Pair Up Privacy Policy
Mars Concepts Limited ("we", "us", "our" or the “Company”) builds our business on trust between members and ourselves. To preserve the confidentiality of all personal data you provide to us for using Pair Up, we maintain the following privacy principles:
1. We only collect personal data that we believe to be relevant and required to understand your needs and to conduct our business and to enhance the functionality of Pair Up.
2. We use your personal data to provide you with better services.
3. We may pass your personal data to other members of the Company, advisers, service provider(s) and/or our respective agents, as permitted by the laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).
4. Subject to 3 above, we will not disclose your personal data to any external organisation unless we (i) have your consent or (ii) are required by law or (iii) have previously informed you.
5. We may be required from time to time to disclose your personal data to governmental, judicial bodies, agencies or regulators, but we will only do so under proper authority.
6. We aim to keep your personal data on our records accurate and up-to-date.
7. We maintain strict security systems designed to prevent unauthorised access to your personal data by anyone, including our staff.
8. All our staff and all third parties with permitted access to your personal data are/will be specifically required to observe our confidentiality obligations.
By maintaining our commitment to these principles, we will ensure that we respect the inherent trust that you place in us.
Privacy Matters
This section provides specific details of how we treat any personal data you provide us when you visit Pair Up.
Data Security
1. Security is our top priority. We will strive at all times to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure. We maintain this commitment to data security by working with our third party server provider to implement appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
2. The secure area of Pair Up supports the use of 128-bit Transport Layer Security (TLS) encryption technology, an industry standard for encryption over the internet to protect data. When you provide sensitive information, it will be automatically converted into codes before being securely dispatched over the internet.
3. Pair Up is protected behind "firewalls" and our systems are monitored to prevent any unauthorised access. We will not send personal data to you by ordinary email or any text message. As the security of ordinary email cannot be guaranteed, you should only contact us by filling in the form on the “Contact Us” page of Pair Up, or email us to cs@2pairup.com.
4. Since your profile and personal information will be publicly viewable on Pair Up (as stipulated in the Terms of Use of Pair Up), you acknowledge and deemed to have expressly provide your consent Pair Up to provide your personal information as provided in your profile to other users of Pair Up for the purposes of matching with other members.
5. We will take all practical steps to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of personal data.
Security Assurance
1. Both you and us play an important role in safeguarding against online fraud.
2. We endeavour to put in place high standards of security to protect your interests.
3. You should be careful that your account details (including your username and password) are not compromised. You should ensure that you do not knowingly or accidentally share, provide or facilitate unauthorised use of such details. Do not share your username or password or allow access or use of your username or password by others.
4. You should safeguard your username and password and keep them secret and confidential. Never write them down. We will never ask you for your password given that you should be the only person who knows it.
5. When choosing your username and password, do not use easily identifiable information such as your birthday, telephone number and/or a recognisable part of your name.
6. If you think your username or password has been disclosed to another person, is lost or stolen or an unauthorised transaction has been conducted, you are responsible for informing us immediately.
7. If, in the unlikely event, an unauthorised transaction or any suspicious action has been conducted through your account through no fraud, fault or negligence on your part, please inform us immediately.
Marketing Promotions
1. Occasionally we may collect personal data from you when you visit Pair Up or when you participate in any campaign or promotion of any features of Pair Up. We only collect personal data from you if you voluntarily provide the same to us. We may use your personal data to inform you of products, services and other marketing materials which we think may be of interest to you. We might also invite you to participate in market research and surveys and other similar activities.
2. You can choose whether to receive marketing and other promotional materials by ticking “Accept” or “Deny” box on the relevant page of Pair Up and you may opt out from receiving these materials at any time.
3. If at any time you would like us to stop sending you direct mailings, please contact our representative s by email us at cs@2pairup.com within 30 days and ensure not to include you in future direct marketing promotions.
4. If we do ask you to provide your personal data, we will always specify the purposes for which such personal data is collected and ensure that it is only used for the purposes specified at the time of collection.
Notice Relating to the Personal Data (Privacy) Ordinance (the 'Ordinance')
1. 1. This Notice is served by us in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the laws of Hong Kong). It is intended to notify you why personal data is collected, how it will be used and to whom data access requests are to be addressed.
Collection of Data
1. We may collect the data of users and members of our Service and other individuals in connection with the purposes set out in this Notice.
2. If the data requested by us is not provided, we may be unable to provide (or continue to provide) products or services to you.
