Welcome to PETBLE application (the “App“). This App provides you a simple way to monitor the health of your pets by collecting health data from different PETBLE devices. The App is published by SGI Venture Limited (“SGI” or “We” or “Us“), a company registered in Hong Kong Special Administrative Region of The People’s Republic of China. Our Privacy Policy explains how we and some of the companies we work with collect, use, share and protect information in relation to our mobile services, web site, and any software provided on or in connection with PETBLE services (collectively, the "Service"), and your choices about the collection and use of your information. We will handle all user information concerned with the Service in accordance with the Personal Data (Privacy) Ordinance (Chapter 486) of the Laws of the Hong Kong Special Administrative Region of The People's Republic of China. The Ordinance provides data subjects with rights to ascertain whether SGI holds personal data relating to them, to obtain a copy of that data, and to correct any data that is inaccurate. Our Privacy Policy applies to all visitors, users, and others who access the Service ("Users"). By using our Service you understand and agree that we are providing a platform for you to post content, including photos, comments and other materials ("User Content"), to the Service and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Use (which can be found at http://petble.com/terms-of-use).

Information Acquisition

We collect the following types of information.

User Information
When creating a new account, e-mail address or Facebook login credential will be used for the following purposes:

To confirm the identity of the user and prevent any unauthorized use of the Service.

For Facebook login, user’s name, email and profile picture will be collected to auto-complete some of the required App profile creation processes.

Other User Information
Users may be asked to register additional details such as his/her pet’s information (Pet names, species, breed, age, profile photos, messages etc.). Furthermore, other Users within the service can view profile and other information (in the form of text, videos, photos etc.) which the users themselves have registered or posted with the aim of sharing with other users.

Use of the Service

Cookies
To provide the best possible service to users, as well as for maintenance and security purposes, Cookies will be used to store user settings, to record access figures as well as monitoring usage patterns and statistics.

Logs
Upon access to the Service, the user’s IP address, browser type, and browser language etc., will be automatically obtained and stored. Such information will be used to analyze user environments, thereby enabling SGI to provide a better Service, as well as to prevent any unauthorized/fraudulent practices which interfere with normal Service operations.

Location Information
Some of the Service may use location information transmitted from users' mobile phones/devices. SGI only uses such information within the scope that is necessary in order to provide the designated service.

Device Information
The user’s device information (OS type) may be acquired at times. This information shall be used for the provision of a better service, as well as for identification purposes and prevention of any unauthorized/fraudulent practices which interfere with normal Service operations.

Purposes for which personal data are collected and used

SGI may use the data collected and provided by you for one or more of the following purposes.

To prevent any unauthorized/fraudulent use of the Service;
To offer an undisturbed Service to Users;
To aggregate statistical data regarding the Service;
To conduct research and analysis aimed at reviewing and improving the Service;
To comply with our legal obligations and for safety and security purposes;
To enable SGI to deal effectively with user inquiries.

Provision of Information

SGI will never provide user information to any third parties without the user’s consent, unless SGI is obliged and/or permitted to do so under applicable laws.

Disclosure of personal data

All personal data held by SGI will be kept confidential but SGI may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties.

Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with SGI;
Any person or company who is acting for or on behalf of SGI, or jointly with SGI, in respect of the purpose or a directly related purpose for which the data was provided;
Any other person or company who is under a duty of confidentiality to SGI and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
SGI’s dealers, agents, contractors, suppliers and other telecommunication, information service providers and content providers; its professional advisers, including its accountants, auditors and lawyers;
Government and regulatory authorities and law enforcement agencies and other organizations, as required or authorized by law; and
Any financial institutions, charge or credit card issuing companies, credit information or reference bureaux, or collection agencies, necessary to establish and support the payment of any services being requested.

Personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right/authority to access such information. In addition, personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned personal data are exempt from the provisions of Data Protection Principle 3 of the Ordinance.

Data Security

The data you provide to us will be stored at SGI office or our servers accessible only to our authorized employees. However, we give no warranty against third parties hacking into the data or any unauthorized access to the data by anyone.

