Privacy Policy

This Privacy Policy (“this Policy” or “Policy”) sets out the basis on which Meed Limited a company incorporated under the laws of Hong Kong with its registered office address at 608, Sunbeam Centre, 27 Shing Yip Street, Kwun Tong, Kowloon, Hong Kong (Company Registration Number 74349808) (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called "Meed", “we” or “us”) collect personal data from you and how we handle such data.

We provide the meed platform (“meed”) for participating businesses (“Program Operators”) to create customer loyalty programs ("Programs") and voucher campaigns (“Campaigns”), and for customers to join the Programs. Through meed, customers can earn and redeem rewards (such as points, stamps, and discount or other incentive or reward vouchers) under the Program and/or on meed.

By visiting our website meedloyalty.com (our “Site”) or using meed or any other web or mobile applications or software we provide from time to time (collectively our “App”), you accept and consent to the practices set out below.

1. COLLECTION OF INFORMATION

1.1 For the purposes outlined in Clause 2, we may collect and process the following information about you:

(a) Information you give us - information that you provide us (which may include your name, user name, address, email address, telephone number, transaction information and/or other personal description) by filling in forms on our Site or our App or otherwise using our products or service, or by corresponding with us (by phone, email or otherwise), for example:

(i) Sign-up and Log-in Information: you will need to provide your name, mobile phone number and/or an email address when you sign up for an account or membership with us . We may also collect any user name, nickname and/or login ID and password created by you. YWe may ask you to add other optional information for your account or membership, such as “about” information. We will use your mobile phone number or email address to verify your account or membership, for example, by sending you a code via SMS or email;

(ii) Receipt Information: when you use the meed scanning feature in our App to collect stamps or other rewards, you will need to upload the relevant transaction receipt, which contains details such as the date, time and location, and the amount of the transaction;

(iii) Business Information: if you are a business customer, for individual directors, owners, or authorised representatives of the business, we may collect personal data such as names and and contact information to create and operate your account with us; and/or

(iv) Contact Information: you may provide us your contact details, such as your name and your address, email address, and/or phone number when you contact us for customer support or report any problem to us, or otherwise communicate with us, or when you complete our survey or questionnaire.

(b) Information we collect about you - information collected when you browse or use our Site or our App by using log files, cookies or similar technologies, for example, for example:

(i) Device and Connection Information: including the location information of the device you use to interact with our Site or our App, such as the iInternet protocol (IP) address and general geographic location, type of device, browser type and version, time zone setting, browser plug-in types and versions, and the operating system;

(ii) Usage Information: information about your usage of our Site or our App, including your browsing history, the full Uniform Resource Locators (URLs) clickstream to, through and from our Site or our App (for example, date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page; and/or

(iii) Activity Information: information about your account or membership activities through our Site or our App, including the time and location of Program and Campaign creation and participation, the issue, collection or redemption of points, vouchers, stamp cards or other offers or rewards, offer or reward balances, and the account or membership status.

1.2 We only retain personal data for so long as it is necessary. If you deactivate your account or membership, we may retain certain information longer if necessary to defend our legitimate interests or those of third parties, comply with legal requirements, resolve or defend ourselves in disputes, investigate misuse or disruption of our products or services, or perform contractual obligations. Data may be archived as long as the purpose for which the data was used still exists.

2. PURPOSE OF USE OF INFORMATION

2.1. We collect your personal data so that we can provide our products and services and operate our business. What we use your personal data for is often referred to as our purposes of processing. We do this by prior notification of the purposes of processing, with your consent where required by law, or where otherwise permitted or required by applicable law. We may not be able to offer or provide our products and services if you do not provide us with, or do not want us to process, the personal data that we consider is necessary and/or is required to meet our legal and regulatory obligations.

2.2 When we process your personal information, we rely on the following legal basis to do so:

(a) Consent: you have consented to the processing of your personal data for a specific purpose(s);

(b) Performance of a Contract: the processing is necessary for us to be able to provide you with our products and services in performance of our contract with you, or in order to take steps at your request before entering into a contract;

(d) Vital Interests: the processing of your personal data is necessary to protect you or someone else’s life or health; and/or

(e) Legitimate Interests: the processing is necessary our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests, for example, combating fraud or other unlawful conduct, protecting privacy, and complying with duties of care for employees and/or customers.

