Mellow App Limited

Privacy Policy

Effective: Apr 23 2019

This Privacy Policy sets out how we, Mellow App Limited (“Mellow”), use and protect your Personal Data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our website, mobile application and pre-paid card distributed by Mellow (“Pre-paid Card”) (collectively, the “Services”) in accordance to Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region (“Hong Kong”). For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to Mellow, and ‘you’ refers to you and your child, the user of our Services.

We may make changes to these Terms and Conditions at any time without informing you in writing. Any changes made to these Terms and Conditions would be uploaded on our website and Mellow App and they will be effective immediately. You are encouraged to check our website regularly for any changes to these Terms and Conditions.

 

Issuer of the Pre-paid Cards
 

ePaylinks Technology Co., Limited (“Global Cash”) is the issuer and processor of the Pre-paid Card associated with our Services. Accordingly, Global Cash will collect, use, process and retain certain aspects of your Personal Data as it relates to, and is required for the administration and operation of the Pre-paid Card. For further information, please refer to Global Cash privacy policy at http://www.globalcash.hk/foot_statement.html.

Our Privacy Policy regarding Children

This Privacy Policy applies to any person, child or adult requesting access to or using our Services.

If you are under the age of 18, your parent or guardian must accept this Privacy Policy on your behalf before you can use our Services and provide us with any of your Personal Data.

As a parent or guardian of a child who has signed up to use our Services, you are giving us informed consent to collect, use and share your child’s Personal Data in accordance with the terms of this privacy policy. We encourage you to regularly monitor and supervise your child’s use of our Services.

Collection of Personal Data

We collect two types of data from you, “Personal Data” and “Non-Personal Data”:

Personal Data means any personally identifying data, from which it is practicable for the identity of an individual to be directly or indirectly ascertained, which we may collect from you when you seek Services from us and include without limitation:

  • Contact and identification information such as your name and your child’s name, your phone number, email address, address, date of birth, identification document numbers, copies of identification documents (for example Hong Kong identification card, passport, utility bills), personal description, photographs and other similar contact information.

  • Financial information such as the last four digits and expiry date of your debit card number, your credit card number, bank account information, bank sort code, IBAN, payment reason, footprint of your credit history, and other similar financial information;

  • Transaction information such as date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, senders and receivers’ names and registration information, as well as other similar transaction information;

  • Demographic information such as your or your child’s age, gender, nationality, country and other similar demographic information;

  • Security information such as passwords, password hints, security questions and answers and other similar security information;

  • Device and technical information such as IP address, unique device identifiers (such as the IMEI number for phones, the MAC address of the device’s wireless network interface), device functionality (browser type and version, operating system and platform, hardware used, browser plug-in types and versions) and other similar device and technical information;

  • Usage information such as the full uniform resource locators (URLs), information about page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), error reports and performance data (ie: details of the software or hardware related to an error, content of files you were using when an error occurred), troubleshooting and help data plus other similar usage information;

  • Location information such as your device location which may include a street name and city or GPS- location, ISP or your mobile carrier, the URL of both the site you came from and the one you go to next and other similar location information. We use GPS technology and your IP address to determine your location - this may be used when the application is running in the foreground and the background of your device. This is used to prevent fraud, for instance, if your phone is saying that you are based in the Hong Kong but your Pre-paid Card is being used to enter into an ATM withdrawal or point of sale purchase in Japan, we may not allow that transaction to be processed. Please also know that most devices allow you to prevent location information from being sent to us;

  • Any other information you directly provide to us when filling out forms, corresponding with us (ie: email, conversations with us by phone or chat sessions), filling out surveys, providing us with feedback and product reviews and other similar information.

Non-Personal Data means aggregate and/or automatic information, which is data collected about the use of our Services (including without limitation our websites, mobile applications and/or the Pre-paid Cards), or about a group or category of users from which individual identities or other individually identifiable information has been removed. This Privacy Policy does not restrict or limit our collection, use, disclosure and provision of Non-Personal Data.

