TELOMERE FINANCIAL TECHNOLOGY CO., LIMITED (“TFT”, "we", "us”, or “our”) respects your privacy and will endeavor to comply with all relevant laws for the protection of data subject privacy. This Privacy Policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, disclose, and/or process the Personal Data you have provided to us when you use and access Cocodp (“cocodp.com”), as well as to assist you in making an informed decision before providing us with any of your Personal Data.
This Privacy Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us. We may from time to time update this Privacy Policy to ensure that it is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements, especially Personal Data (Privacy) Ordinance in Hong Kong, as amended from time to time. This Privacy Policy is to be read with the Terms of Service. Please read this Privacy Policy carefully, particularly the black and bold parts.
By using or accessing the Cocodp or through any other means, you acknowledge that you have read this Privacy Policy, understand it, agree to its terms, and authorize TFT and/or its subsidiaries or assigns to collect and use your Personal Data pursuant to this Privacy Policy. It is important for you to protect against unauthorized access to your computers and devices. Be sure to sign off properly when finished using a shared computer or device.
The Services provided on Cocodp are not directed to persons under the age of eighteen (18). As such, we do not knowingly collect Personal Data from such minors. We can only collect a minor’s Personal Data with the consent, permission, and supervision of their parent or guardian. If you are a parent or guardian supervising a minor, and you accept this Privacy Policy on their behalf so that they may use the Cocodp, you understand that you consent to the processing of the minor’s Personal Data in accordance with this Privacy Policy.
Changes to this Privacy Policy may be made by TFT by posting the revised Privacy Policy on Cocodp or any such page determined by TFT from time to time. In no event will these changes result in the degradation of any security measures designed to protect you from unauthorised disclosure. Your continued use of Cocodp or our services constitutes your acknowledgement and acceptance of such changes.
If you are not comfortable with any aspect of this Privacy Policy. You should immediately discontinue your access to Cocodp and relevant services provided by Cocodp.
1. Types of Personal Data
1.1 For the provision of our services, we may collect and process the following Personal Data about you, such as:
— Your name;
— Email address;
— IP address or Mac Address;
— Documentation that may help us to verify the accuracy of the information you have provided, such as proof of identity;
— Your social media links or public profiles, and any Personal Data that may be visible thereon, which you may provide to us in the course of customer support dealings;
— Any other Personal Data that you may provide to us in the course of using the Cocodp Services.
1.2 When you purchase some goods in the mall and need to increase your purchase limit, we will collect your ID, passport, credit card information, and biometric information. The above information is collected to ensure your transaction security and meet the platform's risk control security requirements. We promise not to reuse your information or collect your information in non-essential scenarios. If you cannot provide the above information, it may affect your ability to purchase some of the items in the mall that exceed your current limit.
1.3 You warrant and represent to us that all Personal Data submitted to us is complete, accurate, true, and not misleading. Failure on your part to do so may result in our inability to provide you with the products and/or services you have requested and/or to process the necessary administration. We reserve the right to request for documentation to verify the information that you provide to us.
1.4 Please refer to the Additional Provisions below for versions of this Privacy Policy, as well as additional matters that may apply to the jurisdiction where you reside.
1.5 We collect and process your Personal Data to enable you to make purchases from us, your mobile network operator, or the relevant third-party payment service provider (the “PSP”), or a merchant or publisher of digital products (the “Publishers”) via our server or database applications, or websites at Cocodp.
2. Collection of Personal Data
2.1 We collect your Personal Data when you use the Services or communicate with us, including:
— Registration of your personal account provided by us;
— Purchase the products provided by us;
— Requests of our support services.
In these instances, you may provide your Personal Data to us directly, or it may be shared with us by our affiliates or subsidiaries, the PSP, or the Publishers, pursuant to your consent given to these third parties.