3. Data may only be collected from you directly.
4. Personal data which will be collected by the Company includes:
(i) name;
(ii) email address;
(iii) location;
(iv) mobile phone number;
(v) gender;
(vi) a photograph of you as provided by you;
(vii) a photograph of you taken when you apply Pair Up
(viii) date of birth;
(ix) time of birth;
(x) body type
(xi) occupation;
(xii) income level;
(xiii) credit card and billing information (if you subscribe to our paid membership);
(xiv) ethnic origin; and
(xv) religion;
5. To properly enable you to utilise our Service, we may also collect certain special category personal data (only if you provide voluntarily) including but not limited to:
(i) marital Status;
(ii) expectation of marriage;
(iii) children;
(iv) habits (e.g. about drinking, smoking, tattoo, frequency of exercising);
(v) hobbies; and
(vi) self- introduction
Use of Data
1. We will use data for the following purposes or any of them (which may vary depending on the Services you use):
(i) enabling us to process your application for membership and enabling us to provide services to you (including creating your publicly viewable profile, allowing members to search for and match with suitable members and providing mechanisms for communication between members);
(ii) our internal research and statistical purposes (including market segmentation and customer value analysis);
(iii) enabling us to forward to you other information or material which we believe may be of interest to you;
(iv) enabling a payment processor to process payments that you make to us;
(v) considering and processing applications for products and services and the daily operation of products and services;
(vi) marketing products, services and other subjects as described in Use of Data in Direct Marketing below;
(vii) determining the amount of indebtedness owed to us by you;
(viii) exercising our rights under contracts with you, including collecting amounts outstanding from you;
(ix) meeting our obligations, requirements or arrangements whether compulsory or voluntary, to comply with or in connection with:
(1) any law, regulation, judgment, court order, voluntary code, sanctions regime within Hong Kong existing currently and in the future ("Laws");
(2) any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry of Hong Kong;
(3) any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body or other authorities, or self-regulatory or industry bodies or associations or any of their agents with jurisdiction over the Company (together the "Authorities" and each an "Authority") that is assumed by, imposed on or applicable to us; or
(4) any agreement or treaty between Authorities;
(x) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Company and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention of unlawful activities under the Laws;
(xi) conducting any action to meet our obligations to comply with Laws or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;
(xii) meeting our obligations to comply with any demand or request from the Authorities;
(xiii) enabling actual or proposed assignee(s) of all or any part of our business and/or assets, or participant(s) or sub-participant(s) of our rights in respect of you to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation and enabling the actual assignee(s) to use your data in the operation of the business or rights assigned;
(xiv) any other purpose specified in Pair Up’s Terms of Use: https://www.2pairup.com/terms-and-conditions/ ; and
(xv) any other purposes relating to the purposes listed above.
2. We do not sell personal data to any third parties or provide personal data to third parties for any business purpose (unless that business purpose has been specifically referred to in our Privacy Policy). We do provide your personal data to our third party service providers and to our associates(s) (if any) in the circumstances set out in our Privacy Policy and our Terms of Use.
3. We reserve the right to notify you regarding recommended profile matches, notification alerts of activity on Pair Up such as interest alerts or message alerts, promotions or offers, changes or additions to our services, or any products and services of our affiliated businesses.
4. If you are a member of Pair Up you may manage your notification preferences by using the settings on the "Notifications" page of Pair Up to customise what type of notifications you wish to receive.
Destruction of Personal Data
1. We will keep your personal data only for as long as we need it for legitimate business purposes and as required by Laws. We will take reasonable steps to erase any personal data that we hold about you, where:
(i) we no longer need the personal data for the purposes for which it was collected and we are not otherwise entitled to retain such data; and
(ii) we are not required or obligated by Laws or court order to retain the information.
2. If certain information has been provided to third parties in accordance with this Privacy Policy, retention of that information will be subject to the policies of the relevant third party.
If you wish to have your personal data erased, please communicate your request to us. We will respond within 40 days after receiving your request to make necessary assessment. We will erase your personal data if we identify no negative payment history or any suspicious pattern. However, please note that you may not be able to fully utilise the Service of Pair Up if you insist on the erasure of such data and we reserve the right, at our sole discretion, to terminate your Service and your Pair Up account.
3. If you intend to delete your Pair Up account and demand erasure of your personal data, your data will be erased by no more than one year upon deletion of your account unless your account shows a negative payment history, irregularity or any suspicious pattern as assessed.
4. If we correct or erase personal data about you that we previously disclosed to a third party in accordance with our Privacy Policy, we will take reasonable steps to notify the third party of the correction or erasure and to request that they do the same.
