Definitions and legal references:
Personal Data (or Data): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data: Information collected automatically through Importify (or third-party services employed in Importify), which can include: the IP addresses or domain names of the computers utilized by the Users who use Importify, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User: The individual using Importify who, unless otherwise specified, coincides with the Data Subject.
Data Subject: The natural person to whom the Personal Data refers.
Data Controller (or Owner): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Importify. The Data Controller, unless otherwise specified, is the Owner of Importify.
Importify (Site or Application): The means by which the Personal Data of the User is collected and processed.
Service: The service provided by Importify as described in the relative terms (if available) and on this site/application.
European Union (or EU): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies: Small sets of data stored in the User’s device.
The site owner details:
Company name: Importify Limited.
Address: Unit 1603, 16th Floor, The L. Plaza, 367 – 375 Queen’s Road Central, Sheung Wan, Hong Kong.
Contact email: firstname.lastname@example.org.
The information collected and the methods of collecting it.
When using Importify Services your action on the site and on the App are collected. The Information we collect is delivered by you knowingly as well as information on you actions on site and App (for statistical purposes):
Information knowingly provided is, for example, the information provided by you when creating a user account – this information identifies you personally, on your name and address, and may include services you have purchased or requested, the means of payment used by you, etc…
Information used for statistical purposes is aggregated information that does not identify you personally and is not saved along with your information. This information includes but not only, advertisements you have viewed, the pages you have browsed, the offers and services that interest you, the Internet address (IP) you directed, and so on.
Among the types of Personal Data that Importify collects, by itself or through third parties, there are: Cookies, Usage Data, email address, first name and last name.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Importify.
Unless specified otherwise, all Data requested by Importify is mandatory and failure to provide this Data may make it impossible for Importify to provide its services. In cases where Importify specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through Importify and confirm that they have the third party’s consent to provide the Data to the Owner.
Methods of processing.
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Importify (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Registration for services.
Insofar as personal information is required when registering for services on the Site/App, Importify will ask the user only the information necessary directly for the provision of the service.
The data collected will be stored at Importify database and under its responsibility.
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Place of processing: Hong Kong.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
The purposes of processing:
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, managing contacts and sending messages, Contacting the User, and Remarketing and behavioral targeting.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data. Personal Data is collected for the following purposes and using the following services:
Analytics – The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Importify, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Facebook Ads conversion tracking (Facebook, Inc.): Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Importify.
Additional information about Data collection and processing:
Legal action: The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Importify or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data:
Use of information.
Allow the use of various services on the site and App.
Improve and enrich the services and content offered on the site.
Modify or cancel existing services and content.
To match the ads displayed when you visit the site to your interests.
Contacting the User: By filling in the contact form with their Data, the User authorizes Importify to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.
Mailing list or newsletter: By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Importify. Your email address might also be added to this list as a result of signing up to Importify or after making a purchase.
Managing contacts and sending messages: This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
SendFox: SendFox is an email address management and message sending service provided by Sumo Group Inc.
AdRoll (Semantic Sugar, Inc.): AdRoll is an advertising service provided by Semantic Sugar, Inc.
Importify wishes to send you occasional e-mail information regarding the services it provides as well as marketing and advertising information.
Such information will be sent to you only if you have given you express consent, and you may at any time withdraw your consent and cease receiving it. Please note that when registering on the Site you agree to the mailing, which you may cancel as stated in this section.
Importify will provide your personal information to advertisers according to section 10 below, and may pass statistical information about the user’s activity on the site.
Statistical information will not be personally identifiable.
Providing information to a third party.
Importify may transfer to third parties your personal information and the information collected about your activity on the site at its sole discretion and in the following cases:
When the transfer of the specific information is necessary for the completion of the service process, which was performed by you within the framework of Importify, from a third party.
In the event of a legal dispute between you and Importify that will require disclosure of your details.
If the user perform illegal actions on the Site.
If a judicial order is issued instructing you to give your details or information about the user to a third party.
Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.
Modern browsers include the option of avoiding cookies. If you do not know how to do this, check the browser help file you’re using.
Advertisements by third parties.
Third-party disclosure: We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential.
Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Importify implements updated information security systems and procedures. While these systems and procedures reduce the risks of unauthorized penetration, they do not provide absolute security. Therefore, Importify does not undertake that its services will be completely immune from unauthorized access to the information stored therein.
System logs and maintenance.
For operation and maintenance purposes, Importify and any third-party services may collect files that record interaction with Importify (System logs) use other Personal Data (such as the IP Address) for this purpose.
The right to review, delete or amend the information.
According to the Protection of Privacy Law, any person is entitled to review the information about him in a database. A person who has examined the information on it and found that it is incorrect, complete, clear or up to date may contact the owner of the database with a request to amend the information or to erase it.
Particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights:
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Importify does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Such a request should be addressed to Importify by email: Support@importify.com.
In addition, if the information in the Importify repositories is used for personal contact with the user, the user is entitled under the Protection of Privacy Law, 5741-1981 to require in writing that the information relating there to be deleted from the database.
Importify may make changes, not material, to this Policy or its appendices at any time and without having to give notice thereof in advance, and these changes will be applied immediately. It is the user responsibility to check from time to time the changes on this Policy. In the event that material changes are made to this policy regarding the use of the personal information provided, they will apply 14 days from published.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 9, 2023