2.2 We also collect transaction information, such as purchase amount, date of purchase, information about the digital content, goods and/or services that you are purchasing (“Transaction Data”), in order to pursue our legitimate interests and to abide by our contractual obligation to provide you access to the Services. In most cases, these are not considered as Personal Data since your identity will not be apparent from them. However, to the extent that your identity may be determined from the Transaction Data, they will be considered and processed as Personal Data under this Privacy Policy. You agree to our collection of such Transaction Data from you when you use the Services.
3. Use, Disclosure and Retention of Personal Data
3.1 We may collect and use the Personal Data for the purposes for which we have specifically obtained your consent, including:
— Providing, operating, and maintaining our Cocodp and/or related website to provide the products and services offered to you;
— Transaction processing such as processing and verifying your online transactions and payments on Cocodp, and find and prevent fraud. As a payment channel aggregator, online distributor of digital content, and provider of related services, we will use your Personal Data and share it with third parties, including our affiliates or subsidiaries, the PSP, and Publishers, for the purpose of providing you with the Services, or where it is a necessary part of doing business with you. Your Personal Data may also be shared for the above purposes between TFT and the Publisher from whom you are purchasing content and the PSP that you have selected as your method of payment.
— Communicating with you, if you opt in to receiving marketing and promotional communications, we may use your Personal Data to notify you about marketing and promotional activities relating to any of the Services, or those conducted jointly, in partnership, or in connection with any Publishers, PSP, or third parties, and we may share your name and/or email address with them for this purpose. If you would like to opt out of receiving marketing and promotional communications or having your Personal Data disclosed for this purpose, please contact us. You may also opt-out of any such marketing and promotional emails by clicking the unsubscribe button provided in that email.
— Responding to your queries and requests;
— Developing new products, services, features, and functionality;
— Complying with any applicable rules, laws, and regulations, codes of practice or guidelines or assisting in law enforcement and investigations by relevant authorities and agencies;
— Any other purposes permitted by you.
3.2 We will only use your Personal Data for the purposes for which we mentioned in this Privacy Policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we process your Personal Data for other purposes, we will notify you in advance and obtain your express consent again.
3.3 TFT will seek your prior consent for any disclosure of your Personal Data in relation to these purposes and for any other purpose that is not listed above, except in the following cases:
• we may disclose your Personal Data as required by laws and regulations, or according to the compulsory requirements of the competent government authorities;
• we may disclose your Personal Data to perform obligations in the course of or in connection with the provision of the services requested by you;
• we may share your Personal Data with third-party service providers that require access to your information to support our operations and delivery of the services provided by Cocodp.
3.4 If we do disclose or share your Personal Data, we will require aforementioned entities to respect the security of your Personal Data and to treat it in accordance with the applicable law. These entities are authorized to use your Personal Data only as necessary to provide services for specified purposes and in accordance with our instructions.
3.5 We may retain your Personal Data for as long as it is necessary to fulfil the purposes described herein and in pursuance with relevant laws and regulations. We will delete or anonymize your Personal Data if it is stored for a period that exceeds what is permitted by law. If it is technically difficult to delete the relevant Personal Data, we will stop processing it except for the purpose of storage and taking necessary security measures.
4. Cookies
Like any other website, TFT uses cookies. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise your experience by customizing our Cocodp and/or related website content based on visitors' browser type and/or other information.
5. Your Data Privacy Rights and Choices
5.1 We enable you to make numerous choices about your Personal Data: Below are the following data protection rights you have when using Cocodp. You may choose to use this privacy right and choices below for the protection of your Personal Data.
— Right to update or correct your Personal Data;
— Right to access your Personal Data;
— Right to delete your Personal Data;
— Right to restrict the processing of your Personal Data;
— Right to opt out from receiving marketing emails;
— Withdraw your consent given to us to collect, use, and/or disclose your Personal Data;
— Right to file a complaint in relation to the use of Cocodp.
5.2 The easiest way to submit your request to us is through our support email: support@cocodp.com found at the bottom of this Privacy Policy. We respond to all requests from individuals wishing to exercise their data protection rights under relevant data protection laws.
