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Notice: In the event of any discrepancy between the English and Chinese versions of this Privacy Policy, the Chinese version shall prevail.

Fuuffy (www.fuuffy.com, hereinafter "Fuuffy", the "Company", "we" or "us") is operated by Tradeluck (HK) Limited (registered office: Room 07, 22/F, 9 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong).

This Privacy Policy (the "Privacy Policy") describes how we collect, use, store, share and protect personal data that you provide to us or that we collect when you use our website (www.fuuffy.com), mobile applications and related services (collectively, the "Services").

Fuuffy fulfils its data protection responsibilities in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong (the "PDPO"). We are committed to protecting the privacy of your personal data.

By using our Services, you confirm that you have read, understood and agreed to the processing of your personal data as described in this Privacy Policy.

Section 1 — Introduction

1.1　This Privacy Policy applies to all personal data collected by Fuuffy through its website, mobile applications and any other channels.

1.2　This Privacy Policy forms part of the Terms of Service between you and Fuuffy (see www.fuuffy.com/about/tos) and should be read in conjunction therewith.

1.3　In the event of any discrepancy between the Chinese and English versions of this Privacy Policy, the Chinese version shall prevail.

Section 2 — Personal Data We Collect

2.1　We may collect the following types of personal data:

Data Category	Details
Account Data	Name, email address, phone number, password, Hong Kong address
Business Entity Data	Company registration name, business registration number, company address
Shipment Data	Sender and recipient names, addresses, phone numbers, item descriptions, weight, dimensions, declared value
Payment Data	Payment method, transaction records, invoice records
Fuuffy Dollar Data	FD balance, earning and usage records, expiry and recovery records
Communication Data	Customer service enquiry records, complaint records, email correspondence
Technical Data	IP address, browser type and version, device information, operating system, login timestamps, page views
Usage Data	Search history, price comparison records, order history, preference settings

2.2　We do not intentionally collect sensitive personal data (such as race, religion, or health information) unless you voluntarily provide it or it is required by law.

Section 3 — How We Collect Data

3.1　We collect personal data through the following means:

(a) Directly from you: When you register an account, submit a shipment order, contact customer service, or participate in promotional activities.

(b) Automatically: When you use our website and applications, we automatically collect technical data and usage data through cookies and similar technologies.

(c) Third-party sources: We receive data relating to your shipments from Courier companies, payment processors and other service providers.

(d) Social login: If you choose to log in using your Facebook or Google account, we may receive your basic personal data from those platforms.

Section 4 — Purposes of Use

4.1　We use the personal data we collect for the following purposes:

(a) Service Delivery: Processing shipment orders, providing price quotes, tracking packages, issuing invoices and processing payments.

(b) Account Management: Creating and maintaining your account and verifying your identity.

(c) Fuuffy Dollar Programme: Managing the issuance, usage, expiry and recovery of Fuuffy Dollars.

(d) Customer Support: Responding to your enquiries, complaints and support requests.

(e) Communications: Sending service notifications, package updates, transaction confirmations and account notices.

(f) Marketing and Promotions: Subject to your consent and in compliance with Part 6A of the PDPO, sending you promotional information, offers and updates about Fuuffy's services. Before using your personal data in direct marketing for the first time, we will inform you of the kinds of personal data to be used and the classes of services to be marketed, and we will not so use your data without your consent (an indication of no objection). You may withdraw your consent and opt out at any time, free of charge (see Section 10).

(g) Service Improvement: Analysing usage patterns to improve our services, website and user experience.

(h) Security and Fraud Prevention: Detecting and preventing fraud, abuse and other harmful activities, including Fuuffy Dollar anti-abuse monitoring.

(i) Legal Compliance: Complying with applicable laws, regulations and court orders.

Section 5 — Sharing and Transfer of Data

5.1　We may share your personal data with the following parties in the following circumstances:

(a) Fuuffy Affiliates: Our subsidiaries and associated companies, to provide and improve the Services.

(b) Courier Companies: The Courier you have selected, to process and deliver the Shipment.

(c) Service Providers: Agents, contractors or other service providers who provide services to Fuuffy (such as payment processors, cloud storage providers and customer service tools), but only to the extent necessary to provide the Services.

(d) Legal Requirements: Any person to whom Fuuffy is under an obligation to make disclosure under applicable laws, regulations, court orders or government requests.

(e) Media: Only in connection with the handling of customer complaints and enquiries forwarded to us by the media.

(f) Persons Under Confidentiality Obligations: Any person who owes a duty of confidentiality to Fuuffy.

5.2　We do not sell or rent your personal data. We will not provide your personal data to any third party for that third party's own direct marketing purposes unless we have first obtained your written consent in accordance with Part 6A of the PDPO.

Section 6 — Cross-Border Data Transfers

6.1　As an international logistics platform, the nature of Fuuffy's Services requires us to transfer your personal data (particularly sender and recipient information) to Courier companies and/or relevant parties in countries or regions outside Hong Kong.

6.2　When transferring data across borders, we take reasonable steps to ensure that the receiving party provides a level of protection for your personal data that is broadly comparable to the standards required by the PDPO.

