Privacy Policy

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Responsible party pursuant to data protection laws, in particular the EU General Data Protection Regulation (GDPR), is

Trekade Media Limited
Room 1105, 11F, Wayson Commercial Bldg.,
28 Connaught Road West, Sheung Wan, Hong Kong
Contact Email: privacy@keebs.gg
Contact Name: James McLane

Your rights as the data subject

You can exercise the following rights at any time using the contact details of our data protection officer:

  • Information on your data stored by us and the processing thereof (Art. 15 GDPR),
  • Rectification of inaccurate personal data (Art. 16 GDPR),
  • Deletion of your data stored by us (Art. 17 GDPR),
  • Restriction of the data processing, provided that we may not delete your data due to legal obligations (Art. 18 GDPR),
  • Objection to the processing of your data with us (Art. 21 GDPR), and
  • Data portability, provide that you have consented to the data processing or have entered into a contract with us (Art. 20 GDPR).

If you have given us consent, you may withdraw it at any time, which will remain in effect in the future.

You can contact a supervisory authority with a complaint at any time, e.g. the supervisory authority of the state of your residence or the authority that oversees us as the responsible party.

You’ll find a list of supervisory authorities (for the non-public area) with their respective addresses at: https://www.pcpd.org.hk.

Collecting general information during a visit to our website

Type and purpose of the processing

When you access our website – i.e. if you do not register or submit information – information of a general nature will be collected automatically. This information (server log files) contains the type of web browser, the operating system used, the domain name of your Internet service provider, your IP address and the like.

It is processed in particular for the following purposes:

  • Ensuring an unproblematic website connection,
  • Ensuring seamless use of our website,
  • Analysis of system security and stability, as well as
  • For additional administrative purposes.

We will not use your data to draw conclusions about your person. This type of information will be statistically analysed by us if necessary to optimise our website and its underlying technology.

Legal basis

The processing occurs according to Art. 6 Para. 1 (f) GDPR, based on our legitimate interest in improving the stability and functionality of our website.

Recipients

Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.

Retention period

The data will be deleted as soon as they are no longer required for the reason they were collected. This is generally the case, after the respective session has ended, for data that are used to make the website available.

Mandatory or required provision

The provision of the aforementioned personal data is neither legally nor contractually mandatory. Without the IP address however, the service and functionality of our website are not guaranteed. Furthermore, individual services can be unavailable or limited. For this reason, an objection is excluded.

Cookies

Type and purpose of the processing

Like many other websites, we use so-called ‘cookies’. Cookies are small text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website.

With cookies, we receive certain information such as IP address, type of browser and operating system used.

Cookies cannot be used to start programs or to transmit viruses to a computer. Based on the information contained in cookies, we can facilitate your navigation of our site and properly display our webpages for you.

The data collected by us will not be shared with third parties under any circumstances nor will a link to personal data be created without your consent.

Of course, you can view our website without cookies. Internet browser are regularly configured to accept cookies. In general, you can disable the use of cookies via your browser settings at any time. Please use your Internet browser’s help function to learn how to change these settings, and keep in mind that individual features of our website may not work if you have disabled the use of cookies.

Retention period and cookies used

If you allow us to use cookies, via your browser settings or consent, the following cookies may be utilised on our web pages:

  • Login token cookie, for 6 months or when you logout
  • Cookie consent cookie, for 6 months

In the following sections, we provide you with information concerning how these cookies can (also) pertain to personal data.

In your browser settings, you can delete individual cookies or the entire set of cookies. You will also find information and instructions on how to delete these cookies or prevent them from being saved in advance. The following links provide the information you’ll need for the respective browser providers:

  • Mozilla Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
  • Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
  • Google Chrome: https://support.google.com/accounts/answer/61416?hl=en
  • Opera: https://www.opera.com/o/ie-simple
  • Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=en_US

Registration on our website

Type and purpose of the processing

With the registration to use our personalised services, some personal data such as name, address, contact and communication information (e.g. phone number and e-mail address) are collected. If you are registered with us, you can access content and services that we only offer to registered users. Registered users also have the ability to change or delete the data entered during registration at any time. At any time, we will also provide you with information on the personal data about you that we have saved.