SGI will take reasonable steps to ensure that all information we collect, use or disclose is accurate, complete and up-to-date and stored in a secure environment accessed only by authorized persons.

User Rights

Users may, through the procedures determined by SGI, send SGI a request for the disclosure of personal information which the users cannot confirm/access via the Service. SGI, in turn shall disclose such information except under the following conditions.

When the disclosure is likely to harm the life, body, property or other rights or interests of the user or any other third party
When the disclosure is likely to severely interfere with SGI's proper operation
When disclosure itself would constitute a violation of laws and/or regulations
When SGI is unable to verify the user’s ownership of the personal information requested for disclosure.

After the disclosure, users may, through the procedures determined by SGI, send SGI a request to correct, add or delete the user’s personal information, if the users find personal information registered with SGI to be incorrect. Under such circumstances, SGI shall swiftly investigate the request to achieve the desired user intention and correct, add or delete the personal information on the basis of SGI's findings.

Withdrawal from Our Services

Upon withdrawing from our Services, when a user account is deleted, all user information will be disposed of in the correct manner in accordance with the law and SGI’s regulations.

Modifications to this Privacy Policy

This Privacy Policy may be revised periodically. Users will be notified of important changes in a recognizable manner.

Inquiries

If users have any uncertainty about this Privacy Policy or questions, complaints, or comments on the handling of personal information related to the Service, You can contact SGI via telephone: +852 2953-1513 or email: enquiry@sgi-venture.com

European Appendix

This Appendix applies if you are based in the European Economic Area (the EEA) during your interactions with us (other than where you are in the EEA solely for travel purposes).

1. Processing of special categories of Personal Data

1.1 We will collect and handle sensitive Personal Data1.

1.2 We will typically ask you for your consent when collecting and handling this type of Personal Data, unless we are otherwise permitted to process such Personal Data under European data protection law (EU DP Law) or the laws of the EU member state in which you are based.

2. Why we collect your data, and who we disclose it to

2.1 The legal basis or “grounds” for our use of your Personal Data are set out below, as required under EU DP Law. In the table below, we have linked each purpose mentioned in section 3 of our Privacy Policy to the relevant legal ground/s:

EU use bases table

Purposes of the data processing	Use bases (The specified ground may vary depending on the specific processing activity and particular personal data being processed)
To prevent any unauthorized/fraudulent use of the Service	- contract performance - legal obligation - legitimate interests (to allow us to correspond with you in connection with our services)
To offer an undisturbed Service to Users	- contract performance - legitimate interests (to allow us to perform our obligations and provide services to you) For sensitive Personal Data - consent
To aggregate statistical data regarding the Service	- consent (which can be withdrawn at any time)
To conduct research and analysis aimed at reviewing and improving the Service	- legitimate interests (to allow us to maintain and improve the quality of our services and products)
To comply with our legal obligations and for safety and security purposes	- legal obligation - legal claims - legitimate interests (to cooperate with law enforcement and regulatory authorities) For sensitive Personal Data - legal claims - vital interests - substantial public interest - public interest in area of public health
To enable SGI to deal effectively with user inquiries	- contract performance - legal obligation - legitimate interests (to allow us to correspond with you in connection with our services)

3. Legal grounds for use of Personal Data

3.1 The legal grounds for our use of Personal Data are as follows:

(a) Consent: where you have consented to our use of your Personal Data. You may withdraw your consent to the use of your Personal Data by contacting us as set out in section 10 of the Privacy Policy.

(b) Contract performance: where we are required to collect and handle your Personal Data in order to provide you with the services that we have contractually agreed to provide to you.

(d) Vital interests: where we need to process your Personal Data in order to protect the vital interests of you or another natural person or pet, e.g. where you require urgent assistance.

(e) Public interest: where we need to process your Personal Data in order to carry out a task that is in the public interest.

(f) Legitimate interests: where we have a legitimate interest in using your information. We will only rely on this legal ground if we consider that our interest in using your Personal Data for the relevant purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your Personal Data.

The legal grounds for our use of the sensitive categories of Personal Data are:

(g) Consent: where you have explicitly consented to our use of your Personal Data. You may withdraw your consent to the use of your Personal Data by contacting us as set out in section 10 of the Privacy Policy.

