Policy Summary

This Privacy Policy is intended to clearly and transparently explain how Infuse Sports and Entertainment Limited (hereinafter referred to as "Infuse", "we", "us" or "our") collects, processes, stores, and protects users' personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region and other applicable laws. By using www.infuseactive.com (hereinafter referred to as "this Website") and its related services, you acknowledge that you understand and accept the practices described in this policy.

1. Data Collection Principles

1.1 Principle of Data Minimization

We only collect personal data that is necessary for providing services and fulfilling legal obligations. The scope of data collection is directly related to its intended purpose.

1.2 Purpose Limitation

All personal data is collected and used based on explicit business purposes, including but not limited to:

• Order processing and contract fulfillment
• Customer service and support
• Compliance and risk management
• Service optimization (based on legitimate interests)
• Marketing activities (based on explicit consent)

1.3 Transparency

We are committed to explaining data processing practices in a clear and understandable manner, ensuring that you are fully informed about how your data flows and is used.

1.4 Sources of Personal Data

We collect personal data directly from you when you interact with our services. We may also receive limited personal data about you from third-party sources (e.g., social media platforms, if you choose to link your account, or from payment processors for fraud prevention). We will always notify you and obtain your consent where required by law when we receive your data from a third party.

2. Personal Data Definition and Retention

For the purposes of this Policy, “personal data” has the meaning given in the Hong Kong Personal Data (Privacy) Ordinance, and refers to any data relating directly or indirectly to a living individual, from which it is practicable to ascertain the identity of the individual.

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, as described in this Policy. The specific retention periods for different data categories are determined by the purpose, legal requirements, and the nature of our relationship with you. Unless otherwise specified below, the standard retention period for personal data linked to a commercial transaction is 7 years from the completion of that transaction, in accordance with common tax and accounting practices in Hong Kong (Extended retention may occur only when strictly necessary for compliance with specific laws or for the establishment, exercise, or defence of legal claims).

If you wish to request that we no longer use your personal data to provide you services, you may contact us in accordance with Section 8.

However, we will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

3. Personal Data Classification and Legal Basis for Processing

3.1 Identity Data

• Categories: Name, contact address, email address, telephone number
• Legal Basis: Necessity for fulfilling purchase contracts

3.2 Transaction and Financial Data

• Categories: Order records, payment information, billing history
• Legal Basis: Contract fulfillment and legal obligations
• Security Measures: Processed through PCI DSS certified payment gateways

3.3 Technical and Behavioral Data

• Categories: IP address, device identifiers, browsing history, cookie data
• Legal Basis: Legitimate interests in website operation
• User Control: Cookie preferences can be managed through browser settings
• Any profiles, inferences, or analytics derived from the above data that relate to you are also treated as personal data and are governed by this Policy

3.4 Voluntarily Provided Data

• Categories: Product reviews, survey responses, marketing subscriptions
• Legal Basis: User's explicit consent
• Withdrawal Mechanism: Consent can be withdrawn at any time through designated channels

3.5 Use of Cookies and Similar Technologies

We use cookies, tags, and pixels ("Cookies") to improve your experience on our website. These small data files allow us to:

• Enhance Functionality: We remember your preferences and shopping basket items so you don’t have to start over.
• Boost Performance: We analyze how our platforms are used (usually via anonymous, aggregated data) to fix errors and streamline your experience.
• Deliver Relevant Ads: We work with partners to show you personalized offers based on your browsing behavior and purchase history.
• Measure Marketing: We track if ads or emails are effective and ensure you don’t see the same advert too many times.

If you choose to disable some or all Cookies, you may not be able to make full use of our platforms.

4. Data Subject Rights and Exercise Procedures

4.1 Statutory Rights Protection

In accordance with Hong Kong's Personal Data (Privacy) Ordinance, you have the following rights:

• Right of Access: To obtain a copy of your personal data held by us
• Right of Correction: To request correction of inaccurate or incomplete data
• Right to Object: To object to specific types of data processing
• Right to Erasure: To request deletion of data under specific conditions

4.2 Rights Exercise Process

1. Submit Request: Submit a written request via support@infuseactive.com

2. Identity Verification: Provide necessary identification information

3. Processing Timeline: We will provide a substantive response within 40 days

4. Fee Policy: Exercising the right of access may involve reasonable administrative fees

5. Personal Data Transfer and Sharing Framework

5.1 Third-Party Service Management

We apply strict standards when selecting third-party service providers:

• Category Assessment: Evaluate the sensitivity of processing activities
• Contractual Obligations: Sign data processing agreements containing confidentiality and security clauses
• Continuous Monitoring: Regularly review compliance status

5.2 Cross-Border Transfer Safeguards

For cross-border data transfers, we ensure:

• Legal Assessment: Evaluate the protection level in the destination jurisdiction
• Supplementary Measures: Implement technical or organizational measures such as Standard Contractual Clauses
• Transparency: Clearly disclose the destination of transfers

5.3 Legally Required Disclosures

Personal data will only be disclosed under the following circumstances:

• To comply with court orders or other legal processes
• To enforce website terms and conditions
• To protect the rights, property, or safety of us and others

6. Security Assurance System

6.1 Technical Protection

• Encrypted Transmission: All data transfers are encrypted
• Security Audits: Regular vulnerability scanning and penetration testing

6.2 Organizational Management

• Employee Training: Regular privacy and security training
• Incident Response: Established data breach emergency response plan

6.3 Compliance Certification

• Regular Assessment: Annual privacy impact assessments
• Continuous Improvement: Optimize control measures based on audit results 

7. Special Considerations

7.1 Minor Protection

This website and services are not directed at individuals under 16 years of age. If we discover that we have collected data from minors, we will delete it immediately.

7.2 Automated Decision-Making

We currently do not use fully automated decision-making systems. Any changes will be notified in advance and consent will be obtained. 

8. Contact and Appeals

8.1 Designated Responsible Person

Privacy Officer: Infuse Privacy Protection Officer

Email: support@infuseactive.com

8.2 Response Commitment

We commit to:

• Acknowledging receipt of inquiries within 14 business days
• Providing a substantive response within 40 business days
• Continuously improving processing procedures

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Interpretation Authority

The interpretation right of this Privacy Policy belongs to Infuse Sports and Entertainment Limited. In case of any discrepancy between the English and any other versions of this policy, the English version shall prevail.