PortfoPlus - Know Your Coverage

PRIVACY POLICY

Last Updated: 18 March, 2025

1. INTRODUCTION

PortfoPlus Limited ("PortfoPlus", "we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it. This privacy policy specifically addresses our obligations in respect of personal data privacy under the Personal Data (Privacy) Ordinance of Hong Kong SAR, Chapter 486 of the Laws of Hong Kong SAR (the "Ordinance").

BY USING PORTFOPLUS WEBSITE OR MOBILE APPLICATION (collectively, “PortfoPlus” OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. Do not use PortfoPlus or give us any of your information if you do not agree to the terms of this privacy policy. However, we will not be able to render certain services to you if you do not provide such information about you to us.

2. INFORMATION WE COLLECT

2.1 Types of Information Collected

In order to provide our services, we may collect and process the following data about you:

a) Account and Profile Information: Information that you provide when registering to use our site (app.portfoplus.com) and/or mobile application, subscribing to our service, posting material, or requesting further services. This includes your name, email address, contact details, and professional information.

b) Communications: If you contact us, we may keep a record of that correspondence.

c) Survey Responses: We may ask you to complete surveys for research purposes, although you do not have to respond to them.

d) Transaction Data: Details of transactions you carry out through our site and/or mobile application and of the fulfillment of your orders.

e) Usage Information: Details of your visits to our site and/or mobile application, and the resources that you access, including, but not limited to, traffic data, location data, and other communication data.

f) Device Information: Information about your computer, mobile device, or other device that you use to access our service, including IP address, browser type, and operating system.

2.2 Data Retention

We only retain personal data for as long as is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and applicable legal requirements.

3. HOW WE USE YOUR INFORMATION

3.1 General Use of Information

The purposes for which your information may be used by us in and outside Hong Kong include:

a) To ensure that content from our site and/or mobile application are presented in the most effective manner for you and for your device.

b) To provide you with information, products, or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

c) To carry out our obligations arising from any contracts entered into between you and us and/or to provide the Services, including (but not limited to) providing relevant information or advice, processing your enquiries, and undertaking administration, planning and account management functions as well as other associated business processes.

d) To allow you to participate in interactive features of our service, when you choose to do so.

e) To improve our services through analysis of how users interact with our platform.

f) To comply with legal and regulatory requirements in or outside Hong Kong.

g) For legal proceedings, including collecting overdue amounts if necessary.

h) To notify you about changes to our service.

3.2 AI-Generated Content

PortfoPlus utilizes AI-powered services to enhance our offerings, including AI-generated content and recommendations. These features are powered by third-party AI models, including Microsoft Azure OpenAI and Google Gemini. When using our AI-powered services, user inputs may be processed by these AI providers to generate responses.

By using our AI services, you acknowledge and consent to your inputs being processed by these third-party AI providers in accordance with their respective privacy policies and terms of use.

3.3 Direct Marketing

We may conduct direct marketing via fax, email, direct mail, telephone, and other means of communication or send e-newsletters to you about our products, services, and promotions.

You may choose not to receive promotional materials at any time by:

Clicking the "unsubscribe" link in our marketing emails

Contacting us directly at

We will honor your request to cease direct marketing communications without charge.

4. DISCLOSURE OF YOUR INFORMATION

4.1 Sharing Your Information

We will keep the personal data we hold confidential but may provide information to:

a) Personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services.

b) Our overseas offices, affiliates, business partners, and counterparts.

c) Persons under a duty of confidentiality to us.

d) Persons to whom we are required to make disclosure under applicable laws in or outside Hong Kong.

e) Actual or proposed transferees or participants of our services.

