This privacy policy covers how Rentolf Limited (“Rentolf”) treats personal information that Rentolf collects and receives, including information related to your past use of websites, mobile applications and services (collectively, the “Services”) provided by Rentolf through the website at https://www.rentolf.com, and all related domains and sub-domains, as may be amended or updated by us from time to time and/or the Rentolf mobile application software, including all its features and content and the services that Rentolf makes available on or through it, and any and all updates, upgrades, supplements, enhancements and releases thereto as may be provided by us from time to time (collectively, the “Platforms”).  Unless otherwise defined herein, capitalised terms used in this privacy policy (“Privacy Policy”) shall have the same meanings as those defined in our Terms of Service.

This Privacy Policy explains how we collect, hold, process, use, protect, store, share and transfer (collectively “Process”, and “Processing” shall be construed accordingly) information and/or data provided by you to us, including but not limited to your personal data and information when you use the Platforms. This Privacy Policy covers both the “online” (e.g., web and mobile services) and “offline” (e.g., collection of data through telephone calls or in person) activities owned, operated, provided and/or made available by us. This Privacy Policy specifically addresses our obligations in respect of personal data privacy under the relevant laws.

Please review this Privacy Policy carefully so that you understand our privacy policies and practices.

BY AGREEING TO GIVE US YOUR PERSONAL DATA WHILE UPON YOUR REGISTRATION TO THE PLATFORMS, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY AND GIVE US YOUR CONSENT TO PROCESS YOUR PERSONAL DATA.

We request all persons using the Platforms to voluntarily provide us with the Personal Data (as set out in section 1 below) for the purposes as set out in section 2 and section 4 below. Do not use the Platforms 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 provide Services to you if you do not provide such Personal Data to us. If you wish to revoke your agreement to the terms of this Privacy Policy, please notify us by sending an email to our Personal Data Privacy Officer in accordance with section 11 below or via any other means as prescribed by us from time to time. This Privacy Policy is an integral part of our Terms and Conditions.

We may update or change this Privacy Policy from time to time to reflect our latest privacy policies and practices as we deem fit pursuant to, inter alia, the prevailing relevant legislation and the changing business circumstances.  Whenever a change is made, we will seek your express consent, objection or no objection thereto on the Platforms. Any changes will be effective immediately upon posting of the revised Privacy Policy and your indication of consent or no objection thereto, whichever is later.  The revised Privacy Policy will then supersede and prevail over the original Privacy Policy and form an integral part of our Terms of Service.  You shall then be bound by such revised Privacy Policy.
Since we use the Google Maps Application Program Interface (API), Google’s Privacy Policy, as may be amended by Google from time to time, is incorporated by reference: http://www.google.com/privacy.html.

1. What Data do we Process?

Depending on the types of goods and/or services we provide to you, we may collect two basic types of Personal Data from you, namely “Personal Data” and “Non- Personal Data”.
“Personal Data” means any personally identifying data which we may collect from you when you seek product(s) and/or service(s) from us and include without limitation:
  1. your name, your email address, your address, your telephone number, and/or other contact details, as well as your location data (if you do not wish to provide us with location-tracking information, you may disable the GPS or other location-tracking functions on your online device. However, if such functions are disabled, you may not be able to use some of the Services);
  2. details about the device that you use to access the Platforms, which may include your IP address or other unique device address or identifiers;
  3. cookies information as set out in section 7 below;
  4. any other information provided by you pursuant to your use of the Platforms;
  5. if you contact us, a record of that correspondence.
  6. gender, photos, identification card number and any registration and/or profile information and reporting information about your use of the Platforms;
  7. details required (e.g. credit card, debit card or bank account numbers and details) in order to collect any fees from you and/or pay to you any fees as relevant;
  8. rating information (where other users of the Platforms are able to rate you as a lender/borrower);
  9. your page views and taps in app, in-app messages and search history; and
  10. your performance, operational and financial details.

