Personal Data Policy Statement

(“Privacy Policy”)

Car Boss Limited (“Company”) pledges to meet fully

with the requirements of the Personal Data (Privacy)

Ordinance, Chapter 486 of the Laws of Hong Kong. In doing

so, the Company will ensure compliance by its staff to the

strictest standards of security and confidentiality in respect

of all personal information and data submitted by users via

http://www.carboss.com and the Company will not

release such information to anyone without the prior consent

of the relevant user(s) of the Sites (whether registered or

not) (“User(s)”) except to the authorized persons listed

hereinafter.

Users are strongly recommended to read this Privacy Policy

carefully to have an understanding of the Company’s policy

and practices with regard to the treatment of personal

information and data provided by the Users on the Sites.

This Privacy Policy is applicable to both registered and non-

registered Users, and the provisions herein may be

updated, revised, varied and/or amended from time to time

as the Company deems necessary.

If Users have questions or concerns regarding this Privacy

Policy, they should first contact the of the Company's

Customer Service Department at +852 61336777 or email

to info@carboss.com.hk

Purpose of Collection of Personal

Data

In the course of using the Sites, Users may disclose or be

asked to provide personal information and/or data. In order

to have the benefit of and enjoy various services offered by

the Sites, it may be necessary for Users to provide the

Company with their personal information and/or data.

Although Users are not obliged to provide the information

and/or data as requested on the Sites, the Company will not

be able to render certain services on the Sites in the event

that Users fail to do so.

The Company’s purposes for collection of information and

data on the Sites include but not limited to the following:

for the daily operation of the services provided to Users;

to identify Users who have posted advertisements,

materials, messages, photos, views or comments or such

other information (collectively “Information”) on the Sites;

to identify Users who have viewed the Information posted on

the Sites;

to provide Users with marketing and promotional materials

for their enjoyment of benefits as members of the Sites (for

further details, please refer to paragraph 4 headed

“Subscription of Newsletter/Promotional Materials/Marketing

Materials” below);

to identify Users who have enjoyed their benefits as

members of the Sites by receiving and using marketing and

promotional materials;

to provide Users with a platform and forum for posting

photos, sharing and discussing their insights in respect of

services or products related to cars and driving;

to allow members of the Sites to enjoy their benefits as

members by enrolling for special events hosted by the

Company and/or its affiliates;

to design and provide products and services to Users in

relation to the above purposes;

to compile aggregate statistics about the Users and to

analyze the Sites and service usage for the Company’s

internal use; and

to facilitate the Company and/or its affiliates to use the

Users’ personal data for purposes relating to the provision of

services offered by the Company and marketing services,

special events and/or promotions of the Company, its

affiliates and/or their respective clients.

If the User is under the age of 13, the Company would

strongly recommend him/her to seek prior consent from a

person with parental responsibility for him/her, e.g. parent or

guardian, who may contact the responsible personnel of the

Company at info@carboss.com.hk for registering the User

as member of the Sites.

The Company strives to only collect personal data which are

necessary and adequate but not excessive in relation to the

purposes set out here in above.

If the Company requires the use of Users’ personal data for

a purpose other than those set out here in above, the

Company may request the Users’ prescribed consent to the

same. If User is a minor, the prescribed consent should be

given by his/her parent or guardian.

Collection of Personal Data

The Company may collect personal information and/or data

about a User such as his/her name, log-in ID and password,

address, email address, phone number, age, sex, date of

birth, country of residence, nationality, education level and

work experience that is/are not otherwise publicly available.

Occasionally, the Company may also collect additional

personal information and/or data from a User in connection

with contests, surveys, or special offers. In addition to the

data above mentioned, Car Boss Limited will collect the

information and/or data as follows:

Payment Information:

The company collects user’s personal payment information,

including information stored on outside services that user

may use with The company. By submitting user’s payment

information and/or linking user’s Car Boss Limited account with

an outside payment service, users authorize the company to access and use this information in order to provide user with

and accept payment for the Service. This allows us to both

confirm user’s identity and provide user with seamless,

hassle-free transactions. User can check the current fees,

fines, and penalties applicable to use of our Service in our

Fee and Commission Schedule.