6.3　By using our Services to submit a shipment order, you consent to the cross-border data transfers necessary to complete the shipment.

Section 7 — Cookies and Tracking Technologies

7.1　Our website and applications use cookies and similar tracking technologies to collect and store information about your use of the Services.

7.2　The types of cookies we use include:

Type	Purpose	Necessity
Strictly Necessary	Core website functionality, account login, security	Required
Functional	Remembering your preferences (e.g. language selection)	Optional
Analytics	Analysing website usage to improve services	Optional
Marketing	Delivering relevant advertisements and promotional content	Optional

7.3　You may manage or reject cookies through your browser settings. Please note, however, that rejecting certain cookies may affect your ability to use some features of the Website.

Section 8 — Data Retention

8.1　We retain your personal data only for the period necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specific retention periods are as follows:

Data Category	Retention Period
Account Data	Duration of account plus 7 years after account closure
Shipment and Transaction Data	7 years after completion of the transaction (in line with the Inland Revenue Ordinance (Cap. 112) of Hong Kong)
Fuuffy Dollar Records	3 years after FD expiry or recovery
Customer Service Communications	3 years after the last communication
Technical and Usage Data	2 years after collection

8.2　Upon expiry of the retention period, we will securely destroy or anonymise your personal data.

Section 9 — Data Security

9.1　We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, use, disclosure, alteration or destruction, including but not limited to data encryption, access controls and regular security audits.

9.2　Despite our efforts, no method of transmission or storage is completely secure. We cannot guarantee the absolute security of your personal data.

9.3　Data Breach Notification. In the event of a data breach affecting your personal data that poses a material risk to your rights and interests, we will notify you and (where applicable) the Office of the Privacy Commissioner for Personal Data of Hong Kong as soon as reasonably practicable. The notification will include the nature of the breach, the types of data potentially affected, the remedial measures we have taken, and the protective steps you can take.

Section 10 — Your Rights

10.1　Under the PDPO, you have the following rights in relation to your personal data:

(a) Right of Access: You have the right to ascertain whether Fuuffy holds your personal data and to obtain a copy of such data.

(b) Right of Correction: You have the right to request correction of any inaccurate personal data.

(c) Right of Deletion: You may request deletion of your Fuuffy account at any time by email or live chat with our customer service. Upon account deletion, all related personal data (including Facebook and Google login details, email and contact information) will be permanently deleted, except for data required to be retained by law.

(d) Right to Object: You have the right to object to the use of your personal data for direct marketing purposes. If you do not wish to receive promotional materials, please log in to the Member Centre on our Website and uncheck "Receive Member Messages (Email)" in your profile settings. Upon receipt of your opt-out request, we will cease using your personal data for direct marketing without charge.

10.2　Any request to access, correct or delete personal data must be made in writing and sent to: cs@fuuffy.com

10.3　Fuuffy requires five (5) working days for administrative processing of data access requests. We may charge a reasonable fee for processing access requests in accordance with the PDPO. In any event, we will respond to a data access or correction request within forty (40) days as required by the PDPO; if we are unable to comply within that period, we will notify you in writing and comply as soon as practicable thereafter.

Section 11 — Fuuffy Dollar Programme Data

11.1　To manage and operate the Fuuffy Dollar Rebate Programme, we collect and process the following additional data: FD balance, earning and usage records, expiry and recovery records, and related order data.

11.2　We may use automated systems to monitor Fuuffy Dollar activity to detect and prevent abuse (as described in the Fuuffy Dollar Rebate Programme Terms and Conditions).

11.3　If automated systems detect anomalous activity, this may trigger an account review. You have the right to appeal any automated decision — see the Fuuffy Dollar Rebate Programme Terms and Conditions for details.

Section 12 — Children's Privacy

12.1　Our Services are intended for adults. While general browsing of the Website is not in itself unsuitable for children, the Services (including placing orders) are not directed at children.

12.2　If you are under eighteen years of age, you should not provide any personal data to us or use our Services to place orders unless you have obtained the express consent of a parent or guardian.

12.3　If we become aware that we have collected personal data from a minor without parental consent, we will take reasonable steps to delete such data as soon as practicable.

Section 13 — Third-Party Links

13.1　Our Website may contain links to third-party websites or services. We are not responsible for the privacy policies or practices of such third parties.

13.2　We recommend that you review the privacy policy of any third-party website before providing your personal data to it.

Section 14 — Changes to This Policy

14.1　We may revise this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any revision will take effect upon being published on our Website.

14.2　If we make material changes to this Privacy Policy, we will notify you by means of a notice on the Website and/or by email.

14.3　Your continued use of our Services after the revision of this Privacy Policy constitutes your acceptance of the revised Privacy Policy.

Section 15 — Contact Us

15.1　If you have any questions, comments or complaints about this Privacy Policy, or wish to exercise your data protection rights, please contact us at:

Tradeluck (HK) Limited
Address: Room 07, 22/F, 9 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong
Email: cs@fuuffy.com

15.2　If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data of Hong Kong (www.pcpd.org.hk).