You understand and acknowledge that this Privacy Policy may not apply to any unsolicited information which you provide to us through the Platforms or through any other means in certain regions where we operate. Where applicable, all unsolicited information shall be deemed to be non-confidential and we shall be free to Process, reproduce, disclose and distribute such unsolicited information to others without limitation or attribution.

“Non-Personal Data” includes aggregate and/or automatic information, which is data collected about the use of the Services (including without limitation our websites and/or mobile applications), or about a group or category of users from which individual identities or other individually identifiable information has been removed.  This Privacy Policy does not restrict or limit our collection, use and provision of Non-Personal Data.

2. What do we use the Personal Data for?

The purposes for our Processing of Personal Data on the Platforms and Services (“Purposes”) include the following:
  1. to verify your identity;
  2. provide the Services to you, including processing any orders and payments;
  3. to provider your personal contact information to lender/borrower in order to complete the rental process, including product listing, delivery and item return;
  4. to operate, protect, improve and optimize all the features of the Services; to improve and customize the user experiences and usage trends of the Platforms, and to develop new services, features and functionality;
  5. to notify you about changes to the Platforms or respond to any communication and/or request from you;
  6. to monitor the use of the Platforms;
  7. to investigate any reported incidents, complaints or potential breaches of the Services;
  8. where applicable and subject to compliance of the relevant laws, to provide you with marketing and promotional materials and messages in accordance with section 4 below;
  9. to identify whether you have enjoyed promotional benefits by receiving and using marketing and promotional materials;
  10. to compile aggregate statistics about you and to analyze the Platforms and Services usage;
  11. where applicable and subject to compliance of the relevant laws, to match the Personal Data with other Personal Data collected for other purposes and from other sources including third parties in relation to the provision of Services to you;
  12. to facilitate our Processing of the Personal Data for purposes relating to the provision of Services offered by us and marketing services, special events and/or promotions of us and/or our clients;
  13. to comply with our obligations under the applicable laws and regulations from time to time;
  14. to disclose to and/or assist relevant authorities where we suspect you have committed an offence, where we suspect existence of fraud or when required by the relevant laws or court orders, or as requested by relevant public and law enforcement authorities; and
  15. to design and provide products and services to you in relation to the above purposes.

We will seek your express consent to change how we Process the Personal Data if required by the relevant laws, but otherwise use of the Services following such changes constitutes your acceptance of the revised statement then in effect.

We also reserve the right to disclose your information that we believe, in good faith, is appropriate and necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, or the rights, property, or safety of others.

When you use our websites and/or mobile applications, we may keep an activity log that does not identify you individually and cannot be used to identify the identity of any particular user. Generally, we collect and store the following categories of Non-Personal Data:

  • information about your device that you use to access our websites and/or mobile applications. This information may include the device name, IP address, operating system and version, the type of network and mobile Internet browser you use, the browser’s type and configuration, the geo-location information and other unique device identifiers of the device, browsing preferences such as language settings and font size etc.; and
  • information about your use of the website and/or mobile application including without limitation the domain names you visit and the specific actions you take on the website and/or mobile application, the number of new or returning visits, statistics on the pages visited and referred, a reading history of the pages and sites you have visited and viewed, search terms used and search results, error and crash statistics, traffic data (such as time, duration and date of access).
The above Non-Personal Data are collected and used to measure traffic, gauge the popularity of various parts of our websites and/or mobile applications, to gain general knowledge about our audience and market our websites and/or mobile applications to advertisers with whom we may share summarized traffic data. We may also share to third parties (including without limitation to those specified under paragraph 3 below) these Non-Personal Data for customizing, enhancing, optimizing, maintaining and/or improving the quality of our websites and/or mobile applications, such as for determining the optimal screen resolution, language and font settings, etc. This Policy in no way restricts or limits our collection, use, handling and provision of Non-Personal Data.

