EastPro Limited - Privacy Policy
Last Revised: March 1^st, 2018
EastPro Limited (“EastPro”, “we”, “us”, and “our”) is committed to the responsible handling of personal data and care about your privacy.  This Privacy Policy explains our privacy policy in connection with our website at eastprophoto.com and pages within such website and any equivalent, mirror, replacement, substitute or backup for such website (“Website”).
Under the Hong Kong Personal Data (Privacy) Ordinance, personal data means any data relating directly or indirectly to a living individual; from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and in a form in which access to or processing of the data is practicable. This Privacy Policy applies to personal data you may provide to us or that we may collect on this Website (“Data”).  As used in this Privacy Policy, the words “you” and “your” refer to you, the user of this Website, as the party agreeing to this Privacy Policy.
In addition to this Privacy Policy, we have established Terms of Use that set forth the general rules and policies governing your use of the Website. A copy of the Terms of Use can be found at the “Terms of Use” document.
Please note that the laws and regulations in different countries impose different (and even conflicting) requirements on the Internet and data protection. EastPro is located in Hong Kong and therefore the Hong Kong Personal Data (Privacy) Ordinance will apply. Any Data you provide will be used by Eastpro in Hong Kong or as otherwise provided in this Privacy Policy.

1.     Your Consent
By using this Website or providing us with your Data, you expressly consent to, and authorize, the collection, use and disclosure of your Data by us as described in our Personal Information Collection Statement and our current Privacy Policy as posted here, or as may otherwise be described at the time of collection. If you do not agree with any term of this Privacy Policy, please do not use this Website nor provide any Data to us.
You may withdraw your consent to our collection, use and disclosure of your Data at any time, as provided in this Privacy Policy. Note that if you withdraw your consent to certain uses of your Data, we may no longer be able to provide you with certain of our products or services.
You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use this Website or provide us with your Data. Regardless of where we use your information, we still protect your information in the manner described in this Privacy Policy.

2.     Collection of Personal Data/Information
In general, you can visit this Website without identifying yourself or revealing any of your Data. There are times, however, that you may choose to give us your Data.
We may ask you to provide personal data such as your name, address, phone number, email address, user name and password, profile picture, country, and information about your photography experience and preferences. 
If you sell or purchase something from us, we may collect payment information, such as your payee name and other information necessary for us to process the transaction. Your credit card information may be required for effecting payment through AsiaPay, PayPal or AliPay.  However, such credit card information will NOT be stored by us and will be held by the relevant online payment systems.
We also collect Data from you when you register as a member and from time to time when you:
 
·       send photos to us,
·       apply for a license to use photos,
·       display photos or products for sale or licence,
·       purchase photos, products or services from us,
·       join our courses, classes, trips or tours
·       participate in our competitions, contests, giveaways, sweepstakes, promotions or special programs,
·       put LIKE, or follow a photographer,
·       sign up to receive email from us, open or respond to our emails, visit any page online that displays our ads or content,
·       use our Website, or
·       in other circumstances with your consent, or where permitted or required by law.
We may collect certain Data when you connect with us through social networking sites or applications or other public forums (such as chat rooms, discussion boards or blogs) where you may be able to publicly post information or communicate with others. Please refer to the privacy policy and settings of the social networking site or application to determine whether and how you may adjust permissions and manage the interactivity between us and the social networking account or application. The protections described in this Privacy Policy do not apply when you provide information (including your Data) in connection with your use of these social networking sites or applications or other public forums. All the information you post on such sites or applications may be accessible to anyone with Internet access, and any Data you include in your posting may be read, collected and used by others. Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy.
Our servers and other technologies automatically collect and store certain information to help us administer, compute, protect, analyze, and improve our services and user experience.  We share your Data with others only as described in this Privacy Policy, or as required by applicable law.