To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.

Our Site offers you the ability to register and login using your third party social media account details (like your Facebook login). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Site. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

Legal basis

The data entered during registration are processed on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR).

If the registration fulfils the obligations of a contract, whose contractual party is the data subject, or serves to implement pre-contractual measures, the additional legal basis for the data processing is Art. 6 Para. 1 (b) GDPR.

Recipients

Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor.

Retention period

Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter, provided that no statutory retention obligations prohibit the deletion. To contact us in this regard, please use the contact information provided at the end of this privacy policy.

Mandatory or required provision

The provision of your personal data is voluntary, based solely on your consent. Without the provision of your personal data, we cannot give you access to our content and services.

Commentary function

Type and purpose of the processing

When users leave comments on our website, the time of their creation and the username selected by the website visitor are saved. This is for our security, as we may be prosecuted for any illegal content on our website, even if it was created by users.

Legal basis

The processing of the data entered as a comment occurs on the basis of a legitimate interest (Art. 6 Para. 1 (a) GDPR).

With the commentary feature, our aim is to provide you with an uncomplicated way to interact. The information you enter will be stored for the purpose of processing the request as well as possible follow-up inquiries.

Recipients

Recipients of the data may be the processors.

Retention period

The data will be deleted as soon as they are no longer required for the reason they were collected. This is generally the case, when the communication with the user has ended and the company can see from the circumstances that the respective issue has been clarified.

Mandatory or required provision

The provision of your personal data is voluntary. Without the provision of your personal data, we cannot guarantee you access to our commentary function.

Submission function

Type and purpose of the processing

Our website allows the uploading of pictures, videos, and other media as a way to express yourself to other members of the community. As a consequence, media that is submitted to our website may be accessed by anyone with access to our website, including other members and third-parties. A full explanation of how uploaded media is treated is covered in our Copyright Policy.

Legal basis

The processing of the data entered as a comment occurs on the basis of a legitimate interest (Art. 6 Para. 1 (a) GDPR).

With the submission feature, our aim is to provide you with an uncomplicated way to interact. The information you enter will be stored for the purpose of processing the request as well as possible follow-up inquiries.

Recipients

Recipients of the data may be anyone with access to the website.

Retention period

The data will be deleted as soon as they are no longer required for the reason they were collected. This is generally the case, when the communication with the user has ended and the company can see from the circumstances that the respective issue has been clarified. However, we cannot control if this media has already been saved or accessed by third parties before this time, and cannot be responsible for removing said content from third-parties in possession of it.

Mandatory or required provision

The provision of your personal data is voluntary. Without the provision of your personal data, we cannot guarantee you access to our submission function.

Contests and polls

Type and purpose of the processing

When participating in certain contests and polls, some personal data such as name, address, contact and communication information (e.g. phone number and e-mail address) are collected. If you are registered with us, you can participate in these activities that we only offer to registered users. We may also save your IP address and a specific cookie for the duration of the contest or poll to ensure singular participations.

Legal basis

The data entered during registration are processed on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR).

If the registration fulfils the obligations of a contract, whose contractual party is the data subject, or serves to implement pre-contractual measures, the additional legal basis for the data processing is Art. 6 Para. 1 (b) GDPR.

Recipients

Recipients of the data may be technical service providers, who work on the operation and maintenance of our website as the processor. Courier companies (such as DHL or FedEx) and third-party hardware sponsors may also have access to this data in order to distribute prizes.

Retention period

Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter, provided that no statutory retention obligations prohibit the deletion. To contact us in this regard, please use the contact information provided at the end of this privacy policy.

Mandatory or required provision

The provision of your personal data is voluntary, based solely on your consent. Without the provision of your personal data, we cannot give you access to our content and services.

Newsletter

Type and purpose of the processing

Your data will be used exclusively to send you the newsletter you subscribed for via e-mail. We request your name so that we can address you personally in the newsletter and identify you as needed should you want to exercise your rights as a data subject.

