Welcome to OAO Limited (“OAO,” “we,” “us,” or “our”). We are committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) describes how OAO collects, uses, processes, and discloses your personal data (as defined below) when you interact with us through our websites, applications, products, and services (collectively, the “Services”), including but not limited to our GIMII platform.
By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, please do not use the Services.
This Policy applies to:
Additional privacy notices may apply to certain specific features or regions. Where those notices conflict with this Policy, they will supersede this Policy for the specific scenario covered.
Account Information
When you create an account, we may collect your name, email address, password, billing information (if applicable), date of birth (where required), or other information you choose to provide.
Content and Communications
If you communicate with us (e.g., via email, chat support, or social media), we collect the content of your communication, contact details, and any other information you provide.
If you upload or submit files, images, or other data via the Services, those files may contain Personal Data.
Feedback or Survey Responses
We may collect feedback, suggestions, or testimonials you choose to provide about our Services.
Technical Information
Log data: Internet Protocol (IP) address, device type, operating system, browser type, time zone, and timestamps of interactions with our Services.
Usage data: Actions you take in the Services, pages viewed, features used, and in-app events.
Device and Location
We may infer an approximate location based on your IP address for service performance, analytics, or security purposes.
If you opt in, we may collect precise geolocation data from your mobile device to enable certain features.
Cookies and Similar Technologies
We use cookies, beacons, and similar tracking technologies to remember preferences and enhance user experience. For more details, see Section 12 (Cookies and Tracking Technologies).
Service Providers and Partners
We may receive data from payment processors, analytics providers, social media networks (if you link your account), or marketing vendors.
Publicly Available Sources
We may collect publicly available information from the internet for research and product development (e.g., training AI models), as permitted by law.
We use Personal Data for the following purposes:
Providing and Improving the Services
Operate, maintain, and enhance our Services, including debugging and technical support.
Account Management
Create and manage user accounts, authenticate logins, and verify user identity.
Communication
Send administrative or service-related communications (e.g., changes in terms, product updates).
Respond to inquiries, provide customer support, or notify you of relevant information regarding your use of the Services.
Development and Research
Develop and improve existing and new products, features, or functionalities, including through machine learning or AI model training (in accordance with user controls or applicable law).
Analytics and Personalization
Understand how users interact with our Services, personalize content, and optimize user experience.
Security and Fraud Prevention
Detect, prevent, and address potential security issues, misuse, fraud, and illegal activities.
Legal and Regulatory
Comply with applicable legal requirements, enforce our Terms of Use, and protect the rights, property, or safety of OAO, our users, or the public.
Where required by law, we rely on one or more lawful bases to process Personal Data, such as your consent, performance of a contract, compliance with a legal obligation, or our legitimate interests.
We may share your Personal Data in the following circumstances:
Service Providers
We engage third-party companies or individuals to provide services on our behalf, such as hosting, payment processing, analytics, email delivery, or customer support. These service providers access and process Personal Data only as directed by us, under obligations of confidentiality.
Affiliates
We may share your Personal Data with subsidiaries or affiliates within the OAO corporate group for internal business purposes, subject to strict confidentiality obligations.
Business Transfers
If we are involved in a merger, acquisition, asset sale, restructuring, bankruptcy, or other corporate transaction, Personal Data may be transferred to a successor or affiliate as part of that transaction.
Legal and Compliance
We may disclose Personal Data when required to do so by law or if we believe in good faith that such disclosure is necessary to (a) comply with legal obligations, (b) protect our rights, property, or safety, or that of our users or the public, or (c) detect, prevent, or address fraud or security issues.
Enterprise Account Administrators
If your account is associated with an enterprise or institutional subscription, your account details, usage data, or uploaded content may be accessible by administrators of that enterprise account.
Consent
We may share your Personal Data with third parties if you give us explicit permission to do so.
OAO is headquartered in Hong Kong but operates globally. Accordingly, your Personal Data may be transferred and stored outside your country of residence, including in countries that may not have equivalent data protection laws. Where required by applicable law, we use legally approved transfer mechanisms (such as Standard Contractual Clauses) to ensure the adequate protection of your Personal Data.
We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine our retention periods include:
After expiry of the retention period, we will securely destroy or anonymize your Personal Data.
Depending on where you reside, you may have certain rights regarding your Personal Data:
Access
Request confirmation on whether we process your Personal Data and obtain a copy of that data.
Rectification
Request correction of inaccurate or incomplete Personal Data.
Erasure (“Right to be Forgotten”)
In certain circumstances, request the deletion of your Personal Data.
Restriction
Ask us to limit the processing of your Personal Data under specific conditions.
Objection
In some cases, object to our processing of your Personal Data, including for direct marketing or when based on legitimate interests.
Data Portability
Request a copy of your Personal Data in a structured, machine-readable format.
Withdraw Consent
If we rely on your consent to process Personal Data, you have the right to withdraw your consent at any time.
To exercise these rights, please contact us at info@oaohk.com. We may require you to provide additional information to verify your identity and, in certain jurisdictions, we may refuse requests that are unlawful or excessive.
Our Services are not directed to children under 13 years of age (or other age as required by local law). We do not knowingly collect or solicit Personal Data from children under 13. If you believe that a child under 13 has provided us with Personal Data, please contact us, and we will take steps to delete such data.
We implement technical and organizational measures designed to protect Personal Data from unauthorized access, loss, misuse, alteration, or destruction. These measures include:
However, no security system is impenetrable, and we cannot guarantee the complete security of our databases nor that information you provide will not be intercepted while in transit over the Internet.
We and our partners use cookies, beacons, and similar technologies to:
You can typically modify your browser setting to refuse some or all cookies. Note that refusing cookies may affect certain features of the Services.
Our Services may include links to third-party websites or services that we do not control. This Policy does not apply to the information practices of those third-party sites or services. We encourage you to review their privacy policies carefully, as their practices may differ from ours.
If you are a resident of California (or other U.S. states with specific privacy laws), you may have additional rights regarding your “personal information.” We will comply with applicable privacy laws, including the California Consumer Privacy Act (as amended by the CPRA), and provide supplemental notices describing your rights when required. Please contact us at info@oaohk.com for details.
We may modify this Policy from time to time. If we make material changes, we will provide you with notice (e.g., by email or a prominent notice in the Services) before those changes become effective. The date at the top of this Policy indicates when it was last updated. Your continued use of the Services after any changes indicates your acceptance of the updated Policy.
If you have any questions, concerns, or comments about this Privacy Policy or our data practices, please contact us at:
OAO Limited
Attn: Privacy Team / Legal Department
Unit C, 4/F, China Insurance Bldg., 48 Cameron Road
Tsim Sha Tsui, Kowloon, H.K.
Email: info@oaohk.com
We will do our best to respond in a timely and efficient manner.