Driver's Record:

We check user's driver's record to make sure user and

user's car meet Car Boss Limited safety standards. By

registering with the company user authorize us to access

user’s driver's record from Hong Kong Police Department,

and other applicable entities. Users also authorize said

entities to release this information to the company. The

company’s authorization to check users’ records is ongoing

throughout the time user use our Service.

Vehicle History and Inspection:

If user owns a vehicle that is used on the Site, we will

inspect the vehicle and obtain a vehicle history report to

make sure the vehicle is safe for user and other drivers to

use. By registering with Car Boss Limited, users authorize us to

obtain this information and user authorizes applicable

entities such as Hong Kong Police Department, inspection

companies and auto mechanics to release such information

to the Company.

Data Gathered from In-Vehicle

Hardware:

The telematics box installed in each Car Boss Limited allows

the company to gather information about user’s vehicle use,

including time of use, location, speed of travel, and other

aspects of user’s vehicle use. The company uses this

information 1) to provide users with the Service 2) to

aggregate user’s use habits and potentially provide user

with related benefits such as better insurance rates or other

perks for safe driving 3) to record vehicle movements and

driver behavior in case of an accident or theft 4) to

aggregate user’s data with other drivers' data and better

understand how people use our Service and how we can

make it even better for user in the future.

Location Tracking:

The location of all Car Boss Limited’s user use is tracked by

GPS and conveyed to Car Boss Limited. Location information is

tracked by the vehicle's telematics box. The company will

never use this information to make user’s location or

movements public without user’s permission. As a car

Owner, user can control when and where other

Car Boss Limited users can see the location of user’s car while

parked. If users are renting a car, the Owner of the car may

be able to see the location of the rented car. Other than that,

other Users will not be able to see user’s movements in a

Car Boss Limited.

The company monitors all cars to prevent theft, and to allow

us to locate user in case of accident, emergency, lock-out,

etc. User’s location information will only be used in direct

relation to Car Boss Limited business, and may be released to

insurance companies, the police, or similar parties in the

due course of investigating and processing accident claims,

and providing user with help in the case of an emergency or

lock-out.

Only duly authorized staff of the Company will be permitted

to access the Users’ personal information and data, and the

Company shall not release such personal information and

data to any third parties save and except for the

circumstances listed out under the Paragraph 3. entitled

“Disclosure or Transfer of Data”.

Disclosure or Transfer of Data

The Company agrees to take all practicable steps to keep

all personal information and data of Users confidential and/

or undisclosed, subject to the following.

Generally speaking, the Company will only disclose and/or

transfer Users’ personal information and/or data to the

Company’s personnel and staff for the purpose of providing

services to Users. However, the Company may disclose

and/or transfer such information and/or data to third parties

under the following circumstances:

where the information and/or data is disclosed and/or

transferred to any third party suppliers or external service

providers who have been duly authorized by the Company

to use such information and/or data and who will facilitate

the services on the Sites, under a duty of confidentiality;

where the information and/or data is disclosed and/or

transferred to any agents, affiliates or associates of the

Company who have been duly authorized by the Company

to use such information and/or data;

where the Company needs to protect and defend its rights

and property;

where the Company considers necessary to do so in order

to comply with the applicable laws and regulations, including

without limitation compliance with a judicial proceeding,

court order, or legal process served on the Sites; and

where the Company deems necessary in order to maintain

and improve the services on the Sites.

Personal data collected via the Sites may be transferred,

stored and processed in any country in which the Company

or its affiliates operate. By using the Sites, Users are

deemed to have agreed to, consented to and authorized the

Company to disclose and/or transfer their personal

information and data under the circumstances stated above,

as well as to any transfer of information (including the

Information) outside of the Users’ country.

