This Privacy Policy explains how smartME Corporation Limited (hereinafter referred to as “the Company”, "we", "our" or "us") collects and uses your personal data and other information. We take all appropriate steps to protect our customers' personal data. In the course of providing our services, we need to collect and maintain personal data as defined by regulation in the Hong Kong Special Administrative Region ("Hong Kong") (e.g. in the Personal Data (Privacy) Ordinance – CAP 486, "PDPO") or the place of incorporation of our affiliated companies. We are committed to protecting the privacy, confidentiality and security of personal data by complying with the PDPO. We are equally committed to ensuring that our employees and agents uphold these obligations. As a rule, we never disclose any personal data about our customers to any non-affiliated third parties, except as described below.

When you apply for, open, or maintain an account with us or post a comment or message on our site, subscribe to our newsletter, we may collect and retain the following information: the data you provide online and on applications or other forms, or through discussions we have with you or your representatives, such as your name, address, email address and telephone number.

Data collection purpose

In general, we collect, use and disclose personal data to meet the needs of our customers and for our business purposes, including: to provide the services to you; the day-to-day operation and maintenance of accounts; to manage our global websites and services; to understand our customers and their needs; to learn about our markets and design and improve our services; to administer and process any request for information or job application; to comply with our regulatory, legal obligations, including warrants, subpoenas, court orders, or with a regulator or law enforcement agency request, and in connection with criminal investigations or to meet government tax reporting requirements; to contact you (including by way of e-mail), in response to your inquiries and comments, and to safeguard your interests; to investigate suspicious activities; and to protect our rights and property, and to conduct direct marketing activities subject to your consent (as further explained below).

We provide services to facilitate electronic execution of certain documents. We may collect information about your property transactions for the above purposes. Furthermore:

- If you are an estate agent or a salesperson for estate agency work, we may collect your information about your estate agent's licence, salesperson's licence, statement of particulars of business, business registration certificate of your licensed estate agent, business address and contact details when you register an account with us.

- If you are an individual acting for and on behalf of a corporate vendor or a corporate purchaser of property, we may collect information about your position, business registration certificate and contact details of your company.

- If you are a vendor or a purchaser of properties, to the extent permissible under applicable regulations, we may collect your Hong Kong identity card, passport number or travel permit and/or copies of such documents ("ID Data") on behalf of the estate agent or salesperson with whom you are dealing ("Your Estate Agent and Salesperson"), provided that we are only a data processor for Your Estate Agent and Salesperson of your ID Data.

- As required by applicable regulations, Hong Kong identity card or passport copy is requested to ensure accuracy of Hong Kong identity card or passport number provided by a data subject. You may choose to present your Hong Kong identity card or passport in person to smartME, or provide such copies electronically over our platform.

- smartME provides a channel for ID Data to be provided, and smartME does not compile or identify any individual based on any ID Data.

- We do not control data practice of Your Estate Agent and Salesperson or other third parties. We advise that you should read and understand separate privacy policies of Your Estate Agent and Salesperson or third parties with whom you deal with in your us of our services.

We may collect personal data from visitors to our websites and individuals who participate in a promotion, contest or survey (including online or via telephone). We may use this information to advise them of products, services and other marketing materials which may be of interest to them and related to our activities in the digital asset space. We may also invite visitors to participate in market research, surveys and similar activities. Please see details in "Direct Marketing" section below.

When you use our mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map. The information we collect includes your mobile phone operating system (i.e., Android, iOS) and your current geographical location from your mobile phone’s GPS component. The use of the GPS information is solely for the purpose of identifying the location where the scanning and authentication of the product in question is being conducted. This is important when verifying the product provenance through our traceability feature to detect any suspicious fraudulent product. The collection of GPS information only active when you use the mobile application, once you exit the application, our application will no longer collect any information from your mobile device.

If you do not want to use your location for the purposes set for the above, you should turn off the location services for the mobile application. The information we collected will not be disclosed to any other parties non for the use of any marketing activities. We will retain the collected information for as long as you use our mobile application and for a reasonable time thereafter.

When we collect personal data from you, we will indicate whether such data is mandatory or voluntary. If you do not provide personal data which is listed as mandatory, we may not be able to provide our services or products to you.

Information disclosure

We may disclose personal data we collect, such as the categories described above, to our service providers ("Service Providers") which provide customer, communications, marketing services to us . We may also use and disclose your personal data as authorised by you. If you decide to withhold certain information, it may limit our ability to provide you with the services or products you requested.

Furthermore, we may disclose your personal data to the following entities: our affiliated companies and non-affiliated third parties ("Third Party Affiliates") for direct marketing purpose (Please see "Direct Marketing" session below); or otherwise required by applicable law. Our affiliated companies and Third Party Affiliates may be in the business of providing financial, block-chain technology, money lending and real estate products and services.