5.3 For your reasonable requests, we do not collect any charges in principle, but for repeated requests or unreasonable requests, we will inform you that we may collect reasonable fees before processing your request. We may reject requests that are unprovoked and repeated, which require too many technical means, pose a risk to the legitimate interests of others or are highly impractical.
6. Protection of Personal Data
6.1 We make reasonable efforts to safeguard your Personal Data, in order to protect against loss, misuse, modification, unauthorised or accidental access or disclosure, alteration, or destruction. Unfortunately, no data transmission or storage over the Internet can be guaranteed as totally secure. Nonetheless, we have adopted and currently practice administrative, organizational, technical, and physical security measures to protect your Personal Data to the best of our reasonable capacity, including but not limited to the following:
— Limiting Personal Data access to authorized and/or necessary personnel;
— Implementing technical solutions, such as Secure Sockets Layer for establishing an encrypted link to ensure information security;
— Continuous monitoring and review of Personal Data protection measures; and
— Other security measures, as may be required by the laws and regulations applicable in the country where you are located.
6.2 Nevertheless, we need to remind you that the Internet environment is not completely secure. We will use our best efforts to ensure or guarantee the security of your Personal Data. We will be liable for any damage to your legal rights and benefits resulting from unauthorized access, public disclosure, alteration or destruction of information due to any damage to our physical, technological or administrative protection facilities. For your own security, please do not send any confidential Personal Data to us outside of our Services. It is also important that you maintain the security and control of your own Personal Data.
7. International Transfer of Personal Data
TFT operates internationally. You therefore accept and understand that we may store your data in different countries depending on applicable data localisation regulations, or share your Personal Data with recipients (such as the Publishers, PSP, or our affiliates/subsidiaries) who are located in countries other than the country in which your Personal Data was originally collected, in order to provide the Services to you, process and complete the transactions you wish to make on Cocodp, or for any other purposes set out in this Policy.
8. Links to Third-Party Websites
We may contain links to other websites which are not maintained by us. When you visit such third-party websites, applications, products and service links, you shall separately assent to the Privacy Policy or the terms on the protection of individual information furnished by them. We and such third-party websites, applications, product and service providers shall assume independent responsibilities for the protection of Personal Data to you within the scope specified by law and agreed by the Parties. We are not responsible for the content, use, or privacy practices of these websites.
9. Governing Law and Jurisdiction
This Privacy Policy shall be governed by and construed according to the laws of Hong Kong, without regard to its conflicts-of-law provisions. Any dispute arising out of or in connection with the performance or interpretation of this Privacy Policy shall be settled through our friendly consultation with you. If no agreement can be reached through such consultation, the dispute shall be submitted to Hong Kong International Arbitration Centre (“HKIAC”) and the Tribunal shall consist of one (1) arbitrator. All arbitration proceedings shall be in the English language. The decision of the arbitrator shall be final and binding.
10. Contact Us
To send us your questions, comments, or complaints or receiving communications from us kindly email us using support@cocodp.com.
11. Additional Provisions
In addition to the foregoing provisions, the following additional provisions apply to users in the following countries. You may access a copy of the Policy, including the Additional Provisions as applicable to your country.
Philippines
If you are residing in or located in the Philippines, these additional provisions (the “Philippines Provisions”) shall govern the collection and processing of your Personal Data, in addition to the foregoing Privacy Policy.
1. We take steps to ensure that any Personal Data transferred in accordance with the Privacy Policy shall be provided a standard of protection that is comparable to the protection under Republic Act No. 10173 or the Data Privacy Act of 2012, its Implementing Rules and Regulations, as well as any relevant amendments or circulars, advisories, or other issuances from the National Privacy Commission.
2. This Privacy Policy and Philippines Provisions shall be governed by and construed according to the laws of the Republic of the Philippines, without regard to its conflicts-of-law provisions. Any dispute arising out of or in connection with the performance or interpretation of this Privacy Policy and Philippines Provisions shall be settled through our friendly consultation with you. If no agreement can be reached through such consultation, the dispute shall be submitted to the proper arbitration of Taguig City and the Tribunal shall consist of one (1) arbitrator. All arbitration proceedings shall be in the English language. The decision of the arbitrator shall be final and binding.