Subscription of Newsletter/

Promotional Materials/Marketing

Materials

The Company and its affiliates may from time to time send

to members and Users of the Sites newsletters, promotional

materials and marketing materials based on the personal

information and data that they have provided to the

Company. The Company may use Users’ data in direct

marketing and the Company requires the Users’ consent

(which includes an indication of no objection) for that

purpose. In this connection, please note that:

the name, log-in ID and password, contact details, age, sex,

date of birth, country of residence, nationality, education

level and work experience of Users held by the Company

from time to time may be used by the Company and/or its

authorized personnel or staff in direct marketing;

the following classes of services, products and subjects may

be marketed:

food and beverage related products and services;

travelling related products and services;

special events hosted by the Company and its affiliates for

members and Users, including but not limited to courses,

workshops, and competitions;

reward, loyalty or privileges programmes and related

products and services;

special offers including coupons, discounts, group purchase

offers and promotional campaigns;

products and services offered by the Company’s affiliates

and advertisers (the names of such affiliates and advertisers

can be found in the relevant advertisements and/or

promotional or marketing materials for the relevant products

and services, as the case may be);

donations and contributions for charitable and/or non-profit

making purposes;

The above products, services and subjects may be provided

or (in the case of donations and contributions) solicited by

the Company and/or:

the Company’s affiliates;

third party service providers providing the products, services

and subjects listed in paragraph (b) above; and

charitable or non-profit marking organizations;

in addition to marketing the above services, products and

subject itself, the Company also intends to provide the data

described in paragraph (b) above to all or any of the

persons described in paragraph (c) above for use by them in

marketing those services, products and subjects, and the

Company requires the Users’ written consent (which

includes an indication of no objection) for that purpose;

the Company may receive money or other property in return

for providing the data to the other persons in paragraph (d)

above and, when requesting the Users’ written consent as

described in paragraph (d) above, the Company will inform

the Users if the Company receives any money or other

property in return for providing the data to the other persons.

Suitable measures are implemented to make available to

such members the options to “opt-out” of receiving such

materials. In this regard, Users may choose to sign up or

unsubscribe for such materials by logging into the

registration or user account maintenance webpage, or

clicking on the automatic link appearing in each newsletter/

message, or contact the Customer Service Representative

of the Company at +852 61336777 or email to

info@carboss.com.hk

Access

Any User is entitled to request access to or make

amendments to his/her own personal information and data

kept with the Company by contacting the Customer Service

Representative of the Company at +852 61336777 or email

to info@carboss.com.

In the event that a User wishes to access or amend his/her

personal information and data, the Company may request

him/her to provide personal details in order to verify and

confirm his/her identity. HKID card number or passport

number or business registration certificate number cannot

be amended unless such data is proved to be inaccurate.

The Company is required to respond to a User’s requests

within 40 days of his/her request and will endeavor to do so

wherever possible.

Cookies and Log Files

The Company does not collect any personally identifiable

information from any Users whilst they visit and browse the

Sites, save and except where such information of the Users

is expressly requested. When Users access the Sites, the

Company records their visits only and do not collect their

personal information or data. The Sites’ server software will

also record the domain name server address and track the

pages the Users visit and store such information in

“cookies”, and gather and store information like internet

protocol (IP) addresses, browser type, referring/exit pages,

operating system, date/time stamp, and clickstream data in

log files. All these are done without the Users being aware

that they are occurring.

The Company does not link the information and data

automatically collected in the above manner to any

personally identifiable information. The Company generally

uses such automatically collected information and data to

estimate the audience size of the Sites, gauge the popularity

of various parts of the Sites, track Users’ movements and

number of entries in the Company’s promotional activities

and special events, measure Users’ traffic patterns and

administer the Sites. Such automatically collected

information and data will not be disclosed save and except

in accordance with the Paragraph 3 entitled “Disclosure or

Transfer of Data”.

