1 Your Privacy


As the Platform owner and operator, Company Limited (“The Company”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy and Personal Information Collection Statement (the “Statement”) explains our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China.


The Company believes the principles in the Ordinance offer no less protection in personal data privacy than those in other jurisdictions and so The Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations globally. For further information on The Company’s compliance with the Ordinance and any other privacy legislation, please contact our Personal Data Privacy Officer at the address or email below.


Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Statement applies to all registered and unregistered users for the accessing to and/or use of our service for discovering, viewing and watching motion pictures, television and other audio-visual entertainment streamed over the Internet to certain Internet-connected TVs, computers and other devices (collectively referred to as the “our Services”), and may from time to time be revised or otherwise changed where we deem necessary.


We will update this Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the services provided by The Company after any such updates take effect will constitute acceptance of those changes.


If there is any inconsistency between the English and Chinese version of this Statement, the English version shall prevail.


Throughout this Statement, the meaning of the term “personal data” is defined in the Ordinance.

2 Data Collection


We receive, collect and store information (such as your name, age, email address, telephone number, account details, payment details, information for the verification of identity including but not limited to device/browser information, operating system and IP address/domain) you provide to us including the information you enter or provide while:
  • (i) using or accessing to our Services;
  • (ii) contacting our customer service;
  • (iii) participating in surveys or marketing promotions;
  • (iv) providing reviews or ratings;
  • (v) entering your taste preference;
  • (vi) setting your account; or
  • (vii) otherwise providing information to us through our Services or elsewhere.


We also collect and store information automatically for the following information:
  • (i) your activities when using our Services;
  • (ii) all information regarding your contact with our customer services, whether by phone, through the emails or our websites, or otherwise;
  • (iii) Identification of your computer and device, device and software characteristics, connection information, statistics on page views, referral URLs, IP address and standard web log information.


We might also obtain information such as demographic data, interest based data, and Internet browsing behavior, from other sources to interpret or supplement the information above received, collected or stored, including from both online and offline data providers.

3 Web Logs and Cookies


When you use our Services, our server may track the pages you visit. We do these things so that we can measure traffic, take necessary actions in respect of any illegal, unlawful or otherwise wrongful contents, gauge the popularity of various parts of our Services, gain some general knowledge about our audience, and market the Services to advertisers with whom we may share summarized traffic data.


We also use cookies and other technologies (such as web beacons, also known as clear gifs or pixel tags) when providing our Services for various reasons such as to make it easy to access our Services by remembering you when you return, to provide and analyze our Services, to learn more about our users and their likely interests, and to deliver and tailor marketing or advertising.


We may use the following types of cookies:
  • (i) Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we may use these cookies to authenticate and identify our members when they use our websites and applications so we can provide our Services to them. They also help us to enforce our Terms of Service, prevent fraud and maintain the security of our Services.
  • (ii) Performance and functionality cookies: These cookies are not essential, but help us to personalize and enhance your online experience with The Company. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors’ use of the our Services so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies will result in limited functionality of our service.
  • (iii) Advertising cookies: These cookies use information about your visit to this and other websites, such as the pages you visit, your use of our Services or your response to ads and emails, to deliver ads that are more relevant to you. These types of ads are called “Interest-Based Advertising.”


The Company may also use other technologies that are similar to cookies, such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, some of these technologies may store small amounts of data on your device. We may use these and various other technologies for similar purposes as cookies. There are a number of ways to exercise choice regarding these technologies. For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser’s help function or support area to learn more.


The Company has implemented Google Analytics Advertising features based on Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting). Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings. The Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to your site.


If you do not wish to allow Google Analytics to use your data, you need to download the Google Analytics opt-out browser add-on here .


The information obtained through the above web logs, cookies, web beacons or Google Analytics mentioned under this paragraph 3 does not identify you as an individual.

4 Use of personal data


Amongst the information we receive, collect and store, it may contain your personal data. The purposes for which we may use your personal data are divided into obligatory purposes and voluntary purposes. If personal data is to be used for an obligatory purpose, you MUST provide your personal data to us if you want to use our Services. If personal data is only to be used for a voluntary purpose, you can tell us not to use your personal data for that purpose and we will not do so.


Purposes for which it is obligatory for you to provide your personal data are:
  • (i) verifying of your identity;
  • (ii) verifying your geographical location;
  • (iii) application, termination and continuation of the use of the our Services;
  • (iv) administration and management of the services which you have subscribed to, including the renewal of contracts;
  • (v) processing of any benefits or privileges to you in connection with our Services;
  • (vi) processing billing and payment including the use of debt collection agents;
  • (vii) determining your Internet service provider;
  • (viii) providing localized content, providing you with customized and personalized viewing recommendations for movies and TV shows;
  • (ix) communicating with you concerning our Services so that we can send you news and updates about The Company, details about new features and content available on The Company, and special offers, promotional announcements and consumer surveys;
  • (x) matching (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision and business planning of our Services;
  • (xi) to assist you and operate your user account with the our Services, such as your password reset requests;
  • (xii) to enable us to better understand the demographics of our users and audience; improving our services (including our user interface experiences), delivery optimization, content selection and recommendation algorithms;
  • (xiii) maintaining and developing our systems and infrastructure, including testing and upgrading;
  • (xiv) meeting the requirements to make disclosure as required by law;
  • (xv) preventing, detecting and investigating potentially prohibited or illegal activities, including fraud and crime, and enforcing our terms; and/or
  • (xvi) any other purposes as may be notified to you or agreed between you and The Company.


