Privacy Policy

1. Introduction

This Privacy Policy ("Policy") sets out how 99 HP Tech Limited ("we", "our", "us"), a company incorporated in Hong Kong and operator of pricempire.com, collects, uses, stores, and discloses personal data. We are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and, where applicable, the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK GDPR, and other relevant laws. Depending on your country of incorporation or residency there may be other data protection legislation applicable to you.

The term "Personal Information" in this Privacy Policy refers to personal data as defined under the GDPR and GDPR UK, 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Your use of pricempire.com constitutes your acknowledgment that you have read and understood this Policy.

2. Categories of Personal Data Collected

Certain categories of personal information we collect are deemed sensitive data, such as biometric information or financial account information. pricempire.com would obtain consent prior to collecting this category of personal information.

In order to provide our services to you, we may collect, hold and process some or all the following personal data:

We may also collect information about you from affiliates (by 'affiliates' we mean other companies that pricempire.com has a contractual relationship with) who provide us with services such as 'name screening' and biometric data (your image in a photo and video form, your voice (as part of our Know Your Client (KYC) checks. We may also make recordings of any video calls we hold with you) to help verify your identity which in turn allows us to improve the safety of our services. This includes being able to detect and respond quickly to any fraud or security risks.

pricempire.com our marketing partners, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer and track users' movements around websites and applications, and gather demographic information about pricempire.com user base, with respect to the following purposes:

• To assist pricempire.com in providing Services to you.
• To store your preferences and other information and to track activity on the pricempire.com platform.
• To better understand the effectiveness of pricempire.com promotional campaigns.
• To deliver information specific to your interests on additional web sites.

pricempire.com may receive individual as well as aggregated customer reports based on the use of these technologies by these partners or service providers.

3. Purposes of Processing

We process personal data for the following purposes:

• Account registration and administration, including but not limited to "Know Your Customer" and customer due diligence procedures, authentication, and management.
• Provision of services, including in-game item trading and marketplace operations.
• Payment processing and settlement.
• Compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) obligations.
• Fraud detection, prevention, and investigation.
• Marketing and promotional communications (subject to consent).
• Analytics, service improvement, and product development.

4. Legal Basis for Processing (where GDPR and GDPR UK are applicable)

We must have a legal basis (a valid legal reason) for using your personal data. Under GDPR and GDPR UK our legal basis will be one of the following:

• Performance of a contract with you.
• Compliance with legal obligations to which we are subject.
• Legitimate interests pursued by us or a third party, provided such interests are not overridden by your rights.
• Consent, where required by law (e.g., for marketing).

5. Does pricempire.com make automated decisions about me?

We may use automated systems to make decisions about you in connection with fraud prevention, anti-money laundering (AML), and counter-terrorist financing (CTF) obligations. These systems analyze transaction patterns, identity verification data, and other relevant information to detect suspicious activity and ensure compliance with applicable laws.

Where such decisions have a legal or similarly significant effect on you, you have the right to request human intervention, express your point of view, and contest the decision. You can do so by contacting us at privacy@pricempire.com.

Automated decision-making is essential to maintaining the integrity and security of our platform, and we apply safeguards to ensure fairness, accuracy, and transparency in these processes.

6. Third parties

pricempire.com may partner with a third party to either display advertising in the pricempire.com application or on the pricempire.com website, or to manage pricempire.com advertising on other sites. pricempire.com third party partners may use technologies such as cookies to gather information about your activities while using the application or website and other sites to provide you advertising based on your browsing activities and interests.

In addition, pricempire.com automatically gathers and stores in log files certain information, such as Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. pricempire.com does not link this automatically collected data to other information we collect about you. pricempire.com as well as our third-party partners may use local storage to store content information and preferences.

Our network infrastructure involves computers, cloud-based servers, and third-party service providers in multiple jurisdictions. The Personal Information that pricempire.com collects from you may be transferred to, and stored at, a destination outside of Hong Kong. It may also be processed by persons operating outside of Hong Kong on behalf of pricempire.com, our affiliate(s), or one of our service providers, providing transaction processing, payment detail verification, as well as other Services-related support.

We take commercially reasonable steps to protect your Personal Information in line with this Privacy Policy, whether it is handled inside or outside Hong Kong. Our Services may not be appropriate or available in all jurisdictions. By using the Services or providing your Personal Information, you agree that it may be transferred to, stored in, and processed in countries outside Hong Kong, which may have different data protection laws from your own.

7. Data Sharing and International Transfers

We may share personal data with:

• Third-party service providers under binding confidentiality agreements.
• Payment processors, banks, and financial institutions.
• Regulatory bodies, law enforcement agencies, and courts.
• Affiliates and subsidiaries.

Where data is transferred outside Hong Kong, we ensure appropriate safeguards are in place, such as contractual clauses or equivalent legal protections. If this is not possible, for example because we are required by law to disclose information, we will ensure the sharing of that information is lawful.

8. Personal Data Breach

If we become aware of a personal data breach, meaning any unauthorized access to, loss, or disclosure of personal data, we will assess the potential impact on your rights and freedoms. If the breach is likely to result in significant risk (whether physical, material, or non-material), we will notify the relevant data protection authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach.

If notification cannot be made within 72 hours, we will document the reasons for the delay and submit the notification as soon as possible thereafter. Where required by law, we will also inform affected individuals and provide details about the nature of the breach, the steps we are taking, and how they can protect themselves.

9. Data Retention

The amount and type of information collected by pricempire.com will be limited to that which is necessary to provide pricempire.com Services, and the information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected.

We retain personal data for as long as necessary to fulfil the purposes outlined in this Policy or as required by applicable law. For example, certain transaction records may be retained for at least five years to comply with PDPO and AML obligations.

10. Data Subject Rights

Subject to applicable law, you have the right to:

• Access your personal data.
• Request correction or deletion of your personal data.
• Object to processing or request restriction of processing.
• Withdraw consent at any time (where processing is based on consent).
• Request data portability.

Requests should be submitted to our Data Protection Officer (see Section 14).

11. Children's privacy

The platform, application, and Services are not directed at or intended for use by children under the age of 18. pricempire.com will not knowingly collect or maintain Personal Information from children under the age of 18. If we obtain actual knowledge that we have collected Personal Information from a child under the age of 18, we will promptly delete it, unless we are legally required to retain such information.

12. Security Measures

We implement technical and organizational measures to protect personal data, including:

• Encryption in transit and at rest.
• Secure storage systems.
• Access controls and authentication protocols.
• Regular security audits and monitoring.

13. Changes to This Policy

We may update this Policy from time to time. The latest version will be posted on pricempire.com with the effective date.

14. Contact Information