Privacy Policy

EDGE SQUARED LIMITED

PERSONAL INFORMATION COLLECTION STATEMENT

This personal information collection statement (“PICS”) is to inform you:

  1. a) of the purpose for which your personal data collected by us will be used following collection in connection with your use of this website (https://peaktraders.com/) (“Website”) or our service of providing various educational and informational products using Edge Squared Limited’s proprietary video courses and training materials and branded as “Peak Traders” offered on our Website (“Service”);
  2. b) to whom your personal data may be transferred; and
  3. c) to whom you may address data access or correction requests,

in compliance with the Personal Data (Privacy) Ordinance (Chapter 486) (“PDPO“).

Edge Squared Limited may revise this PICS by amending this page. You should check this page from time to time to take notice of any changes we make.

 

  1. DATA USER

Edge Squared Limited (“Edge Squared”, “we”, “us”, “our”), a private company limited by shares incorporated in Hong Kong with Companies Registry number 2806519, is the data user.

 

  1. DATA SUBJECTS

This personal information collection statement applies to personal data from (“you” or “your”):

  1. a) Visitors: individuals who visit our Website;
  2. b) Users: individuals who purchase, use, request, subscribe for or receive our Service;
  3. c) Contacts: individuals who contact us through our Website, by email, or other means; and

d) Subscribers: Visitors who subscribe for communications from us.

 

WHAT TYPES OF PERSONAL DATA WE COLLECT

3.1     We may collect, hold, process, transfer and use the following types of personal data:

  1. a) from Visitors:
  2. IP address or other unique device identifiers;*
  3. b) from Users:
  4. full name; *
  5. email address; *

iii.     billing address; *

  1. payment information; *
  2. c) from Contacts:
  3. full name; *
  4. email address; *
  5. any other personal data which you provide to us;
  6. d) from Subscribers:
  7. full name;
  8. email address.*

*mandatory personal data

3.2     If you do not provide us with mandatory personal data, we may not be able to provide you access to our Website and Service, or respond to your communications with us.

 

  1. PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

4.1     We may collect, hold, process, transfer and use your personal data for any of the following purposes:

  1. a) to provide our products and services to you such as:
  2. to enter into a contract to provide our Service to you;
  3. to manage your subscription to our Service;

iii.     to perform our Service for your use;

  1. to create and update your account registered with us;
  2. to process and facilitate billing and payment for our Service.
  3. b) to monitor the use our Website and Service;
  4. c) to help maintain the safety, security and integrity of personal data collected through our Website and Service;
  5. d) to personalise your experience on our Website: identifying your preferences and behaviour helps us to better respond to your individual needs;
  6. e) to compile aggregate statistics about you and to analyse your usage of our Service;
  7. f) to implement our Affiliate program;
  8. g) to improve our Website and our Service: we continually strive to improve our services and offerings based on the information and feedback we receive from you;
  9. h) for research and development: your personal data will help us test, research, analyse, assist with product development and machine learning to improve your experience;
  10. i) for customer service and to help us to more effectively respond to your Service requests, receive feedback and support needs;
  11. j) for legal proceedings or as required by regulators, government entities and official enquiries;
  12. k) for technical purposes and for project management needs;
  13. l) for non-marketing communications relating to our Service such as notifications of changes to our Service or upcoming expiry of your subscription to our Service;
  14. m) for direct marketing, but only if we receive your consent (see paragraph 10 below); and
  15. n) for other purposes directly relating to the above.

4.2     Personal data collected by us may not be used for other purposes, unless:

  1. a) you have expressly given your consent to the use for the relevant other purposes;
  2. b) the purpose is directly related to the purpose for which the personal data was collected; or
  3. c) we are permitted to use the personal data for other purposes arising from an exemption or otherwise in accordance with applicable law and regulation.

 

5. PERSONAL DATA TRANSFEREES

5.1     We may transfer your personal data to the following persons (in or outside Hong Kong):

  1. a) employees or officers of Edge Squared;
  2. b) Whop(https://whop.com/),  Discord (https://discord.com/), Paypal Holdings Inc., their respective subsidiaries or other payment processors or facilitators (“Payment Processors”) whom we may engage to perform payment processes for us in respect of our Service or in the course of our business;
  3. c) other service providers and data processors engaged by us such as:
  4. administrative service providers;
  5. IT services and software suppliers;

iii.    data analytics providers;

  1. entry and processing service providers;
  2. cloud service providers; and
  3. credit reference agencies.
  4. d) our insurers and bankers;
  5. e) our legal, financial and accounting professional advisors;
  6. f) other companies, organisations or persons to the extent required by applicable law, regulation, legal process, governmental request or where the disclosure is appropriate due to safety concerns. This includes exchanging your personal data with other companies, organisations or persons for the purposes of fraud protection and prevention; and
  7. g) other companies, organisations or persons as part of negotiations of any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into that other company.

5.2     By making payments to us through Payment Processors, you will directly enter into an agreement with the Payment Processor and become subject to its terms of use and privacy policy. You should review and, if applicable and at your discretion, indicate your consent to the privacy policy of the Payment Processor, which will not be governed by this PICS or by our privacy policy.

5.3     If we transfer your personal data to other persons, we will ensure the confidentiality of your personal data by including confidentiality clauses in the agreements with third parties with whom we will share your personal data, or including other contractual terms to keep your personal data confidential.

5.4     We may share your personal data with anyone other than as described in paragraph 5.1 above if we notify you and receive your consent beforehand.