4.2 Third-Party Service Providers

We use the following third-party analytics and service providers to help us analyze how users use our site and/or mobile application, improve our services, and communicate with you. Please refer to their respective privacy policies for details on data handling:

Google Analytics is used on our website to help analyze how users use the site. Google Analytics is a web analysis service provided by Google Inc. Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google’s ability to use and share information collected by Google Analytics regarding your visits to this site is restricted by the Google Analytics

MIXPANEL is used on our website to help analyze how users use the site. MIXPANEL is a web analysis service provided by Mixpanel. Mixpanel utilizes the data collected to track and examine the use of our website, to prepare reports on its activities. Mixpanel’s ability to use and share information collected by Mixpanel regarding your visits to this site is restricted by the Mixpanel

AMPLITUDE is used on our website to help analyze how users use the site. AMPLITUDE is a web analysis service provided by AMPLITUDE. AMPLITUDE utilizes the data collected to track and examine the use of our website, to prepare reports on its activities. AMPLITUDE’s ability to use and share information collected by AMPLITUDE regarding your visits to this site is restricted by the AMPLITUDE

4.3 AI Service Providers

For AI-generated content and recommendations, user inputs may be shared with Microsoft Azure OpenAI (ChatGPT) and Google Gemini for processing. These AI providers may process the data solely for the purpose of generating responses and improving their services. Please refer to their respective privacy policies for details on data handling: Microsoft Azure OpenAI Privacy Policy , Google Gemini Privacy Policy

We cannot control how third parties use information.

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 How We Use Cookies

Our website and mobile applications use cookies, device identifiers, and similar tracking technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website or use our mobile applications and also allows us to improve our services. By continuing to browse the site or use our mobile applications, you are agreeing to our use of these technologies.

5.2 Types of Cookies We Use

a) Strictly necessary cookies: These are cookies and similar technologies that are required for the operation of our website and mobile applications. They include, for example, technologies that enable you to log into secure areas, maintain session state, or use core functionality.

b) Analytical/performance cookies: They allow us to recognize and count the number of visitors and app users, and to see how visitors and users move around and interact with our services. This helps us to improve the way our website and mobile applications work, for example, by ensuring that users can find what they're looking for easily.

c) Functionality cookies: These are used to recognize you when you return to our website or mobile applications. This enables us to personalize our content for you, greet you by name, and remember your preferences.

d) Targeting cookies: These technologies record your visits to our website and mobile applications, the features you've used, and your interaction patterns. We use this information to make our services and the content displayed more relevant to your interests.

5.3 Mobile Device Identifiers

Our mobile applications may use device identifiers (such as IDFA on iOS devices or Advertising ID on Android devices) and other mobile analytics tools to collect information about how you use our applications. These technologies function similarly to cookies on websites but are managed differently on mobile devices.

5.4 Cookie Management

For Website Cookies:

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

For Mobile Applications:

iOS Devices: You can opt out of interest-based ads by going to Settings > Privacy > Advertising and turning on "Limit Ad Tracking"

Android Devices: You can opt out of interest-based ads in the Google Settings app under "Ads" or "Google" > "Ads"

6. DATA SECURITY

6.1 We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition:

All information you provide to us is stored on our secure servers.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site and/or mobile application, you are responsible for keeping this password confidential.

We use encryption to protect sensitive data transmitted to and from our site and/or mobile application.

We regularly review and update our security practices.

6.2 We will take all reasonable steps to protect your personal data from loss, misuse, unauthorised access, modification or disclosure..

7. INTERNATIONAL DATA TRANSFERS

Where necessary, the Company may transfer your personal data to third parties outside of Hong Kong for the purposes specified in this Privacy Policy. We will ensure that any international transfer of your personal data is made pursuant to appropriate safeguards in accordance with the Ordinance as well as applicable laws and regulations in Hong Kong.

8. YOUR RIGHTS AND CHOICES

8.1 Your Consent

By using our service, making an application, or visiting our website and/or mobile application, you consent to the collection and use of your information and other activities as outlined in this Privacy Policy.

8.2 Your Rights Under Hong Kong Law

Under the Hong Kong Personal Data (Privacy) Ordinance, individuals have the right:

To check whether we hold personal data about you and to access such data

To require us to correct inaccurate data

To ascertain our policies and practices in relation to personal data and the kind of personal data held by us

8.3 Exercising Your Rights

To exercise any of these rights, to cease communications, and/or to submit any questions or complaints about our privacy practices, please contact us at:

Email:

We may charge a reasonable fee for processing a data access request.

9. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy. The updated version will be effective as of the "Last Updated" date at the top of this policy.

10. GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region. You agree to submit to the exclusive jurisdiction of the Hong Kong courts.