3.     Cookies or Other Tracking Technologies
When you visit this Website, we may automatically collect information such as what type of browser you use, the third-party web site from which your visit originated, the search terms you use on this Website, the specific web pages you visit on this Website and the duration of your visits, your IP address (a number that is assigned to your computer automatically when you use the Internet) or information about your computer. We may then link this information to you for the purposes described in this Privacy Policy and, if your identity can be directly or indirectly ascertained from this information, it will also be considered your Data.  We may also collect IP addresses for the purposes of systems administration (e.g., how many visitors logged in to this Website).
The use of Cookies and other tracking technologies is standard across websites and apps through which information is collected about your online activities.  When you visit our Website eastprophoto.com, we may use cookie files to store and track information about your Data or your actions for the purposes of providing our services to you.  EastPro and our third-party providers set and use cookies and similar technologies to store and manage user preferences, deliver advertising, enable content, and gather analytic and usage data.
Most web browsers are initially set up to accept cookies.  You can choose to ‘not accept’ cookies by changing the settings but if you do so you may find that certain features on the website, including online banking, may not work properly.
EastPro may allow third party ad servers (i.e., third parties that provide technology to place ads on web sites and track ad performance) to use Cookies, pixel tags and other technologies to automatically collect information about your visit to this Website or to place our ads on third-party sites and to analyze the effectiveness of those ads.

4.     Storage, Keeping and Security of Personal Data
We use third parties such as data storage server, cloud hosting services, suppliers, and technology support located around the world to serve the needs of EastPro and its members.  In some cases, we may need to disclose or transfer your Data to third parties in areas outside of Hong Kong.  Such places may not have the same level of data protection as Hong Kong and you hereby expressly consent to EastPro transmitting your Data as detailed in this Privacy Policy. 
We take appropriate steps both internally and through our third-party vendors to ensure that personal data is processed and transferred in a secured manner.  We also secure personal data against loss, unauthorized access, or use, according to applicable law.  We may establish and maintain a file of your Data for the purposes described in this Privacy Policy, which will be accessible at our offices. Authorized employees and agents who require access to your Data in order to fulfil their job requirements will have access to your Data.
Please be aware that despite our efforts, no data security measures are 100% secure at all times. Therefore, EastPro cannot guarantee that your Data is under absolute security with the existing security technology.  If you have any questions about the security of our Website, you can contact us at info@easetprophoto.com.
 
We DO NOT STORE ANY CREDIT CARD information.
 
We will retain your Data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  

5.     Our use of your Personal Data
We use your Data for the following photography platform and services purposes:
 
·       Set-up and administration of EastPro membership accounts
·       Listing your licensed photo and products
·       Processing your purchase order
·      Processing payments for stock photo sell and dues, second hand cameras and lenses sell and dues, photography class or trip, or other products or services
·       Photography administration, such as gallery and stock photo sections, keeping of membership levels, number of LIKEs, members following, and tracking dues payments
·       Delivering marketing and events communications to you across various platforms, such as email, telephone, text messaging, social media, mobile devices, smart phones, apps, and online.  If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future.  For apps, you may turn off the alert or notification.
·       We may use personal information to meet our audit requirements, security purposes, respond to requests from law enforcement agencies, and to protect our rights and safety.  We may be required to use and retain personal data for legal and compliance reasons, such as the prevention, or investigation of a crime, loss prevention, or fraud
·       Help us improve our services to you
·       For internal statistical, marketing or operational purposes, such as to measure and understand demographic, user, user interest, purchasing and other trends among our users
·       Respond to your questions
·      Investigate, prevent, defend against or take other action regarding violations of this Privacy Policy or the Terms of Use, illegal activities, suspected fraud or situations involving potential threats to the legal rights of us or others
·       Comply with applicable laws and regulations;
·       For any other purposes for which we notify you specifically at the time of collection or as otherwise described in this Privacy Policy or as permitted or required by law, rule, regulation, subpoena or other legal process.
We will not use your Data for direct marketing purposes unless with your consent.