3. Do we disclose any Personal Data to outside parties?

We generally only permit our duly authorised staff to access the Personal Data, and we will only release such Personal Data to third parties under the following circumstances:
  1. where the Personal Data is disclosed, provided and/or transferred to:
    1. any third-party suppliers or external service providers who have been duly authorised by us to use such Personal Data and who will facilitate the Services on the Platforms, under a duty of confidentiality;
    2. our agents who have been duly authorised by us to use such Personal Data;
    3. any other parties in connection with a sale or proposed sale of all or part of our business or portfolio of products or other assets;
    4. us, our business partners, and/or agents in connection with marketing and/or cross marketing about the goods or services which may be of your interest;
    5. any Outside Parties (as defined below) as set out in section 4 below;
  2. any borrower/lender for the purpose of completing the rental transaction and matters in relation thereto;
  3. to credit reference agencies, debt collection agencies, fraud detection and/or prevention agencies;
  4. to any relevant public authorities or law enforcement agencies, including, for example, where we suspect you have committed an offence, where we suspect existence of fraud or where required by applicable law, regulation or legal proceedings;
  5. in order to enforce or apply our Terms and Conditions of your use of the Platforms or any other agreement to which you and we are a party, as applicable; and
  6. where we deem necessary, in order to maintain and improve the Services.

We may transfer, disclose, grant access to or share certain Personal Data inside or outside of Hong Kong to companies working with us or on our behalf for the purposes described in this Privacy Policy to the extent permitted by law and subject to the fulfillment of the regulatory requirements of the applicable laws. The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes described in this Privacy Policy.

You should take care when using any Platforms social networking features since the Personal Data you disclose can be seen by other users. You understand and acknowledge that we cannot control the actions of other users of social networking features with whom you may choose to share the Personal Data with. We do not monitor the use of such features in the normal course of business although we reserve the right to do so at our discretion. Therefore, you understand and acknowledge that we cannot and do not guarantee that the Personal Data will not be reviewed by unauthorised persons.

4. Do we Process any Personal Data for marketing and promotional purposes?

We intend to and may from time to time make telephone calls to you or send you information directly by mail, fax, email or other means of communication based on the Personal Data in order to offer or advertise the availability of goods, facilities or services or to solicit donations or contributions for charitable, cultural, philanthropic, recreational, political or other purposes (“Direct Marketing”).

In particular, the following classes of services, products and subjects are intended to and may be marketed:
  1. transport, logistics and automotive related products and services;
  2. special events hosted by us for you and other users of the Platforms, including but not limited to competitions and social gatherings;
  3. reward, loyalty or privileges programmes in relation to the Services and related products;
  4. special offers in relation to the Services and related products, including but not limited to coupons, discounts, purchase offers and promotional campaigns;
  5. products and services offered by us and our business partners and agents which maybe of your interest;
  6. products and services offered by us and our advertisers (the names of which can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); and
  7. donations and contributions for charitable and/or non-profit making purposes.

The above products, services and subjects may be provided or solicited by us, third-party service providers providing the above services, products and subjects and charitable and/or non-profit making organizations (“Outside Parties”). We intend to and may provide the Personal Data to Outside Parties for use by them in marketing their above services, products and subjects.

We may not use the Personal Data in Direct Marketing or provide the Personal Data to Outside Parties for their use in Direct Marketing unless we have received your consent to such intended use.  Upon your registration to the Platforms, you will be directed to a page where you will be asked to express consent, objection or no objection to all or parts of our intended use of the Personal Data in Direct Marketing and to our intended provision of the Personal Data to Outside Parties for their use in Direct Marketing.  Your answer will be sent to and saved in our system.  You may also revise your setting in “Contact Information” on “My Profile” column.