2.3 In particular, we use information held about you for the following purposes:

(a) Operation and Administration: providing, operating, improving and developing our products or services, performing the contract we enter into with you for example, creating, administering and maintaining your account or membership and using or generating information about your use of our product or service (such as user activity data, analytics event data and clickstream data) for data analytics and machine learning, and to help us measure traffic and usage trends of our product or service, to protect the safety and security of our platform, verification purposes and addressing and remediating technical issue and bugs;

(b) Optimisation and Improvements: researching, designing and launching new features or products or services, for example, creating anonymous data from data we collect by removing information that makes the data personally identifiable to you, and we may use this anonymous data and share it with third parties for lawful business purposes to analyse and improve our products or services;

(c) Personalisation: presenting content and information in our Site and our App in the most effective manner for you and for the device you use, for example, posting, uploading, creating or otherwise generating any content and/or information on our Site and/or our App;

(d) Transactional Communications: as part of providing our products or services, providing users with service, transactional, technical and other administrative communications, such as communications about your account or membership, our product or service offerings, changes to our product or service offerings, and important product or service-related notices, such as system maintenance, security and fraud notices;

(e) Marketing: providing you with alerts, updates, materials or information about our products or services or other types of information that you requested or signed up to, for example, promotional and marketing events;

(f) Laws and Regulations: complying with laws and regulations applicable to us in any part of the world;

(g) Exercising our Legal Rights: tracing and exercising our rights and protecting ourselves against harm to our rights and interests, and/or responding or taking part in legal proceedings, including seeking professional advice;

(h) Customer Support: communicating with you and responding to your questions or requests, including providing non-marketing information in relation to our products or services;

(i) Mergers, Acquisitions and Divestments: should we or any of our affiliates undergo an actual or potential transfer of all or part of our business and/or assets, a change in control, including by means of a reorganisation, merger, acquisition or purchase, a joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stocks, your information may be shared with the parties involved in such an event;

(j) Protecting Rights and Safety: if we believe in good faith that this will help protect the rights, property or personal safety of us, any of our users or any member of the general public, with or without notice to you; and/or

(k) Related or Incidental Purposes: purposes directly related or incidental to the above.

2.3 With your consent where required by law, we may send you direct marketing communications as permitted by law, including notifying you of promotions, offers and events via email or in-app notifications. You may withdraw your consent for us to use your personal data in direct marketing communications. Please refer to Clause 11.2 on your right to withdraw your consent.

3. DISCLOSURE OF INFORMATION

We will keep your personal data we hold confidential but you agree we may provide information to:

(a) Group Members: any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries ("Group Members");

(b) Personnel, Service Providers and Advisers: employees, officers or other personnel, agents, advisers, auditors, contractors, consultants, financial institutions, insurers or insurance brokers, and service providers in connection with our operations, products or services;

(d) Courts, Authorities and Regulators: persons to whom we are required or expected to make disclosure under applicable laws and/or regulations in any part of the world, or by a court order or if we believe that such action is necessary to prevent fraud or cybercrime or to protect our Site or our App or the right, property or personal safety of any person;

(e) Transferees: as permitted by applicable law, to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and/or

(f) Other Third Parties: persons under a duty of confidentiality to us.

4. COOKIES

4.1 Our Site and our App use cookies to distinguish you from other users of our Site and our App. This helps us to provide you with a good experience when you browse our Site and our App and also allows us to improve our Site and our App.

4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.

4.3 We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or our App or a partner site that uses our products or services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

4.4 We use the following cookies:

(a) Necessary Cookies - These are essential for our Site or our App to function properly. They include, for example, cookies that enable you to create and operate your account or membership with us or log into secure areas of our Site or our App. Our Site or our App cannot operate optimally without these cookies.

(b) Analytics/Performance Cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our Site or our App when they are using it, for example, collecting information about the pages visited, the time spent on our Web or our App, and any issues encountered. This helps us to improve the performance of our Site or our App and user experience.

(c) Functionality/Preference Cookies - These are used to recognise you when you return to our Site or our App. This enables us to provide enhanced functionality and personalisation, including personalising our content for you, greeting you by your name and remembering your preferences (for example, your choice of language or region).

(d) Targeting/Marketing Cookies - These record your visit to our Site or our App, the pages you have visited and the links you have followed. These may be set through our Site or our App by our third party web service providers. We will use this information to make our Site, our App and the information displayed on it more relevant to your interests.

