Privacy and Cookies Policy

1. Introduction

Statistical Inference Limited (hereinafter referred to as "we", "us", or "our") welcomes you (hereinafter referred to as "you" or the "User") to the website where this document is published (hereinafter referred to as the "Website"). This Privacy and Cookies Policy (hereinafter referred to as the "Policy") describes the types of information we gather from people visiting and/or submitting information through the Website. Any capitalized terms used in this Policy have the meaning defined in our Terms of Use. By accessing the Website, you agree to adhere to this Policy. If you do not agree to the terms of this Policy, please do not use the Website. Each time you use the Website, the current version of this Policy will apply.

2. General Principles

We may collect two types of information from Users: "Personal Data" and "Aggregate Information" (as defined below).

3. Personal Data

3.1 Processing Personal Data in a secure, fair, and transparent way is extremely important to us.

3.2 We process Personal Data in accordance with applicable privacy laws and best industry standards. In addition to terms defined in the Terms of Use, this Policy uses the following definitions:

"Controller" is a party that determines the purposes and means of the processing of Personal Data; we are the Controller with respect to your Personal Data.

"Data Subjects" refers to those individuals who are our Users.

"Incident" means: (a) a complaint or request with respect to the exercise of an individual's rights under applicable privacy laws; (b) an investigation into or seizure of the Personal Data by government officials, or a specific indication that such an investigation or seizure is imminent; or (c) any breach of security and/or confidentiality as set out in this Policy leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, the Personal Data, or any indication of such breach having taken place or being about to take place.

"Personal Data" is any data relating directly or indirectly to an identifiable Data Subject. Personal Data does not include any data that is anonymised, aggregated, de-identified and/or compiled on a generic basis and which does not name or identify a specific individual, directly or indirectly.

"Processing" is collecting, recording, using, storing, amending, adapting, disclosing, transferring or transmitting, structuring, combining, deleting or destroying Personal Data.

"Processor" is the party that processes Personal Data on behalf of the Controller.

3.3 We collect Personal Data that is voluntarily provided when a User submits an enquiry or contact form on the Website.

3.4 This information is used to respond to your enquiry, to send you relevant information about our services, and for marketing communications where you have given consent or where it is otherwise permitted.

3.5 We also automatically collect and store limited information about your use of the Website, including pages visited, so that we can better understand how users interact with the Website.

3.6 We will process your Personal Data only to the extent strictly necessary for the purpose of responding to your enquiry and/or providing information in accordance with these Terms of Use and this Policy. We shall:

3.6.1 implement and maintain a reasonable and appropriate security programme comprising adequate security, technical and organisational measures to protect against unauthorised, unlawful or accidental Processing, use, erasure, loss or destruction of, or damage to, your Personal Data;

3.6.2 ensure that only our personnel, contractors or third-party providers who "need-to-know" will be given access to your Personal Data to the extent necessary to perform our obligations;

3.6.3 provide adequate training to our staff and ensure that they comply with the obligations in this Policy; and

3.6.4 upon your request, delete, destroy or anonymise your Personal Data that we have in our possession in accordance with our backup and retention policy, unless applicable privacy laws require otherwise.

4. How We Use Your Personal Data

4.1 We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

4.1.1 If you are a prospective customer or enquirer, we will process your Personal Data to take pre-contractual steps at your request or to respond to your enquiry;

4.1.2 Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or

4.1.3 Where we need to comply with a legal obligation.

4.2 When we process your Personal Data, we are required to have a lawful basis for doing so. There are various lawful bases on which we may rely, depending on what Personal Data we process and why:

Consent: where you have given us clear consent for us to process your Personal Data for a specific purpose.

Contract: where our use of your Personal Data is necessary for a contract we are about to enter into or have entered into with you, or because you have asked us to take specific steps before entering into a contract.

Legal obligation: where our use of your Personal Data is necessary for us to comply with the law (not including contractual obligations).

Legitimate interests: where our use of your Personal Data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your Personal Data which overrides those legitimate interests).

5. Who We Share Your Personal Data With

5.1 We may share your Personal Data with third-party contractors where necessary to respond to your enquiry or to provide you with information you have requested.

5.2 We will also share Personal Data with law enforcement or other authorities if required by applicable law.

5.3 We do not sell, rent or otherwise trade your Personal Data to third parties for their own marketing purposes.

6. Transfer of Personal Data Outside Your Jurisdiction

6.1 We are a company incorporated in Hong Kong. Due to the global nature of our operations, we may collect, access, store, process and transfer your Personal Data in Hong Kong and in any other jurisdiction in which we, our affiliates, service providers or business partners operate, provided that such collection, storage, processing or transfer is not prohibited by applicable law.

6.2 By providing your Personal Data to us, you acknowledge and agree that your Personal Data may be transferred to, stored in, or otherwise processed in jurisdictions outside your country or region of residence, which may have data protection laws that differ from those in your jurisdiction. Where required by applicable law, we will implement appropriate safeguards to ensure that such transfers comply with legal requirements and that your Personal Data remains protected in accordance with applicable data protection standards.