Links to Other websites

The Sites may provide links to other websites which are not

owned or controlled by the Company. Personal information

and data from Users may be collected on these other

websites when Users visit such websites and make use of

the services provided therein. Where and when Users

decide to click on any advertisement or hyperlink on the

Sites which grants Users access to another website, the

protection of Users’ personal information and data which are

deemed to be private and confidential may be exposed in

these other websites.

Non-registered Users who gain access to the Sites via their

accounts in online social networking tools (including but not

limited to Facebook) are deemed to have consented to the

terms of this Privacy Policy, and such Users’ personal data

which they have provided to those networking tools may be

obtained by the Company and be used by the Company and

its authorized persons in and outside of the User’s country

for the purpose of providing services and marketing

materials to the Users. These Users are deemed to have

consented to the Company and its authorized personnel’s

access and use of their personal data so obtained.

This Privacy Policy is only applicable to the Sites. Users are

reminded that this Privacy Policy grants no protection to

Users’ personal information and data that may be exposed

on websites other than the Sites, and the Company is not

responsible for the privacy practices of such other websites.

Users are strongly recommended to refer to the privacy

policy of such other websites.

Security

The security of Users’ personal information and data is

important to the Company. The Company will always strive

to ensure that Users’ personal information and data will be

protected against unauthorized access. The Company has

implemented appropriate electronic and managerial

measures in order to safeguard, protect and secure Users’

personal information and data.

All personal information and data provided by Users are

only accessible by the authorized personnel of the Company

or its authorized third parties, and such personnel shall be

instructed to observe the terms of this Privacy Policy when

accessing such personal information and data. Users may

rest assured that their personal information and data will

only be kept for as long as is necessary to fulfil the purpose

for which it is collected. Registered Users should safeguard

his/her unique Username and Password by keeping it secret

and confidential and never share these details with anyone.

The Company uses third party payment gateway service

providers to facilitate electronic transactions on the Sites.

PayDollar is a leading, secure and reliable international

payment service provider to banks and online merchants

since 2000. Customers' payment details are securely

transmitted to the acquiring bank, card and payment

companies for real-time transaction authorisation using 256-

bit Extended Validation Certificates (EV) SSL transaction

encryption. PayDollar supports CVV/CVC check as well as

3-D secure authentication of Visa and MasterCard namely:

Verified By VISA, MasterCard SecureCode for added

security protection for both customers and merchant.

The Company follows generally accepted industry standards

to protect the personal information and data submitted by

Users to the Sites, both during transmission and once the

Company receives it. However, no method of transmission

over the Internet, or method of electronic storage, is 100%

secure. Therefore, while the Company strives to protect

Users’ personal information and data against unauthorized

access, the Company cannot guarantee its absolute

security.

Retention of Personal Data

Once the Company has obtained a User’s personal

information and/or data, it will be maintained securely in the

Company’s system. Subject to legal requirements, the

personal information and/or data of Users will be retained by

the Company after deactivation of the relevant service until

the User requests the Company in writing to erase his/her

own personal information and/or data from the Company's

database or to terminate his/her membership of the Sites.

Changes in this Privacy Policy

The Company reserves the right to update, revise, modify or

amend this Privacy Policy in the following manner at any

time as the Company deems necessary and Users are

strongly recommended to review this Privacy Policy

frequently. If the Company decides to update, revise, modify

or amend this Privacy Policy, the Company will post those

changes to this webpage and/or other places the Company

deems appropriate so that Users would be aware of what

information the Company collects, how the Company uses

it, and under what circumstances, if any, the Company

discloses it.

If the Company makes material changes to this Privacy

Policy, the Company will notify Users on this webpage, by

email, or by means of a notice on the home page of the

Company.

For any query, please contact our Customer Service

Representative at +852 61336777 or email to

info@carboss.com.hk

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