6.     Disclosure, Sharing and Transfer of Personal Data
EastPro shares or discloses your Data when necessary to provide services to members or conduct our operations as described below.  When we share your Data, we do so in accordance with this Privacy Policy and applicable laws and regulations.  Below are the parties with whom we may share your Data and why.
·       Our third-party service providers: We partner with and are supported by third party hosting companies and service providers.  Your Data will be made available to these parties only when necessary to fulfill the services they provide to us, such as hosting our server, data management for processing and maintaining your Data, software, system, platform support, storage, cloud hosting services, direct marketing services, advertising, data analytics, and order fulfillments and delivery.  Our third-party service providers are not permitted to share or use your Data that we make available to them for any other purpose than to provide services to us.
·       Our business partners: We may partner with other organizations to provide more opportunities for you to sell or purchase products or services.  If so, our affiliates will be announced on our Website.  As part of these arrangements, you may be a customer of both EastPro and our partners, and we and our partners may collect and share Data about you.  EastPro will handle your Data in accordance with this Privacy Policy, and we encourage you to review the privacy policy of our partners to learn more about how they collect, use, and share personal information.
·       Legal obligations: as requested from government agencies, including law enforcement and other public authorities, which may include authorities outside of Hong Kong. 
·       Security and safety – To project our rights, users, members, systems, and services.
 
If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, your Data and other information concerning your relationship with us. Such third parties will assume responsibility for the information and your Data collected by us in connection with our business operations or through this Website and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.

7.     Privacy Protection for Children
In compliance with applicable laws and regulations, we do not intend that portions of this Website that require provision of personal data will be accessed or used by persons under the age of eighteen (18). This Website is designed and intended for adults. If we later learn that any registrant is under the age of eighteen (18), we will take appropriate steps to remove that registrant’s information from our database. We will not knowingly collect or use any personal data from children we know to be under the age of eighteen (18) without obtaining express parental consent.

8.     Links to Other Web Sites and Social Networks
From time to time, this Website may contain links to and may be used by you in conjunction with third-party apps, services, and other websites that are not affiliated with, controlled, or managed by us or other web sites that are operated by us or our affiliates but are subject to separate privacy policies. If you use these links, you will leave this Website. The privacy policies of such other web sites govern the information collection, use and dissemination practices occurring on such web sites. You should read the privacy statements and terms and conditions of linked or referenced sites you enter. These third party web sites may send their own Cookies and other tracking devices to you, log your IP address and otherwise collect data or solicit personal information.
We do not have control over, and is not responsible for what third parties do in connection with their websites, or how they handle your Data. Accordingly, this Privacy Policy only applies to us and our Website and does not cover the collection methods or use of the information collected by third party ad-servers and third party websites, and EastPro is not responsible for these websites, the activities and practices that take place on these websites or the relevant associated privacy policies.  We encourage you to review the privacy policies or statements of these third party advertising companies and websites for further information.
 
Our websites or apps or electronic mailings may also include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive programs.  If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services.  These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly.  We are not responsible for the security or privacy of any information collected by these third parties, so please review the privacy statements or policies applicable to the third-party services you connect to use.  You may choose to not connect your social media account with EastPro.

9.     Notification of changes
EastPro may revise this Privacy Policy at any time and from time to time by updating this posting. You should visit this page from time to time to review the then-current Privacy Policy because it is binding on you. We may also email you about material changes. You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on this Website and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy.

10.   Access to or Correction of Personal Data
We respect your right to access and control your information.  You may contact us if you: (a) have any questions or comments about our Privacy Policy; (b) wish to be provided with access to the Data that we have collected about you; (c) wish to make amendments or corrections to any Data you have provided to us; (d) want to opt-out from receiving future commercial correspondence, including emails, from us; or (e) wish to withdraw your consent to sharing your Data with others.  You may revise your account information on our Website or you may contact our Privacy Officer at info@eastprophoto.com with any requests related to your Data.
Your right to access or correct your Data is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.  Depending on the scope of your data access request, we may impose a reasonable administrative fee for complying with such a request. 

11.   Governing Law and Jurisdiction
This Privacy Policy and any contract or agreement with EastPro concluded in accordance with this Privacy Policy is governed and construed in accordance with the laws of Hong Kong Special Administrative Region (“Hong Kong”), without application of conflict of laws rules.  
Any dispute arising directly or indirectly, interpretation, or enforcement of the Privacy Policy will be submitted to the exclusive jurisdiction of the Courts of Hong Kong.

12.   About Payment Security
Contact Us
We understand that you may have questions or concerns about this Privacy Policy or may wish to file a complaint.  Please feel free to contact us at info@eastprophoto.com