Effective date: February 26, 2019

Digitalist Limited, a company organized and existing under the laws of Hong Kong, having its registered offices at Room B, 9/F Billion Plaza II, 10 Cheung Yue Street, Lai Chi Kok, Kowloon, Hong Kong. and registered under company number 2001963 (“us”, “we”, or “our”) operates the website available at (hereinafter referred to as the “Website”).

This Privacy Policy informs you of our policies regarding the collection, use and transfer of Personal Data (as defined below) when you use our Website.

We process your Personal Data in particular to operate, maintain and improve the Website, provide customer support and publish your posts. By using the Website, you acknowledge that we may collect and use your Personal Data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Categories of Data Collected

Personal Data

While using our Website, we may ask you to provide us with certain personal information relating to you (“Personal Data”), that can be used to contact or identify you. Personal Data that we process are:

  • Your email address
  • Your first and last name
  • Communications exchanged with us
  • Your posts on the Website pages
  • Usage Data (as defined below)

Usage Data

We may collect information on how the Website is accessed and used (“Usage Data”). Usage Data include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, other diagnostic data.


We don’t use cookies or any similar tracking technologies such as Web beacons (“Cookies”) to track the activity on our Website.

Use of Data

We use the collected Personal Data for various purposes:

  • To operate and maintain our Website
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Website
  • To monitor and improve the usage of our Website
  • To detect, prevent and address technical issues

Legal Basis for Processing Personal Data

We process your Personal Data because the processing is necessary for the purposes of legitimate interests we pursue as long as they are not overridden by your rights. Such legitimate interests are (i) the ability to answer your request(s) and (ii) the operation, maintenance and improvement of our Website.

Retention of Data

We will retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy, for a maximum period of one year. We may however retain and use your Personal Data for a longer period exclusively to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes, for a maximum period of one year (except when this data is used to strengthen the security or to improve the functionality of our Website, or when we are legally obligated to retain this data for longer periods).

Transfer and disclosure of Personal Data

Service Providers

We may employ third party companies and individuals to operate and maintain our Website (“Service Providers”), perform Website-related services or assist us in analyzing how our Website is used.

These Service Providers may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Personal Data may be transferred to — and maintained on — Services Providers’ computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Hong Kong and choose to provide information to us, please note that we transfer Personal Data to Services Providers in Hong Kong.

We will take all the steps reasonably necessary to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy and that no transfer of your Personal Data will take place to an organization or a country unless there are appropriate contractual measures taken to ensure the security of your Personal Data in compliance with the applicable privacy and personal data protection legislation. A copy of those appropriate contractual measures can be provided upon request.

Legal Requirements

We may disclose your Personal Data in the good faith belief that such action is necessary:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Digitalist Limited
  • To prevent or investigate possible wrongdoing in connection with the Website
  • To protect the personal safety of users of the Website or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights

You have certain data protection rights. We aim to take all steps to allow you to exercise those rights.

If you wish to be informed about what Personal Data we process about you and/or to update them, please contact us by following the procedure described below.

In certain circumstances, you also have the following data protection rights:

  • The right to delete the Personal Data we process about you.
  • The right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object to the processing of your Personal Data.
  • The right to request that we restrict the processing of your personal information.
  • The right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format (right to data portability).
  • The right to withdraw your consent at any time, in case we relied on your consent to process your Personal Data.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

To exercise your rights, please contact us through the contact form available at, together with the necessary elements allowing us to confirm your identity.

Data Protection Officer contact:

Privacy Core Services Limited, Level 2, Lara Building, Triq Guseppi, Calleja, Iklin, IKL1262, Malta.


Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Website does not address anyone under the age of 18 (“Child”).

We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers (except where processing is lawful under applicable privacy and data protection legislation).

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any change to our Privacy Policy via email and/or a prominent notice on our Website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us through the contact form available at