We require that commercial entities (as described above) with which we share your personal data should keep your personal data confidential. We also prohibit those entities from using or disclosing your personal data except for a limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted or required by law.

Our Service Providers must agree to contractual requirements consistent with our privacy and security policies. We prohibit our Service Providers from using personal data except for the specific purpose for which we provide it to them, and require them to comply with legal obligations applicable to the personal information at issue. Occasionally, at our discretion, we may include or offer our affiliated companies' or Third Party Affiliates' products or services on our platform. These affiliated companies and Third Party Affiliates have separate and independent privacy policies. We therefore have no

responsibility or liability for the content and activities of Internet sites, information and data practice of these Third Party Affiliates. Nonetheless, we seek to protect the integrity of our platform and welcome any feedback about them.

Data storage

Generally, the personal data that we collect from you will be stored in the Hong Kong. And we may store your personal data in other countries, which may have different privacy laws and standards than those in your country of residence. Your personal data may be transferred . By submitting personal data via to us, you agree to our storage, transfers and processing which may be out of Hong Kong. We will take all steps reasonably necessary to treat your personal data securely and in accordance with this Privacy Policy.

It is important to note that some or all of your personal data provided to our Service Providers, affiliated companies or Third Party Affiliates may be located outside Hong Kong You acknowledge and understand that your personal data will be subject to the applicable laws of each such jurisdiction, which may not provide for the same protection as your country of residence. For example, government entities in the Hong Kong and other countries may have certain legislative rights to access your personal data. If you have questions about our policies and practices with respect to service providers outside your jurisdiction, including the collection, use, disclosure or storage of such personal data by our service providers worldwide, you may contact us by e-mail at

Protection of your personal data

We maintain reasonable physical, electronic, and procedural safeguards to protect your personal data. We place your account information on the secure portion of our website, using firewalls and other security technology to protect our network and systems from external attacks, and we require that you enter a unique user name and password to access your account information online. In addition, if you access information online, we may use digital certificate services to authenticate that you are transacting with our website and not the website of an impostor.

Online security

In addition to our security measures, you can also take steps to maximise your security online and to protect your confidential information. We encourage you to use strong passwords with mix of uppercase, lowercase, numbers and special symbols; passwords should never include personal data. Our support teams will never ask you for your personal data such as username or identification number via email. We will never ask for your password as we are not keeping any password in our databases. As per industry standards we are using a secure salt and hash storage. We also recommend that you protect your workplace, your computer or even your physical environment to protect your information.

We are concerned about safeguarding the confidentiality of your information. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Usage of cookies

Cookies are small bits of information that are automatically stored on your web browser in your computer that can be retrieved by www. “this Site”. Cookies and similar technologies are used to identify user’s device for the following purposes:

- Temporarily allow users to carry information between pages of this Site to avoid having to re-enter that information.

- Allow us to enable the cookies setting on user’s web browser. This allows us to know whether data can be collected from user’s web browser.

- Tracking user’s visits to this Site and allow us to recognise your device. Cookies store information about your use of our services , thus enabling us to provide more features that are useful to you, to tailor the content of our services to suit your interests.

- Cookies store user login data and other preferences. Users do not have to re-enter that information when user return to this Site.

Advertising cookies, record user’s visits to our services, user response to our online advertisements, track the web pages’ that user has visited and the website links that user has followed. We use cookies information to:

- Provide online advertisements or offers on our platform or third party websites, which are most likely to interest users.

- Make our platform more relevant to user’s interests.

The above cookies may be placed on user’s device by third parties (for example, advertising networks and providers of external services like web traffic analysis services). We will not share users’ personal data with third parties, except as stated in our privacy policy.

Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies. By disabling cookies, you may not be able to take full advantage of our platform.

Direct Marketing

We would like to use your personal data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. With your consent, we may (1) use your name, your address, telephone number, email address and/or account usage ("Marketing Data") to promote and market ; and (2) provide your Marketing Data to our affiliated companies and our Third Party Affiliates for them to promote and market, services, products and reward programmes of ours, our affiliated companies and our Third Party Affiliates. These services, products and reward programmes may include financial; block-chain technology, money lending, real estate services and products. We may receive some benefits for such provision of data.

If a data subject does not wish us to use his/her personal data for use in direct marketing as described above, the data subject may exercise his/her opt out right by contacting our Personal Data Privacy Officer of at telephone number 2250 1199 or email to

Access and Correction of Personal Data

You have the right:

To check whether we hold personal data about you and of access to such personal data;
To require us to correct any personal data relating to you which is inaccurate;
To ascertain our policies and practices in relation to personal data ;

Personal data provided by data subjects are retained for as long as the purposes for which such data were collected continue.

Please note that before we handle your personal data access or correct request, we may ask you for additional information to verify your identity. We will only use such information to verify your identity.

By using our services, you consent to our privacy policy.

We have the right to update our privacy policy any time without notice. In case of revision, our website will point to the latest policy statement and we may make an announcement in the news section.