Should there have been offline collection of your Personal Data (e.g., by telephone calls or in person), your consent will be asked by our staff orally to express consent, objection or no objection to all or parts of our intended use of the Personal Data in Direct Marketing and to our intended provision of the Personal Data to Outside Parties for their use in Direct Marketing.  Within 14 days after our staff’s receipt of your indication of consent or no objection, we will send you a written confirmation by email or by post for your record.

Please note that by indicating your objection to all or parts of our intended use of the Personal Data in Direct Marketing and to our intended provision of the Personal Data to Outside Parties for their use in Direct Marketing:

  1. you may not be able to use some or all of the Services; and
  2. may still receive non-marketing and non-promotional messages, including but not limited to product updates and service notices as permitted under applicable local laws and regulations.

When we use your Personal Data in Direct Marketing for the first time, we will remind you of your right to require us to cease such use.

You are entitled to require us to cease to use your Personal Data in Direct Marketing or to cease to provide your Personal Data to Outside Parties for their use in Direct Marketing at any time even after you have previously expressed consent or no objection to such use.

5. Can you access, correct, and erase your Personal Data?

You (or a relevant person on your behalf) have the right, if expressly permitted by relevant laws, to:
  1. check whether we hold any Personal Data and, if we hold the Personal Data, to receive copies of such Personal Data;
  2. request us to make necessary correction to any Personal Data which is inaccurate; and
  3. request us to erase any of your Personal Data in such form as you reasonably request on the Personal Data Access Request Form and within a reasonable time we will provide a mechanism to erase such Personal Data.
The Personal Data Request Form can be obtained from:  https://www.pcpd.org.hk/english/resources_centre/publications/forms/Dforme.pdf   The completed form should be sent to the Personal Data Privacy Officer in the Region in accordance with section 11.
  1. any other request that is expressly permitted by relevant laws.

Subject to relevant laws, we have the right to charge a reasonable fee for processing a Personal Data access request; and if expressly permitted by relevant laws, we shall provide you with an estimate of the fee after we receive a Personal Data access request from you.  However, the final fee to be charged may differ from the estimated fee.  If the final fee to be charged is higher than the estimated fee, we shall inform you of the higher fee.  Your Personal Data access request may be refused if you do not pay the fee.

The aforementioned requests in relation to the Personal Data may be made by contacting our Personal Data Privacy Officer by email or by post in accordance with section 11 below. Any such request should also clearly state the details of Personal Data in respect of which the request is being made and we may request you to prove your identity in relation to your request to access and/or correct and/or erase such Personal Data.

6. How do we protect the Personal Data?

We have adequate measures in place and will take all practicable steps to protect the Personal Data from unauthorised or accidental access, processing, erasure, loss or destruction. Where we have given you (or you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of Personal Data via the Internet is not completely secure. While we endeavour to protect your Personal Data, we cannot guarantee the security of Personal Data transmitted to the Services; any transmission is at your own risk. Once we have received the Personal Data, we will use strict procedures and security features to try to prevent unauthorised access. In case of cyber-security risks, we may issue warnings and provide instructions, guidance or suggestions in relation to coping measures to you in accordance with the relevant laws.

7. Do we use cookies?

We use Google Analytics to help analyse how users use the Platforms and Services. Google Analytics is a web analysis service provided by Google LLC. Google utilises the Personal Data collected to track and examine the use of our Platforms and Services, to prepare reports on its activities and share them with other Google services. Google may use the Personal Data collected to contextualise and personalise the advertisements of its own advertising network. Google Analytics features implemented on this site include Display Advertising (Demographics and Interest Reporting). Google’s ability to use and share information collected by Google Analytics regarding your visits to the Platforms is restricted by the Google Analytics Terms of Service.

We do use certain cookies (such as Google Analytics’ cookies) and other similar technologies as part of our Services. The cookies used are for the purposes of enabling you to use the Services (for example, to enable you to complete a registration or access information) and for us to understand and save your preferences for future visits, analyse usage patterns, keep track of advertisements and compile aggregate Personal Data about site traffic and site interaction so that we can offer better site experiences and tools for the Platforms in the future. We may contract with third-party service providers to assist us in better understanding our site visitors in accordance with this Privacy Policy.