Purposes for which it is only voluntary for you to provide personal data are:
  • (i) our future marketing purposes and/or joint promotion with subsidiaries or third parties;
  • (ii) other promotions of our operations; and
  • (iii) for direct marketing of our products and services.


The Company honours your request not to use your personal data for the purpose of direct marketing. If you do not want us to use your personal data for the voluntary purposes listed above, kindly tick the “opt out” box when you register as a user or indicate your request in your profile. You can also at any time send your request to our [Personal Data Privacy Officer] (with sufficient identification information) to stop receiving the direct marketing materials or to start receiving the same if you have unsubscribed from receiving it before.


Any personal data supplied by you will be retained by The Company and will be accessible by our employees and third parties (as applicable) for the purposes set out in this Statement or as otherwise indicated by prior notice to you.


If you are under the age of 18 or the age of majority in your country of region, you must ask your parent or guardian before providing any personal data to us.

5 Disclosure of Personal Data


We will take all practicable steps to keep your personal data confidential but we may transfer/assign such data to the following parties for one or more purposes named in paragraph 4:
  • (i) any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with The Company;
  • (ii) any person, agent, contractor or third party service or content provider (including their professional advisers, such as their accountants, auditors and lawyers) who provides administrative, telecommunications, computer and other services to The Company in respect of the purpose or a directly related purpose for which the data was provided;
  • (iii) any other person or company who is under a duty of confidentiality to The Company and has undertaken to keep such information confidential, provided that such person or company has a legitimate right to such information;
  • (iv) any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureaux, or collection agencies, security agencies, necessary to establish and support the payment of any of our Services being requested;
  • (v) your authorized representatives or your legal advisers when requested by you to do so;
  • (vi) any person to whom The Company is under an obligation to make disclosure to
    • (a) satisfy any applicable law, regulation, legal process, or governmental request or any guidelines or codes of practice issued by regulatory or other authorities with which The Company is expected to comply,
    • (b) enforce applicable Terms of Service, including investigation of potential violations thereof,
    • (c) detect, prevent, or otherwise address fraud, security or technical issues,
    • (d) respond to user support requests, or
    • (e) protect against harm to the rights, property or safety of The Company, its users or the public, as required or permitted by law;
  • (vii) any party to whom The Company is under an obligation to make disclosure in connection with any reorganization, restructuring, merger or sale, or other transfer of assets;


Personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right/authority to access such information.


In addition, personal data may be disclosed under any of the circumstances as permitted by the Ordinance.


You should also be aware that you may disclose your information in the following ways:
  • (i) While using the our Services you will have opportunities to post reviews or other information publicly, and third parties could use the information you disclose;
  • (ii) Our services may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your smart device;
  • (iii) Social plugins (including those offered by Facebook, Twitter and Google etc) allow you to share information on those platforms. Social plugins and social applications are operated by the social network themselves, and are subject to their terms of use and privacy policies.


If you share or otherwise allow others to have access to your account, they will be able to see your information, including in some cases personal information, such as your watch history, ratings, reviews and account information (including your email address or other information in your account).

6 Transfer of Personal Data Outside Hong Kong


At times it may be necessary and/or prudent for The Company to transfer certain personal data to places outside the Hong Kong in order to carry out the purposes, or directly related purposes, for which the personal data were collected. By using our Services, you are deemed to consent to such transfer and where such a transfer is performed, it will be done in compliance with the prevailing requirements of the Ordinance.

7 Links to Other Third-party Application(s)


This Statement only applies to your use of our Services. If you click on any advertisement or hyperlink linking to other third-party application(s) (including, without limitation, websites, widgets, software, or other software utilities) (“third-party application(s)”), you will be directed to another location. At any other third-party application(s), the protection of your privacy, personal data and your exposure to cookies are not our responsibility and you are advised to refer to the privacy policy of that other location (if any).

8 Security of Personal Data


Upon registering or using our Services, we will endeavor to ensure that your personal data will be encrypted, transferred to a dedicated The Company server and stored electronically with password protection.


Except as mentioned under the subtitle “Disclosure” above, your personal data, however stored, will be accessed only on a “need to know” basis by our employees or contractors who are under a duty of confidentiality to The Company and are authorized to do so. Such authorized personnel of The Company or its relevant contractors designated to handle personal data will be instructed to do so only in accordance with this Statement.


We will use reasonable administrative, logical, physical and managerial measures to safeguard your personal data against loss, theft and unauthorized access, use and modification. But you should be aware that no systems or measures can be guaranteed to provide 100% security, especially no information provided over the Internet can be guaranteed to be completely secure.

9 Use of Personal Data in Legal Proceedings


If it becomes necessary that we have to take action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and take legal action against you.

10 Retention of Data


We will keep your personal data for as long as necessary to fulfill the purpose for which the data was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations.


Personal data which is no longer required will be destroyed.

11 Your Right to Access and Retention


You may at any time request access to and correct personal data relating to you in any of our records.


You may also ask us to delete you or your personal data from any active mailing or distribution list, if any.


To exercise any of your rights, contact our [Personal Data Privacy Officer] at the address or email below marking you communication “Confidential”. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days and we will endeavor to do so wherever possible, but we may charge you a reasonable fee for doing so.

12 Personal Data Privacy Officer


The person to whom (1) requests (a) for access to data or correction of data; (b) for general information regarding our policies and practices with respect to personal data; and (c) about the kinds of personal data that we hold; and (2) general questions and complaints should be addressed is as follows:- Company Limited
Personal Data Privacy Officer
(Marked Confidential)
Address: Unit 521, InnoCentre, 72 Tat Chee Avenue, Kowloon Tong, Hong Kong
Email: [email protected]