Malaysia
If you are residing in or located in Malaysia, these additional provisions (the “Malaysia Provisions”) shall govern the collection and processing of your Personal Data, in addition to the foregoing Privacy Policy.
1. We take steps to ensure that any Personal Data transferred in accordance with the Policy shall be provided a standard of protection that is comparable to the protection under Act 709 or the Personal Data Protection Act 2010, as well as its relevant amendments, guidelines, enforcement rules, etc.
2. This Privacy Policy and Malaysia Provisions shall be governed by and construed according to the laws of Malaysia, without regard to its conflicts-of-law provisions. Any dispute arising out of or in connection with the performance or interpretation of this Privacy Policy and Malaysia Provisions shall be settled through our friendly consultation with you. If no agreement can be reached through such consultation, the dispute shall be submitted to the Asian International Arbitration Centre (“AIAC”) under the Arbitration Rules of the AIAC for the time being in force, which rules are deemed to be incorporated by reference into this section. The seat of arbitration shall be Kuala Lumpur, and the Tribunal shall consist of one (1) arbitrator. All arbitration proceedings shall be in the English language. The decision of the arbitrator shall be final and binding.
Brazil
If you are residing in or located in Brazil, these additional provisions (the “Brazil Provisions”) shall govern the collection and processing of your Personal Data, in addition to the foregoing Privacy Policy.
1. We take steps to ensure that any Personal Data transferred in accordance with the Policy shall be provided a standard of protection that is comparable to the protection under the Lei Geral de Proteção de Dados Pessoais, as well as its relevant amendments and rules, regulations, guidelines, etc.
2. This Privacy Policy and Brazil Provisions shall be governed by and construed according to the laws of Brazil, without regard to its conflicts-of-law provisions. Any dispute arising out of or in connection with the performance or interpretation of this Privacy Policy and Brazil Provisions shall be settled through our friendly consultation with you. If no agreement can be reached through such consultation, the dispute shall be submitted to the courts of the City of São Paulo, State of São Paulo, to the exclusion of all courts in any other venue.
Thailand
If you are residing in or located in Thailand, these additional provisions (the “Thailand Provisions”) shall govern the collection and processing of your Personal Data, in addition to the foregoing Privacy Policy.
1. We take steps to ensure that any Personal Data transferred in accordance with the Privacy Policy shall be provided a standard of protection that is comparable to the protection under the Personal Data Protection Act B.E. 2562, as well as its relevant regulations, amendments, guidelines, enforcement rules, etc.
2. This Privacy Policy and Thailand Provisions shall be governed by and construed according to the laws of Thailand, without regard to its conflicts-of-law provisions. Any dispute arising out of or in connection with the performance or interpretation of this Privacy Policy and Thailand Provisions shall be settled through our friendly consultation with you. If no agreement can be reached through such consultation, the dispute shall be submitted to the courts of Thailand, to the exclusion of all courts in any other venue.
Indonesia
If you are residing in or located in Indonesia, these additional provisions (the “Indonesia Provisions”) shall govern the collection and processing of your Personal Data, in addition to the foregoing Privacy Policy.
1. We take steps to ensure that any Personal Data transferred in accordance with the Privacy Policy shall be provided a standard of protection that is comparable to the protection under the Law No. 27 of 2022 concerning Personal Data Protection, as well as its relevant regulations, amendments, guidelines, enforcement rules, etc.
2. This Privacy Policy and Indonesia Provisions shall be governed by and construed according to the laws of Indonesia, without regard to its conflicts-of-law provisions. Any dispute arising out of or in connection with the performance or interpretation of this Privacy Policy and Indonesia Provisions shall be settled through our friendly consultation with you. If no agreement can be reached through such consultation, the dispute shall be submitted to Badan Arbitrase Nasional Indonesia. The seat of arbitration shall be Jakarta, and the Tribunal shall consist of one (1) arbitrator. All arbitration proceedings shall be in the English language. The decision of the arbitrator shall be final and binding.