4.5 We may use third-party web services. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it, including ads displayed on our Site or our App, more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

4.6 You can block cookies by activating the setting on your device or browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site or our App. These opt-out mechanisms are specific to the device or browser, so you will need to opt out on every browser and device that you use. Please also note that opting out of our first-party or third-party targeting/advertising cookies does not necessarily mean that you will not see our ads, only that these ads will not be targeted to you through the use of such cookies.

5. AGGREGATED DATA

We may generate or extract aggregated or anonymised data that does not include any personally identifiable information out of any databases that contain your personal data. Such aggregated or anonymised data may be used by us or other third parties to enable us or them to better understand customer needs or to improve our or their operations, products and services, or for the purposes of industry benchmarking, machine learning, behaviour segmentation, targeted marketing and research or analytics.

6. THIRD-PARTY SITES

Our Site, our App or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for any practices of third-party websites.

7. SECURITY

7.1 We take the privacy and security of your personal data very seriously. We take reasonable steps, including physical, technical and organisational measures, to protect your personal data from unauthorised access, processing or use.

7.2 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

7.3 We restrict access to personal data to our employees, officers, service providers, contractors and consultants on a strictly need-to-know basis and ensure that those persons are subject to confidentiality obligations.

7.4 We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

7.5 Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site or our App; any transmission is at your own risk.

8. DATA TRANSFER

8.1 We are based in Hong Kong and process data in Hong Kong, which may not provide the same levels of rights and protections as your home jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Policy.

8.2 When providing our products or services, your personal data may be processed by, transferred to or stored at our other Group Members outside of Hong Kong, or contractors, advisers and service providers who operate outside Hong Kong who are contractually committed to protect and secure your data, however, we do not control or accept liability for the acts and omissions of these third parties.

8.3 By submitting your personal data or continuing to use our Site or our App, you agree to such transfer, storing or processing of data outside of your home jurisdiction.

9. SENSITIVE PERSONAL DATA

In some jurisdictions, certain types of personal data (such as information about your race, religious, political or philosophical views, sexual orientation and health) are characterised as sensitive personal data, which is subject to stricter regulation than other types of personal data. We do not require you to provide sensitive personal data to use our Site or our App.

10. PERSONAL DATA OF CHILDREN

We do not intentionally gather personal data from an individual under the age of majority (“Child”, and collectively “Children”) without first obtaining parental or guardian consent to and acknowledgement of this Policy. If you are a parent or guardian of a Child and you believe that we have collected personal data from your Child without such parental or guardian consent and acknowledgement, please contact us at info@meedloyalty.com so that we can investigate and remove such personal data.

11. YOUR RIGHTS

11.1 You have rights in relation to personal data we hold about you. To the extent provided by applicable laws and regulations, you have the right to:

(a) check whether we hold personal data about you;

(b) request a copy of personal data we hold about you; and

You have the right to change or withdraw your consent to process your personal data. However, we may not be able to provide our products and services or engage with you without certain personal data.

11.2 You have the right to request us to stop using your personal data to send you direct marketing by changing the app push notification setting for your account or membership in our Site or our App, changing the settings on your mobile device, or by following the unsubscribe instructions in the direct marketing communication we send to you. If you opt out of direct marketing communications, you may continue to receive service-related and other non-marketing communications from us.

11.3 To the extent permitted by applicable laws and regulations, any request under this Clause 11 may be subject to a small administrative fee to meet our cost in processing your request.

11.4 We will respond to requests to exercise your personal data rights in line with applicable law. We may ask you to verify your identity before processing your request.

11.5 We are not involved in or responsible for any marketing materials that are not related to meed and sent directly by any Program Operator to you. If you would like to stop receiving any such marketing materials from any Program Operator, please contact them directly to unsubscribe from their mailing lists.

12. CHANGES TO POLICY

We may amend this Policy from time to time by posting the updated Policy on our Site and our App. By continuing to use our Site or our App after the changes come into effect means that you agree to be bound by the updated Policy.

13. LANGUAGE

We may translate this Policy into multiple languages. If there is any conflict or inconsistency between the English version and any other language version of this Policy, the English version will prevail.

14. CONTACT US

If you have any questions, comments or requests regarding personal data, please address them to:

Data Protection Officer, info@meedloyalty.com

Last updated: January 2025