We are committed to safeguarding your privacy and ensuring that your Personal Data is protected.  This Privacy Policy Statement explains the types of Personal Data we collect and how we process and protect that data.

We shall keep your Personal Data confidential and shall ensure that our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of your Personal Data comply with the laws of Hong Kong. Personal Information Collection Statement (“PICS”)

This PICS is issued pursuant to the PDPO in relation to the operation of our online business by BrainX Company Limited (referred to as “we” or “us”).

  1. This PICS is last updated on the Effective Date.
  2. Definitions

Under this PICS, unless the context otherwise requires, the following words and expressions shall have the following meanings:

2.1. “Database” means the database of our customers’ Personal Data.
2.2. “Effective Date” means 20 November 2022.
2.3. “Member” means a member of our communities.
2.4. “Our Apps” mean the mobile applications operated by us.
2.5. “Our Customer Hotline” the hotline number(s) is available on Our Website.
2.6. “PDPO” means the Personal Data (Privacy) Ordinance (Cap.486).
2.7. “Personal Data” has the meaning ascribed to it under the PDPO.
2.8. “Our Websites” all websites operated by us and including
2.9. “Registered Customer” means our customer who has registered for an account with us.

Personal Data: what we collect and why

  1. In order for you to become a Registered Customer and to enjoy our services in the web portal, it is necessary for you to provide us with certain essential Personal Data as indicated at the time of collection.  We may also ask for other information which helps us to offer you tailored products and services that we think may be of interest to you.  The types of Personal Data we may collect include and not limited to your name, address, email, telephone number, date of birth, gender, age, wedding and/or anniversary dates, social media account, browsing and shopping preferences, hobbies and interest.
  2. We shall have the right to collect, hold, process and/or use, the Personal Data in the Database in each case for the purposes as set out in, and in accordance with, this PICS.  If you are unable or unwilling to provide us with complete and correct Personal Data, we may not be able to provide or continue to provide our products and services to you.

Use of your Personal Data

  1. You agree that the Personal Data you provide to us and all information relating to the use of Our Apps and/or Our Websites may be used and retained by us for:
5.1. processing your application as a Registered Customer or a Member;
5.2. providing you with our services;
5.3. the normal management, operation, and maintenance of Our Apps and/or Our Websites;
5.4. providing you with regular communications from us with details of our business and relevant benefits;
5.5. providing you with goods or services which you have requested;
5.8. carrying out data sorting and analysis to enable us to better understand your characteristics and buying behaviour and to provide other services better tailored to your needs;
5.9. designing new or improving existing services provided by us, Our Affiliates and/or Our Partners to you;
5.10. investigation of complaints, suspected suspicious transactions, and research for service improvement;
5.11. prevention or detection of crime;
5.12. disclosure as required by law; and
5.13. performing research, statistical analysis or surveys, whether verbally or in writing
5.14. analyzing trends, usages and behaviors analysis (whether on an individualized or aggregated basis), which helps us better understand how our collective user base consumed and the underlying commercial activities conducted
  1. With your consent or indication of no objection, we will use your Personal Data for direct marketing to you (whether by post, email, phone, SMS, WhatsApp, social media or other media whether now known or available in the future) in relation to offers and promotions from BrainX Company Limited
  1. We may disclose and transfer (whether in Hong Kong or abroad) your Personal Data to our agents or contractors under a duty of confidentiality to us who provide administrative, data processing, research and marketing, distribution, telecommunications, professional or other similar services to us.
  2. We may also disclose and transfer (whether in Hong Kong or abroad) to any of our actual or proposed assignees or transferees of our rights with respect to your Personal Data in connection with a re-structuring of our business, and/or merger (as between us and a third party), sale, or transfer (whether of assets or shares, in whole or in part), to use, hold, process or retain such Personal Data for the purposes mentioned in clauses 5 and 6 above.

Browsing information collected from you (Cookies)

  1. We use cookies and similar technologies to collect data about you when you visit the Our Websites and our other related websites (“Sites”). Cookies are files that store information on your computer hard drive or browser that mean we can recognise that you have visited our Sites before. We use cookies to give you the best possible experience on our Sites, by evaluating the use of our Sites and reviewing your browsing and shopping habits, personalizing your website experience, evaluating website activity on our Sites and generally making our Sites easier to use.
  2. The types of data we may collect from you when you visit the Sites include:
  • information about the type of browser you use;
  • details of the web pages you have viewed;
  • your IP address;
  • the hyperlinks you have clicked; and
  • the websites you visited before arriving at our Site.

  1. You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but to do so you may not be able to utilize or activate all of the functions and services of our Sites.

Your rights in relation to your Personal Data

  1. You have the right to:
12.1. check whether we hold any of your Personal Data;
12.2. access your Personal Data held by us;
12.3. require us to correct any Personal Data which is inaccurate;
12.4. ascertain our policies and practices (from time to time) in relation to Personal Data and the type of Personal Data held by us;
12.5. opt out from receiving direct marketing materials from us at any time.
12.6. request for the Personal Data to be deleted.

Any request in relation to the above shall be in writing (sent by post or email) and addressed to:

Marketing Department Unit 711, Hang Lung Centre, 20-22 Paterson Street, Causwway Bay, Hong Kong

Email address:

For enquiries, please contact Our Customer Hotline, which can be found on Our Websites or Our Apps.

  1. In accordance with the Ordinance, we have the right to charge you a reasonable fee for the processing of any Personal Data access request.

Protecting your Personal Data

  1. We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data.
  2. Our Websites may contain hyperlinks to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites.  Once you have left our websites, we cannot be responsible for the protection and privacy of any information which you provide.  You should exercise caution and look at the privacy statement for the website(s) you visit.


  1. Nothing in this Privacy Policy Statement shall limit your rights under the PDPO.
  2. If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.
  3. This Privacy Policy Statement shall be governed by, and construed in accordance with, the laws of the Hong Kong Special Administrative Region.
  4. We may change this Privacy Policy Statement from time to time by posting an updated version on the Our Websites and Our Apps.