You can choose to disable cookies (through changing your browser or device settings) although you should be aware that this may prevent you from being able to use all of the Services.

For further details about the cookies we use, please see our Cookies Policy which can be found here: [link to cookies policy]

8. Retention of Personal Data

Once we have obtained the Personal Data, it will be maintained securely in our system; and subject to legal requirements expressly provided in relevant laws and our internal policy, may be retained by us after deactivation of the relevant Services where such Personal Data is still required for the purpose for which it was Processed.

Once your Personal Data is no longer necessary or required for the purposes stated in section 2 above and any directly related purposes or is inaccurate, we will take all practicable steps to erase such Personal Data as soon as reasonably practicable unless any such erasure is prohibited under any law or it is in the public interest for the Personal Data not to be erased.

9. Links to third-party websites

Subject to this Privacy Policy, at our discretion, we may include or offer third-party products or services on the Platforms. You understand and acknowledge that the fact that we may include or offer third-party products or services on the Platforms does not mean that we endorse or authorise the collection of Personal Data by such third parties, nor does it constitute a representation of any affiliation between us and such third parties. You understand and acknowledge that:

  1. once you click on a link to third-party websites, applications or advertisements, you will access third-party websites, applications and advertisements which may collect Personal Data;
  2. such third-party websites, applications and advertisements follow separate and independent privacy policies regarding the Processing of the Personal Data you submit to them; and
  3. hence, we have no responsibility or liability for the content and activities of these linked websites, applications and advertisements (including any Processing of the Personal Data by such third parties)

Nonetheless, we seek to protect the integrity of the Platforms and welcome any feedback about these sites.

10. Personal Data of minors and/or other individuals

In some circumstances, you may have provided Personal Data relating to minors and/or other individuals (e.g., individuals who are incapable of managing his or her own affairs or mentally incapacitated persons within the meaning of the Mental Health Ordinance (Cap.136)) and in such circumstances you represent and warrant that you are authorised to provide the Personal Data to us and you have obtained their consent for the Personal Data be Processed in the manner as set forth in this Privacy Policy.

Where applicable, as a parent or legal guardian, please do not allow the minor(s) under your care to submit the Personal Data to us.  In the event that such Personal Data is provided to us, you hereby consent to the Processing of the minor’s Personal Data and personally accept and agree to be bound by this Privacy Policy and take responsibility of his or her actions.

If we learned that Personal Data has been collected on the Service from a minor and without verifiable parental consent, then we will take the appropriate steps to delete the Personal Data information. If you are a parent or legal guardian and discover that a minor under your care has obtained an account on the Service, then you  may alert our Personal Data Privacy Officer at the contact in section 11 and request that we delete that minor’s Personal Data information from our systems.

11. Personal Data Privacy Officer contact details

Your requests shall be sent to the Personal Data Privacy Officer below:
  1. If by email, please send your requests to: pdpo@rentolf.com
  2. If by post, please send your requests to: Unit 601, 6/F of Mill 5 of The Mills, No. 45 Pak Tin Par Street, Tsuen Wan, N.T., Hong Kong

Where applicable, as a parent or legal guardian, please do not allow the minor(s) under your care to submit the Personal Data to us.  In the event that such Personal Data is provided to us, you hereby consent to the Processing of the minor’s Personal Data and personally accept and agree to be bound by this Privacy Policy and take responsibility of his or her actions.

If we learned that Personal Data has been collected on the Service from a minor and without verifiable parental consent, then we will take the appropriate steps to delete the Personal Data information. If you are a parent or legal guardian and discover that a minor under your care has obtained an account on the Service, then you  may alert our Personal Data Privacy Officer at the contact in section 11 and request that we delete that minor’s Personal Data information from our systems.