Privacy Matters

Privacy Policy

Effective Date: 11th of July 2024

1. Introduction

This privacy notice explains how Now Squared™ collects and processes your personal data through your use of our site www.nowsquared.com. By providing us with your data, you confirm that you are over 13 years of age. Now Squared™ is the data controller responsible for your personal data (referred to as “we,” “us,” or “our” in this privacy notice).

Contact Details:
Full Name of Legal Entity: Now Squared Limited
Email Address: [email protected]
Phone Number: +852 2632 9750
Postal Address: Room 7B, One Capital Place, 18 Luard Road, Wan Chai, Hong Kong.

The information we hold about you must be accurate and up to date. Please let us know if your personal information changes at any time by emailing us at [email protected].

2. What Data We Collect, What Purpose, and What Ground We Process it

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:

• Communication Data: Includes any communication you send us, whether through our contact form, email, text, social media messaging, or social media posting. We process this data for communication with you, record-keeping, and for establishing, pursuing, or defending legal claims. Our lawful ground for this processing is our legitimate interests: reply to communications, keep records, and manage legal claims.
• Customer Data: Includes data relating to any purchases of goods and/or services, such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details, and card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us.
• User Data: Includes data about how you use our website and any online services, together with any data that you post for publication on our website or through other online services. We process this data to operate our website, ensure relevant content is provided to you, maintain backups, and enable publication and administration of our website. Our lawful ground for this processing is our legitimate interests, which are to administer our website and business.
• Technical Data: Includes data about your use of our website and online services, such as your IP address, login data, browser details, length of visits, page views, navigation paths, and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyse your use of our website, protect our business and website, deliver relevant content and advertisements, and understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which are to administer and grow our business.
• Marketing Data: Includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in promotions such as competitions, prize draws, and free giveaways, deliver relevant content and advertisements, and measure the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests, which are to study how customers use our products/services, develop them, and decide our marketing strategy.

We may use Customer Data, User Data, and Marketing Data to deliver relevant content and advertisements to you (including Facebook ads or other display advertisements) and to measure the effectiveness of the advertising. Our lawful ground for this processing is legitimate interests, namely to grow our business. We may also use this data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (to grow our business). We may need to collect the following Sensitive Data to process your applications:

• Religion
• Race
• Ethnicity

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for your consent.

If we need to collect personal data by law or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you do not provide us with the requested data, we may have to cancel a product or service you ordered, but we will notify you at that time.

We will only use your personal data for the purposes we collected it for or a reasonably compatible purpose if necessary. For more information, please email us at [email protected]. We may process your personal data without your knowledge or consent where required or permitted by law. We do not carry out automated decision-making or any type of automated profiling.

3. How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our Cookies Policy by clicking here for more details about this.

We may receive data from third parties such as analytics providers (e.g., Google), advertising networks (e.g., Facebook), and search information providers. We may also receive data from publicly available sources.

4. Marketing Communications

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if:

• You made a purchase or asked for information about our goods or services, or
• You agreed to receive marketing communications and have not opted out of receiving such communications since.

If you are a limited company, we may send you marketing emails without your consent, but you can opt-out at any time. Before sharing your personal data with any third party for their own marketing purposes, we will get your express consent.

You can stop receiving marketing messages from us at any time by following the opt-out links on any marketing message sent to you or by emailing us at [email protected]. If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases.

5. Disclosures of Your Personal Data

We may have to share your personal data with:

• Other companies in our group that provide services to us.
• Service providers who provide IT and system administration services.
• Professional advisers, including lawyers, bankers, auditors, and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer or merge parts of our business or our assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We may transfer your personal data to countries outside the European Economic Area (EEA). If we do, we ensure a similar degree of protection by implementing safeguards such as transferring data to countries approved by the European Commission or using specific contracts or mechanisms approved by the European Commission.

7. Data Security

We have security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. Access to your personal data is limited to employees and partners who have a business need to know. They will only process your personal data on our instructions and must keep it confidential. We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying legal, accounting, or reporting requirements. When deciding how long to keep the data, we consider its amount, nature, sensitivity, potential risk of harm from unauthorised use or disclosure, processing purposes, and legal requirements.

For tax purposes, we keep basic customer information (including Contact, Identity, Financial, and Transaction Data) for six years after they stop being customers. We may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under data protection laws, you have rights in relation to your personal data, including the right to request access, correction, erasure, restriction, transfer, object to processing, data portability, and (where the lawful ground of processing is consent) to withdraw consent. For more information about these rights, visit the Information Commissioner’s Office (ICO) GDPR Individual Rights. If you wish to exercise any of these rights, please email us at [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive, or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This security measure ensures that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask for further information about your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take longer if your request is complex or if you have made multiple requests. In this case, we will notify you. If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. However, we would appreciate the chance to resolve your concerns before you approach the Information Commissioner’s Office (ICO), so please contact us first.

10. Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.