6.3 We will take reasonable technical and organisational measures to safeguard your Personal Data during international transfers and to ensure that any third parties receiving such data are subject to appropriate confidentiality and data protection obligations consistent with applicable law.

7. Marketing

7.1 We would like to send you information about our services and any special offers which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

7.2 We will ask whether you would like us to send you marketing messages when you submit your contact details through the Website.

7.3 If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

7.3.1 contacting us using the details provided at the end of this Policy; or

7.3.2 using the "unsubscribe" link in emails.

8. User Obligations

In supplying Personal Data to us, you warrant that you have all necessary rights to provide such Personal Data for Processing in connection with the use of the Website. To the extent required by applicable law, you are responsible for ensuring that any consents necessary to this processing are obtained and that a record of such consents is maintained.

9. Aggregate Information

9.1 We may also collect aggregate information. Aggregate information is information about your activities on the Website that cannot be used to identify, locate or contact you (such as frequency of visits, pages most frequently accessed, browser type, etc.). Aggregate information is collected as you visit the Website even if you do not submit any information.

9.2 We may use aggregate information to improve the Website, monitor traffic and general usage patterns, and for our other legitimate business interests. We may disclose aggregate information to third parties for a variety of business reasons, including to potential investors. Aggregate information will not include any Personal Data.

10. Security of Personal Data

10.1 We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorised access to systems where we store Personal Data.

10.2 We restrict access to collected information to our employees, service providers and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

11. Integrity of Your Data

We process your Personal Data only for the purposes for which it was collected and in accordance with this Policy. We review our data collection, storage and processing practices to ensure that we only collect, store and process the Personal Data needed. We take reasonable steps to ensure that the Personal Data we process is accurate, complete and current, but we depend on our Users to update or correct their Personal Data whenever necessary.

12. Children and Special Categories of Personal Data

12.1 The Website is not directed to children and we will not request personally identifiable information from anyone we know to be under the age of 18, unless we have obtained verifiable parental consent from a parent or legal guardian. If we become aware that a user under the age of 18 has provided Personal Data without such consent, we will immediately remove that Personal Data from our files.

12.2 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

13. Business Transfers

In the event that we sell substantially all of our assets, or one of our business units is acquired, Personal Data of Users will likely be one of the transferred assets.

14. Your Rights

14.1 You have a number of important rights free of charge. In summary, those include rights to:

14.1.1 fair processing of information and transparency over how we use your Personal Data;

14.1.2 access to your Personal Data and to certain other supplementary information that this Policy is already designed to address;

14.1.3 require us to correct any mistakes in your Personal Data which we hold;

14.1.4 require the erasure of Personal Data concerning you in certain situations;

14.1.5 receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit those data to a third party in certain situations;

14.1.6 object at any time to processing of Personal Data concerning you for direct marketing;

14.1.7 object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;

14.1.8 object in certain other situations to our continued processing of your Personal Data; and

14.1.9 otherwise restrict our processing of your Personal Data in certain circumstances.

14.2 If you would like to exercise any of those rights, please email or write to us using the details provided on the Website.

14.3 We will require information from you to allow us to identify you. We will endeavour to respond to all requests within 30 days of receipt.

15. Cookies

15.1 When you access the Website, we may collect information regarding your IP address for the purposes of administering the Website and tracking usage. However, your IP address may vary each time you visit or it may remain the same depending on the type of Internet connection you are using or the location from which you access the Website.

15.2 We may also collect information about the websites that directed you to the Website after you clicked a link or ad from another website, or the day and time you visited the Website and how long you spent on it. We aggregate such information to help us compile reports on trends and user behaviour. Such information is anonymous and cannot be tied directly to you.

15.3 We may also use "cookies" to enhance your experience on the Website. A cookie is a small data file placed on your computer's hard drive that contains information that allows us to track your activity on the Website. The cookie itself does not contain any Personal Data; however, if you provide us with any personal information the cookie may act as an identifier to tie your personal information to your IP address or computer. You may choose to delete cookies from your computer's hard drive at any time or to disable cookies on your computer. If you delete cookies that relate to the Website, we may not be able to identify you upon your return. If you disable cookies, you may not be able to access certain features of the Website that require cookies to be enabled.

15.4 The Website's cookies cannot be used to read data from your hard drive and cannot retrieve information from any other cookies created by other websites. Our cookies cannot be used as a virus, Trojan horse, worm, or any other malicious tool. Our cookies are used to help us better understand how you and other users use the Website so we can continue to provide a better, more personalised user experience.

15.5 We also share website usage information about the Website with those interested in running targeted promotional campaigns on the Website. For this purpose, we and our advertisers may track some of the pages that you visit on the Website through the use of pixel tags (also called clear gifs).

15.6 We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

15.7 You can withdraw any consent to the use of cookies or manage any other cookie preferences by using our privacy dashboard on the Website.

16. How to Contact Us

If you have any questions regarding this Privacy Policy or the Personal Data we hold about you, please contact us through the contacts provided on the Website.