5.5     Some persons to whom we transfer your personal data may be located outside Hong Kong, in locations that may not have in place data protection laws which are substantially similar to Hong Kong, and this may mean your personal data may not be protected to the same or similar level as that in Hong Kong.

 

  1. COOKIES

6.1     A cookie is a small data file that a web site can send to your computer or device when you visit our Website.  You can find more information about cookies in this publication of the Privacy Commissioner for Personal Data, Hong Kong:

https://www.pcpd.org.hk/english/publications/files/guidance_internet_e.pdf

6.2     Cookies are used to make websites work in a better, more efficient way, usually by enabling them to recognise you and remember important information that will make your use of a website more convenient (e.g. by remembering your user preferences).

6.3     We use cookies to:

  1. a) remember your preferences on language, font size, colour scheme, so that the look and feel of our Website is kept for your future visits;
  2. b) analyse how you navigate our Website to help us optimise its design; and
  3. c) track your behaviour and preferences so we can assess the kind of information and services you may be interested in from us.

6.4     We use:

  1. a) session cookies which are unique to each visit you make to our Website; and
  2. b) persistent cookies which will not be deleted when you close your browser window and will be activated every time you visit our Website.

6.5     The cookies we use are either:

  1. a) necessary cookies which are essential to our Website to help you to move from page to page and use our Website’s features;
  2. b) functionality cookies which allow our Website to remember choices you make, and provide more personal features; or
  3. c) performance cookies which collect information about your use of our Website and help us to improve the way it works.

6.6     We use a limited number of third party cookies, including:

  1. a) Google analytics cookies: These cookies are used by Google Analytics to monitor traffic levels, search queries and visits to our website. Google Analytics stores internet protocol (“IP”) addresses on its servers in the US.  These cookies enable Google to determine whether you are a return visitor to our Website, and to track the pages that you visit during your session. The information generated relating to our Website is used to create reports about the use of the Website. Google hold this information and provide us access to it.  This is the link to Google’s privacy policy: https://policies.google.com/privacy?hl=en-US;

6.7     By continuing to use our Website without notifying us of your refusal to use cookies or withdrawing your consent, you are agreeing to our use of cookies.

6.8     You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser.  These settings are usually found in the “options” or “preferences” menu of your internet browser, or by clicking “help” on your browser menu.  Removal of cookies may affect your use and experience of our Website.

6.9     We only retain cookies for the duration needed for the function they are used.  This function varies according to the cookie.

 

  1. RETENTION

7.1     Your personal data will be stored securely.

7.2     We will retain your personal data for the period reasonably necessary to fulfil the purposes for which it was collected.  We may also retain your personal data for a longer period if it is necessary for us to do so to comply with our contractual or legal obligations.  Personal data you have provided to us will be destroyed on expiry of this retention period.

 

  1. YOUR RIGHTS TO ACCESS AND CORRECT YOUR PERSONAL DATA

8.1     You have the right under the PDPO to:

  1. a) request a copy of your personal data held by us, unless we are exempted from complying with a data access request; and
  2. b) request for us to make necessary corrections in respect of any personal data that you consider inaccurate after we have fulfilled a data access request from you. We may refuse a data correction request if we believe the personal data is accurate, an expression of opinion or the proposed correction is inaccurate.

8.2     If you wish to access or correct your personal data, please contact: [email protected]

8.3     We reserve the right to charge a reasonable fee to process any personal data access or correction request.

 

  1. COMPLIANCE WITH NON-HONG KONG REQUIREMENTS

9.1     We may need to comply with personal data protection and privacy requirements of your home jurisdiction, which may be different from those of Hong Kong. Therefore, we may require your reasonable cooperation to enable us to comply with any legal or regulatory requirements applicable to our processing of data in your jurisdiction of residence or incorporation.

9.2     If you refuse to provide the requested cooperation, we may have to take appropriate action to comply with the requirements of your home jurisdiction. The content of the relevant action will depend on the nature of the applicable requirements. However, we may not be able to provide our Service to you unless we comply with applicable requirements.

 

  1. USE OF PERSONAL DATA FOR DIRECT MARKETING

10.1   We may use your personal data collected to directly market our services and products to you.

10.2   The type of personal data we use for direct marketing purposes are:

□       your full name;

□       your email address; and

□       your billing address.

□       I do not object to the use of these types of personal data for direct marketing.

□       I object to the use of the types of personal data in the ticked boxes for direct marketing services (but not to the other types).

10.3   The direct marketing activities we intend to conduct using your personal data are:

□       information and promotional material about: Edge Squared’s products and services, initiatives or products similar to those you previously purchased, and information about Edge Squared which we believe you may find useful;

□       invitations to join our events, seminars, and presentations;

□       newsletters about our Website, services or products;

□       updates in respect of our Website, services or products; and

□       festive greetings.

□       I do not object to receiving these types of direct marketing activities.

□       I object to receiving the types of direct marketing activities in the ticked boxes (but not to the other types).

10.4   If you do not expressly indicate your consent, then we may not use the types of personal data for the direct marketing activities described in this paragraph 10.

10.5   If we receive your consent for direct marketing, we may transfer your personal data for direct marketing purposes to the persons stated in paragraph 5.1 above.

10.6   You may request us to cease using your personal data for direct marketing purposes at any time by emailing us at: [email protected] or by replying with the heading “unsubscribe” to any direct marketing communication from us.