To receive the newsletter, providing your e-mail address is sufficient. When you subscribe to our newsletter, the data you provide will be used exclusively for this purpose. Subscribers can also be notified by e-mail about circumstances that are relevant to the service or registration (such as changes to the newsletter offer or technical matters).

We need a valid e-mail address to complete your registration. In order to verify that a registration is actually made by the owner of an e-mail address, we utilise the ‘double opt-in’ procedure. To this end, we log the newsletter subscription request, when a confirmation e-mail is sent and the receipt of the requested reply. Additional data is not collected. The data will be used exclusively for sending the newsletter and will not be shared with third parties.

Legal basis

Based on your express consent (Article 6 (1) a DSGVO), we will send you our newsletter on a regular basis or comparable information via e-mail to your specified e-mail address.

The consent to save and use your personal data for the newsletter may be withdrawn at any time and remain in effect in the future. Every newsletter contains a corresponding link, and you can also unsubscribe on this website at any time or inform us of your cancellation via the contact option indicated at the end of this privacy policy.

Recipients

Recipients of the data may be the processors.

Retention period

Data are only processed in this context provided that the corresponding consent has been given. The data will be deleted thereafter.

Mandatory or required provision

The provision of your personal data is voluntary, based solely on your consent. Unfortunately, we cannot send you our newsletter without your consent.

Contact/Support form

Type and purpose of the processing

The data you enter are used for individual communication with you. A valid e-mail address and your name are required for this communication, which serves to organize your inquiry and the respective subsequent reply. Providing additional information is optional.

Legal basis

The processing of the data entered in the contact form occurs on the basis of a legitimate interest (Art. 6 Para. 1 (f) GDPR).

By providing the contact form, our aim is to facilitate an uncomplicated means for you to contact us. The information you enter will be used to process the inquiry and saved for possible follow-up questions.

If you contact us to request an offer, the processing of the information provided in the contact form will occur in order to implement pre-contractual measures (Art. 6 Para. 1 (b) GDPR).

Recipients

Recipients of the data may be the processors.

Retention period

The data will be deleted no later than 6 months after processing the inquiry.

Provided that we enter into a contract together, we will use the statutory retention periods in the commercial code and delete your data according to the respective stipulated deadlines.

Mandatory or required provision

The provision of your personal data is voluntary. However, we can only process your inquiry if you provide us with your name, e-mail address and the reason for your inquiry.

Using Google Analytics

Type and purpose of the processing

This website uses Google Analytics, a web analytics service of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 USA (hereinafter: ‘Google’). Google Analytics uses so-called ‘cookies’, i.e. text files that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookie about your use of this website is typically transmitted to a Google server in the U.S. and stored there. However, due to the activation of IP anonymisation on these websites, your IP address will be truncated beforehand by Google within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the U.S. and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, summarise reports on website activities and provide other services related to website and Internet usage to the website operator. The IP address transferred from your browser as part of Google Analytics will not be combined with other data from Google.

The data processing purposes are the website-use analysis and the summary of reports on activities on the website. Based on the use of the website and the Internet, other related services will be provided.

Legal basis

The processing of the data occurs on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR).

Recipients

The recipient of the data is Google as the processor. For this, we have entered into the corresponding data-processing contract with Google.

Retention period

The deletion of the data occurs as soon as they are no longer necessary for our recording-keeping purposes.

Third country transfers

Google processes your data in the United States of America and is subject to the EU-US Privacy Shield: https://www.privacyshield.gov/EU-US-Framework.

Mandatory or required provision

The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.

Revocation of consent

You can prevent the storage of cookies by a corresponding setting in your browser software; however, please note that in this case you may not be able to use all the functions of this website in their entirety. Furthermore, you can prevent the collected data generated by the cookie and the data related to your use of the website (including your IP address) being transmitted to Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: browser add-on to deactivate Google Analytics.

Profiling

With the assistance of the tracking tool Google Analytics, the browsing behaviour of the website visitors can be evaluated and their respective interests can be analysed. For this analysis, we create a pseudonymous user profile.