Use of Personal Data

We use the Personal Data collected from our Services for the following purposes:

  • Provide our Services. We use your Personal Data to deliver our Services, such as processing your account application, processing your payments, processing your child’s payments, provide analytics to you about your child’s spending records, financial activities, wishes (things they want to buy) and other data;

  • Maintain and improve our Services. We use your Personal Data to ensure our Services are working as intended and improve our Service offerings to you;

  • Develop new services. We use the information collected to develop new services;

  • Provide personalized Services, including content and ads. We use the information collected to personalize our Services for you including providing purchase recommendations, personalized content for you and your child;

  • Measure performance. We use Google Analytics and other analytics software to analyze and measure to understand how our services are being used. This software may record information such as how often you or your child uses the application, events that occur within the application, aggregated usage and performance data;

  • Communicate with you. We may directly contact you through the email address or phone number that you have provided. For instance, we will contact you if we have suspicions that the Pre-paid Card is not being used by your child, such as if the Pre-paid Card is used overseas or used in online casinos or gambling; and

  • Prevent fraud and complying with legal and regulatory requirements. We may use your Personal Data to analyze whether anyone is using our Services for improper or illegal purposes.

 

Direct marketing

Any use of your Personal Data by us for direct marketing or any directly related purposes would be in accordance with the Ordinance and this Privacy Policy. We will only use your Personal Data for direct marketing of our products and services and our business partners after we have obtained your consent and you have the right to withdraw such consent at any time.

 

Disclosure of Personal Data

We may disclose the Personal Data collected to other members of our group of companies and to our subsidiaries.

We may also disclose your Personal Data with third parties who assist us with our operations and internal functions, such as personnel, agents, advisers, auditors, contractors, financial institutions, risk and security system providers and other service providers in connection with our Services. We may also disclose your Personal Data to the Pre-paid Card processor, Global Cash, to provide you with the Pre-paid Card services and meet their legal obligations such as Anti-Money Laundering and Counter-Terrorist Financing Ordinance. Your Personal Data is only accessible by our own personnel or the personnel of the third parties listed above for the purposes specified above. Our own personnel and the personnel of the third parties will be instructed to observe confidentiality and the terms of this Privacy Policy when accessing your Personal Data.

 

Transfer of Personal Data outside Hong Kong

We may transfer your Personal Data to places outside the Hong Kong for carrying out the purposes, or the directly related purposes specified above, for which the Personal Data was collected, or for storage or processing in relation thereto. All the transfer of such Personal Data will be carried out in compliance with the requirements of the Ordinance and our Privacy Policy. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take reasonable and practicable steps to ensure that your Personal Data is treated securely and in accordance with the Ordinance and our Privacy Policy.

 

Retention of Personal Data

We will not retain your Personal Data for longer than is necessary for the fulfillment of the above purposes and to comply with all applicable laws and regulations.

 

Third-party web services

We may use third-party web services such as Google Analytics on our website and mobile application. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyze how visitors use our website and mobile application and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualize and personalize the marketing materials of their own advertising network.

 

Protection and storage of Personal Data

We have implemented reasonable and practical security measures designed to protect against loss, misuse and/or alteration of your Personal Data under its control.

 

Accuracy of Personal Data

We shall take reasonable steps to keep your Personal Data as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Personal Data that is used on an ongoing basis, including information that is disclosed to third parties, will generally be kept accurate and up-to-date. Where you inform us of Personal Data which is inaccurate, incomplete, misleading or not up-to-date, we will update it in compliance with the Ordinance and our Privacy Policy, subject to our statutory rights and obligations.

 

Changes to our Privacy Policy

We may amend this Privacy Policy from time to time by posting the updated policy on our website and mobile application. By continuing to use our website and our mobile application after the changes come into effect means that you agree to be bound by the revised policy.

 

Access to information and contact

 

Under and in accordance with the Ordinance and our Privacy Policy, you have the right to seek access to and correction of your Personal Data held by us. In addition, you may request us to delete your Personal Data that is no longer required for the relevant purposes which you have given consent. Such rights may be exercised by you at any time. We reserve the right to charge you a reasonable fee for complying with a data access request as permitted by the Ordinance.

If you wish to exercise such rights, or if you have any question regarding your Personal Data or this Privacy Policy, please contact:

Teresa Chan

Co-Founder of Mellow

Room 28, Level 5, Core F, Cyberport 3, Hong Kong

info@mellowapp.io