(h) Vital interest: where we need to process your Personal Data in order to protect the vital interests of you or another natural person where you or the other person is physically or legally incapable of giving consent.

(i) Legal claims: where your Personal Data is necessary for us to establish, exercise of defend any legal claims.

(j) Substantial public interest: where we need to process your Personal Data for reasons of substantial public interest set out in EU law or the laws of the member state in which you are based.

(k) Public interest in area of public health: where we need to process your Personal Data for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, set out in EU law or the laws of the member state in which you are based.

4. Profiling

4.1 In connection with our marketing activities, we analyse some of the information that we collect about our Users and the pets (together with information about Users and the pets that we collect from our loyalty and other partners) to determine what offers are most likely to be of interest to different categories of Users in different circumstances and at different times. We call this the creation of “segments”. To do this, we combine Personal Data that we have collected from Users directly together with Personal Data that we have collected from our affiliates and other partners, if any. From time to time, we will assess the Personal Data that we hold about you in order to assign you to a particular segment. We will use the segment that you have been assigned to in order to tailor our marketing communications to include offers and content that are relevant to you or your pets.

4.2 You have the right to opt out of our direct marketing, and the underlying analysis of your Personal Data that we use to tailor the direct marketing that we send to you, at any time. You can exercise this right, by contacting us in accordance with section 10 of the Privacy Policy.

5. Our decision-making processes

5.1 In connection with our business, we will use your Personal Data to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to ensure security of our systems, or to detect fraud. Some of these decisions may be taken on an automated basis including, by matching your Personal Data against information in certain risk models that we have created based on the behaviour of other individuals and using your Personal Data to further enhance such models.

6. Export outside the EEA

6.1 Your Personal Data may be accessed by staff or suppliers, transferred, and/or stored outside the EEA, including to countries which may have a lower level of data protection than under EU DP law.

6.2 We must comply with specific rules when we transfer Personal Data from inside the EEA to outside the EEA. When we do this, we will use appropriate safeguards to protect any Personal Data being transferred.

6.3 We will transfer your Personal Data subject to European Commission approved contractual terms that impose different data protection obligations directly on the recipient, or as otherwise permitted under EU DP Law.

6.4 Please contact us as set out in section 10 of the Privacy Policy if you would like to see a copy of the specific safeguards we apply to the export of your Personal Data.

7. Retention period

Our retention periods for Personal Data are based on business needs and legal requirements. We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose. For example, we may retain: (i) certain details and correspondence until the time limit for claims arising from the transaction with us has expired (which is typically between 6 to 10 years after the relevant transaction occurred, and in some cases much less than this); or (ii) certain data to comply with regulatory requirements regarding the retention of such data. Where Personal Data is no longer needed, we either irreversibly anonymise the data (in which case we may further retain and use the anonymised data) or securely destroy the data.

8. Your rights

8.1 In addition to the section 7 of the Privacy Policy, in certain circumstances, you may have the rights under EU DP Law to ask us to:

(a) provide you with further details on how we use and process your Personal Data;

(b) delete Personal Data we no longer have grounds to process; and

Please note that we will not charge a fee when we deal with your requests in the exercise of the above rights.

8.2 In addition, under certain conditions, you have the right to:

(a) where processing is based on consent, withdraw the consent; and

(b) object to any processing of Personal Data that we process on the "legitimate interests" or "public interests" grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms.

8.3 You may exercise these rights by contacting us at the contact details in section 10 of the Privacy Policy. Please note that we will not charge a fee when we deal with your requests in the exercise of these rights.

8.4 These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). We will aim to respond to requests within 30 days.

8.5 If we are unable to resolve an inquiry or a complaint, you have the right to contact the data protection regulator in the country in which you are based.

NOTE 1 : Under European data protection law (EU DP Law), certain categories of Personal Data are considered particularly sensitive and therefore as needing additional protection. These categories include information about health, racial or ethnic origin, political opinions, religious beliefs, trade union membership or your sexual orientation and genetic and biometric data. Information concerning criminal convictions and offences is also viewed as sensitive under EU DP Law.