Disclosure of Data
1. Data held by us will be kept confidential but we may provide data to the following parties or any of them (whether within or outside Hong Kong) for the purposes set out in Collection of Data section above:
(i) any agents, service providers, contractors, sub-contractors or associates of ours (including their employees, officers, agents, contractors, service providers and professional advisers), if any;
(ii) any third party service providers who provide services to us in connection with the operation or maintenance of our business (including their employees and officers);
(iii) any persons under a duty of confidentiality to us which have undertaken to keep such data confidential;
(iv) any persons to whom we are under an obligation or required or expected to make disclosure for the purposes set out in, or in connection with, paragraphs 1(x), 1(xi) or 1(xii) of Use of Data section above;
(v) any actual or proposed assignee(s) of ours or participant(s) or sub-participant(s) or transferee(s) of our rights in respect of you;
(vi) any persons giving or proposing to give a guarantee or security to guarantee or secure your obligations to us; and
(vii) external service providers that we engage for the purposes necessary for maintaining services of Pair Up.
2. Such data may be transferred in and to a place outside Hong Kong. Any profile information that you have provided to us will be publicly viewable on your profile, irrespective of the location of the viewer. By creating a profile, you acknowledge that both local and overseas recipients will be able to view your profile.
3. In order to provide customer support, perform back office functions, perform fraud prevention tasks, or provide services to you we may need to allow our staff or suppliers (who may be located or whose resources may be located outside Hong Kong) to access your profile information, billing information or other personal data that you have supplied.
4. By providing your personal data and special category personal data you are explicitly consenting to the international transfer and processing of such data in accordance with this Privacy Policy in full and informed knowledge of the risks associated with such transfers and processing.
5. We do not sell your personal data to any third parties. Unless specifically referred to in this Privacy Policy, we also do not disclose your personal data to any third parties for other business purposes.
6. Notwithstanding the above we may in certain circumstances make your personal data available to our third party service providers (to enable us to deliver our services to you) or to our affiliated entities (if any).
Anonymity
1. 1. When you register for our Service you are required to identify yourself, but it is your own decision to do so by providing any name or alias for appearing on Pair Up. However, you must, upon our request, provide your full name and present identity document(s) for our verification at any time, including matching with other members on Pair Up and/or attending offline events organised by Pair Up.
Use of Data in Direct Marketing
1. We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. Please note that:
(i) your name, contact details, products and other service portfolio information, transaction pattern and behaviour, financial background and demographic data held by us (where applicable) from time to time may be used by us in direct marketing;
(ii) the following classes of products, services and subjects may be marketed:
(1) reward, loyalty, co-branding or privileges programmes and related products and services (if any); and
(2) products and services offered by our co-branding partners (the names of such co-branding partners will be provided during the application for the relevant products and services, as the case may be).
(iii) the above products, services and subjects may be provided by or solicited by us and/or:
(1) reward, loyalty, co-branding or privileges programmes and related products and services (if any); and
(2) products and services offered by our co-branding partners (the names of such co-branding partners will be provided during the application for the relevant products and services, as the case may be).
(iv) in addition to marketing the above products, services and subjects ourselves, we may provide the personal data described in paragraph (i) of this section to all or any of the persons described in paragraph (iii) of this section for use by them in marketing those products, services and subjects, and we require your written consent (which includes an indication of no objection) for that purpose; and
(v) we may receive money or other property in return for providing the data to the other persons in paragraph (iv) of this section and, when requesting your consent or no objection as described in paragraph (iv) of this section, we will inform you if we will receive any money or other property in return for providing the data to the other persons.
(vi) if we have collected your personal data in accordance with this Privacy Policy and elect to use such personal data for the purposes of direct marketing (to which you consent), you have the right to opt out from receiving these direct marketing materials at any time to such use. You can email us at cs@2pairup.com, or tap “unsubscribe” at the bottom of the email.
(vii) upon receiving your request, we will, as soon as is reasonably practical, cease using your personal data for the purposes of direct marketing.
Provision of Another Person’s Data
1. Where you provide to us data about another person, you should give to that person a copy of this Notice and, in particular, tell him/her how we may use his/her data.
Data Access Requests
1. You have the right:
(i) to check whether we hold data about you and to access such data;
(ii) to require us to correct any data relating to you which is inaccurate; and
(iii) to ascertain our policies and practices in relation to data and to be informed of the kind of data held by us.
2. In accordance with the provisions of the Ordinance, we have the right to charge a reasonable fee at our discretion for the processing of any data access request.
3. You should send requests for access to data or correction of data or for information regarding policies and practices and kinds of data by filling in the form on “Contact Us” page of Pair Up, or via E-mail: cs@2pairup.com
4. Nothing in this Notice shall limit your rights as a data subject under the Ordinance.
Note: In case of discrepancies between the English and translated versions (if any), the English version shall apply and prevail.
IMPORTANT: By accessing Pair Up and any of its pages you are agreeing to the terms set out above. Thank you for choosing Pair Up.