A.   Our Commitment to Users

1.         Our Company is committed to protecting and respecting your privacy, and undertake to collect and process all personal data provided through the Toilet Buddy App in accordance with the relevant provisions of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong.

2.         Through this Privacy Policy, our Company hopes to make clear to Users our principles and practices for collecting and processing personal data through the Toilet Buddy App. Once you start to use or continue to use the Toilet Buddy App, it means that you accept and agree to our Company’s collection and use of your information in accordance with this Privacy Policy.

3.         This Privacy Policy must be read together with our Company’s Terms and Conditions. The definitions of terms in the Terms and Conditions also apply to this Privacy Policy.

4.         Our Company reserves the right to revise or supplement this Privacy Policy at any time without prior notice to you. Any revised Privacy Policy will take effect immediately upon being published. By continuing to use the Toilet Buddy App, a User is regarded to have agreed to the revised Privacy Policy.

B.    Collection of Personal Data

                To provide Users with a great service, our Company may collect and process the following data from each User:

1.         Information provided by each User during registration on the Toilet Buddy App, including but not limited to:

·         User name for logging in;

·         User password for logging in;

·         Email address;

·         Phone number;

·         Consent to receive marketing communications from our Company; and

·         Consent to receive marketing communications from advertisers.

2.         Data generated when each User uses the Toilet Buddy App, including but not limited to:

·         The date and time when each User logged in, used and left the Toilet Buddy App;

·         The sanitary facilities that each User has browsed or searched;

·         Any map locations that each User has allowed the Toilet Buddy App to read, a requirement before any User can search for or rate any sanitary facilities on the Toilet Buddy App;

·         Any User Content;

·         Ratings of sanitary facilities submitted by any Users;

·         User preference settings;

·         Each User’s time of stay at different parts of the Toilet Buddy App;

·         Each User’s behaviour and habits of using the Toilet Buddy App; and

·         Any technical error messages in the Toilet Buddy App.

3.         Information automatically collected from each User’s computer or device when the User uses the Toilet Buddy App, including but not limited to:

·         Information about the device use to access the Toilet Buddy App;

·         The Internet Protocol (IP) address of each User;

·         Browser type and version;

·         Records and content of browsing and searching on the Toilet Buddy App;

·         Time zone settings; and

·         Operating system and platform.

C.   Purposes for Collection of Personal Data

Our Company collects User’s personal data for the following purposes:

1.         To provide services to Users and continue to improve the Toilet Buddy App to ensure its usability and normal operation. In particular, our Company will organise and analyse personal data and statistical data of Users to customise the user experience of the Toilet Buddy App (for example based on the type of browsers or devices used) and make the Toilet Buddy App more secure.

2.         To create an anonymous database – our Company will anonymise and aggregate personal data of Users, and use such database of personal data for analysis, benchmarking and other commercial purposes. Our Company may also share some of the anonymised data with advertisers to help them understand the characteristics of their marketing targets and at the same time protect the privacy of Users.

3.         User research – our Company may contact individual Users to collect feedback on their use of the Toilet Buddy App. This feedback may be used by the company for:

·         Customisation and improvement of the experience provided by the Toilet Buddy App;

·         Research to develop new products and services;

·         Troubleshooting and testing; and

·         Statistics and surveys.

4.         For marketing – during registration, each User can choose whether they consent to receive marketing communications from our Company and/or our advertisers. If consent is provided by a User, our Company will send newsletters, promotional materials, marketing information, as well as information related to products and services of our Company or our advertisers or any other related information to the User based on preferences provided by the User, through email, SMS, network communication tools or social platforms.

D.   Data Disclosure or Transfer

1.         In most cases, our Company will only disclose or provide Users’ personal information and data to our Company’s internal employees for the purposes mentioned in the “Purpose for Collecting Personal Information”.

2.         However, in some cases, our Company may pass Users’ information and data to the following third party individuals or organisations:

·         Cloud storage providers, web hosting service providers, email notification automation system providers, and any service providers that provide technical support or functions for the Toilet Buddy App;

·         Personnel, agents, consultants, auditors, contractors, financial institutions and service providers related to our Company’s business or services;

·         Any office(s) of our Company outside Hong Kong;

·         Any service providers commissioned by our Company to feedback problems and improve our system;

·         Any actual or proposed assignee; and

·         Any legal person to whom disclosure is required under applicable laws of Hong Kong or any location apart from Hong Kong.

3.         Our Company declares that we have never and will never approve or endorse any improper use of information obtained by any third party through the Toilet Buddy App.

E.    Data Transfer Outside Hong Kong

Under general circumstances, our Company will store each User’s data on servers located in Hong Kong. However, our Company may transmit such data to our Company’s office(s) outside Hong Kong, or to any persons or organisations set out in Clause 4.2 above even if it is located outside of Hong Kong.

F.    Rights of Users

1.         According to the Hong Kong Personal Data (Privacy) Ordinance, you have the right to:

·         Check if our Company holds your personal data and be given a copy of such data;

·         Request our Company to correct any inaccurate data; 

·         Request our Company for personal data deletion; and

·         Know our Company’s principles and practices regarding personal data and the types of personal data held by our Company.

2.         To obtain or correct your personal data, raise deletion request of your personal data, stop receiving communications from our Company, raise questions or file complaints, please contact our Company using the following method(s):

Oslo Hygiene Solution Limited

Email address: [email protected]

3. Our Company may charge a reasonable fee for the processing of data access requests.

G.   Governing Law and Jurisdiction

1.         This Privacy Policy should be exclusively governed by and interpreted in accordance with the laws of Hong Kong.

2.         The Hong Kong courts should have exclusive jurisdiction over any legal procedures related to this Privacy Policy.