Using Matomo

Type and purpose of the processing

This website uses Matomo (formerly Piwik), an open-source software for the statistical evaluation of visitors. The provider of the Matomo software is InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand.

Matomo uses so-called ‘cookies’, which are text files that are stored on your computer and allow an analysis of your use of the website.

The information generated by the cookie about your use of the website is stored on servers in: United States of America

The IP address is anonymised immediately after the processing and before it is saved. You have the option to prevent the installation of cookies by changing the settings of your browser software. Please note that with the corresponding setting, not all functions of this website may be available.

You can decide whether a unique web analytics cookie may be stored in your browser in order to allow the operator of the website to collect and analyse various statistical data.

You’ll find additional information on the privacy settings of the Matomo software at the following link: https://matomo.org/docs/privacy/

Legal basis

The processing of the data occurs on the basis of the user’s consent (Art. 6 Para. 1 (a) GDPR)

Recipients

Recipients of the data may be the processors.

Retention period

The deletion of the data occurs as soon as they are no longer necessary for our recording-keeping purposes.

Mandatory or required provision

The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.

Revocation of consent

You can prevent the storage of cookies by a corresponding setting in your browser software; however, please note that in this case you may not be able to use all the functions of this website in their entirety.

Profiling

With the assistance of the tacking tool Matomo, the browsing behaviour of the website visitors can be evaluated and their respective interests can be analysed. For this analysis, we create a pseudonymous user profile.

Embedded YouTube videos

Type and purpose of the processing

We embed YouTube videos on several of our websites. The operator of the respective plugins is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter ‘YouTube’). YouTube, LLC is a subsidiary of Google LLC, 1600 Amphitheater Pkwy, Mountain View, CA 94043, USA (hereinafter ‘Google’). When you visit a page with the YouTube plug-in, a connection to YouTube’s servers will be created, which tells YouTube which pages you visit. When you are logged into your YouTube account, YouTube can associate your browsing behaviour with you personally. You can prevent this by logging out of your YouTube account beforehand.

If a YouTube video is started, the provider uses cookies that collect information about user behaviour.

You will find additional information on the purpose and scope of the data collection and its processing by YouTube in the provider’s privacy policy, as well as additional information on your rights and setting options for protecting your privacy (https://policies.google.com/privacy). Google processes your data in the United States of America and is subject to the EU-US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

Legal basis

Your consent is the legal basis for the integration of YouTube and the associated data transfer to Google (Art. 6 Para. 1 (a GDPR).

Recipients

Visiting YouTube automatically triggers a connection to Google.

Retention period and revocation of consent

Everyone who has disabled the storage of cookies for the Google ad programme will not have to expect any cookies when watching YouTube videos. However, YouTube also stores non-personal usage information in other cookies. If you would like to prevent this, you must block the storage of cookies in the browser.

You’ll find additional information on data protection at ‘YouTube’ in the provider’s privacy policy at: https://policies.google.com/privacy.

Third country transfers

Google processes your data in the United States of America and is subject to the EU-US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

Mandatory or required provision

The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this can lead to functional limitations on the website.

SSL encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (such as SSL) via HTTPS.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third Party Links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:

  • Users can visit our site anonymously
  • Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
  • Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.
  • Users will be notified of any privacy policy changes on our Privacy Policy Page.
  • Users are able to change their personal information by emailing us.

How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third party behavioral tracking?
It’s also important to note that we allow third party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur, we will notify the users via in site notification within 7 business days.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

To be accordance with CANSPAM we agree to the following:

  • NOT use false, or misleading subjects or email addresses
  • Identify the message as an advertisement in some reasonable way
  • Monitor third party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly
  • Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email.

Questions for the data protection officer

If you have any questions pertaining to data protection, please send us an e-mail or contact the person responsible for data protection in our organization:

Trekade Media Limited
Contact email: privacy@keebs.gg
Contact name: James McLane

Revision of our privacy policy

We reserve the right to amend this privacy policy so that it always complies with current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. Your next visit will be subject to the new privacy policy.

Effective November 2018

Parts of this this privacy policy were created via the activeMind AG Privacy Policy Generator.