Bull Bear Mobile Application - Privacy Policy

This Privacy Policy ("Policy") governs the collection of personal data in connection with your use of the Bull Bear Mobile Application (the "App") for mobile devices provided by [Bull Bear Group Limited] (the "Company"). Under the Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO") and related laws and regulations, the Company has certain legal obligations regarding the personal data that we collect from you. This Policy is designed to give you useful information about the way we collect it, what we use it for, when we might disclose it and how you can manage your personal data.


By downloading and using the App, you are accepting our Policy. If you do not agree to the terms of this Policy, please do not download the App. We reserve the right to change the provisions of this Policy at any time. Your continued use of the App will mean that you accept any changes to the Policy from time to time.
We collect two basic types of data from you in conjunction with your use of the App, "Personal Data" and "Non-Personal Data".
"Personal Data" is any information that can individually identify you and includes your [name, e-mail address, username, telephone number, postal address, billing and contact information]. We will only collect and use your Personal Data for the purposes which are set out in this Policy.
"Non-Personal Data" includes aggregate and/or automatic information, which is data collected about the use of the App or about a group or category of users from which individual identities or other individually identifiable information has been removed. This Policy in no way restricts or limits our collection, use and provision of Non-Personal Data.
We may use your Personal Data and Non-Personal Data in the following ways:
  1. register, verify and manage your account on the App;
  2. facilitate your log-in access to the App, e.g. establish and maintain your logged-on identity in the App so that you can conveniently browse, access and use the App without being repeatedly requested to log-on;
  3. communicating with you about your account and sending you information about and/or features of the App;
  4. monitoring, customizing or improving the use of the App;
  5. facilitate the performance of our services offered on the App;
  6. customizing the advertising content of the App;
  7. administering the events/games organized on the App including informing you of a prize you have won;
  8. communicating with you about changes to our policies or terms;
  9. detecting, investigating and preventing activities that may violate our policies or be illegal;
  10. compile, process and generate statistics reports for the App, and performing statistical, demographic, and marketing analyses of users of the App;
  11. compile, maintain and update our database of account holders and users on the App; and
  12. use for our internal management or administrative purposes in relation to the App.

You shall provide true, accurate and updated Personal Data and shall not misrepresent yourself to be another individual or legal entity. Any changes in your Personal Data shall be notified to the Company immediately and in any case no later than 7 days from the date of such changes.
In accordance with the requirements of the PDPO on direct marketing, the Personal Data that you provided and/or will provide during your activity at bullbearapp.com (the "Site") or on the App may be used by the Company for sending the Company's advertising content to you, unless you object the Company to do so. You may send to the Company, at any time, an e-mail to [email protected] requesting the Company to cease from sending such advertising content to you. The aforesaid mark removal in the approval tick box and/or the e-mail receipt by the Company will oblige the Company to cease sending advertising content to you within seven business days.
The Personal Data that you provided and/or will provide during your activity at the Site or on the App may be disclosed by the Company to official authorities. The Company will make such disclosure only if required to be disclosed by the Company by applicable law, regulation or court order and to the minimum extent required.
As a precondition for performing online transactions (the "Transactions"), you may be asked to provide certain identification documents and any other documents required by the Company. If such documents are not provided, the Company can, at its sole discretion, freeze your Account for any period of time as well as permanently close your Account. Without prejudice to the above, the Company may, at its sole discretion, refuse to open an Account for any person or entity and for any reason, or for no reason. In case a person gets registered on the App on behalf of a corporation or other business entity, such registration shall be considered as a representation by such person, and such person is authorized to bind the corporation or other business entity. The Company shall not, during your usage of the App and/or after you cease to use the App, divulge any of your Personal Data unless you approve in writing of such disclosure or unless such disclosure is required under applicable law or is required in order to verify your identity. Your Personal Data is passed only to employees of the Company who deal with your Account. All such Personal Data shall be stored on electronic and physical storage media according to applicable law.
You hereby confirm and agree that all or part of the information concerning Your Account and Transactions (including but not limited to Personal Data and Non-Personal Data), will be stored by the Company and may be used by the Company in case of dispute between you and the Company.
At its sole discretion, the Company may, but is not obliged, to review and inspect any information provided by the Client (including but not limited to Personal Data and Non-Personal Data) for any purpose. It is manifestly stated that, by downloading and using the App, you also agree that the Company holds neither commitment nor responsibility to you due to any aforesaid review or inspection of information.
The Company will take measures to implement advanced data protection procedures and to update them from time to time for the purpose of safeguarding your Personal Data and your Account. We will retain your Personal Data and Non-Personal Data for as long as it is necessary to fulfill the purposes for which they are to be used and erase any of your Personal Data and Non-Personal Data that we have stored as soon as reasonably practicable, subject to, or where otherwise required by law or permitted by law.
Upon registration on the App, you will be asked to choose a username and password to be used by you on each future login and for the performance of Transactions and use of the Company's services. In order to protect your privacy, sharing of the registration details (including without limitation, username and password) by you with other persons or business entities is strictly prohibited. The Company shall not be held liable for any damage or loss caused to you due to improper use (including prohibited and unprotected use) or storage of such username and password, including any such use made by a third party, and whether or not known to or authorized by you. Any access to your Account on the App with your username and password remains your sole responsibility. The Company shall not be held liable for any of such use. You are obliged to forthwith notify the Company of any suspicion for unauthorized use of your Account.
The Company does not store or collect any Credit Card data. In accordance with the recommendations of Payment Card Industry Security Standards Council, customer card details are protected using Transport Layer encryption - TLS 1.2 and application layer with algorithm AES and key length 256 bit.
Games or events run via the App will be subject to a set of rules. The rules for each game or event will specify how the information gathered from you for entry will be used and disclosed, if it is different to what is described in this Policy.
You should be aware that when you access to the Site or use the App, we may collect information by using cookies, web beacons or unique device identifiers to identify your device that is accessing the Site or the App. A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a "device" browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. You may choose to configure your browser to reject cookies by modifying your browser settings or preferences.
During the course of any visit to the Site or use of the App by you, the pages viewed, along with a cookie are downloaded to your device. Cookies stored may determine the path you took on the Site or the App and used to anonymously identify repeat users of the Site and what pages were most popular among our users. However, the Company protects your privacy by not storing your Personal Data. Using cookies is an industry standard and is currently used by most major websites. Stored cookies allow the Site to be more user-friendly and efficient for users by allowing the Company to learn about what information is more valued by our users versus what isn't.
You can stop all collection of information by the Company easily by uninstalling the App and/or deleting your Account on the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. We will remove your Personal Data and other preferences associated with your Account promptly after you delete your Account on the App.