unlawful (eg, where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
Have an unreasonable impact on another person’s privacy; or
Prejudice an investigation of unlawful activity.
We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.
If we refuse to give you access, we will provide you with reasons for our refusal.
Correcting your personal information
We will amend any personal information about you that is held by us and that is inaccurate, incomplete, or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness, or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.
Overseas transfer
Your personal information will not be disclosed to recipients outside of Australia unless you expressly request us to do so, and in that case, the overseas recipient will not be required to comply with Australian Privacy Principle and we will not be liable for any mishandling of your information in such circumstances.
We do not provide services to, target, or monitor the behaviour of individuals in the European Union. Accordingly, the European Union’s General Data Protection Regulation does not apply.
Storage and security of your personal information
We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. Firewalls, anti-virus software, and email filters, as well as passwords, protect all of our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.
Third party websites
You may click-through to third party websites from this site, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site only, and the Company assumes no responsibility for the content of any third-party websites.
Re-marketing
We may use the Google AdWords and/or Facebook re-marketing services to advertise on third-party websites to previous visitors to this site based upon their activity on this site. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of your personal Google and/or Facebook information is reported to us.
Changes to this Privacy Policy
From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We may notify you about changes to this Privacy Policy by posting an updated version on this site.
If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Federal Privacy Commissioner’s website (see OAIC ).
Last Updated: [15.03.2024]
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Ownership of Content
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Usage Restrictions
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Contact for Permissions
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Acknowledgment
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Thank you for visiting Embracy.com and for respecting our intellectual property rights.