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Privacy Policy


Version 2.0

April, 2020

Control Free Ltd. (“Control Free”, "Company", "we", "us", or "our") respects the privacy of the users ("user" or "you") of our mobile application and website located at, including other media forms and media channels related or connected thereto (collectively, the "Service"). This Privacy Policy applies to data collected by us through this Service and the services offered on this Service as well as any offline support services.





We may, in our sole discretion, change this Privacy Policy from time to time. Each time you use this Service, the current version of this Privacy Policy will apply. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised terms on this Service. Accordingly, each time you use this Service you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used this Service.




This Service is hosted in the Hong Kong Special Administrative Region (“HKSAR”) and is subject to law of Hong Kong. If you are accessing our Service from other jurisdictions, please be advised that you are transferring your personal information to us in the HKSAR, and by using our Service, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by those laws of Hong Kong concerning your use of this Service and your agreements with us. If you are accessing this Service from any jurisdiction with laws or regulations governing the use of the Internet (including personal data collection, use and disclosure) that are different from those of the jurisdictions mentioned above, you may only use this Service in a manner lawful in your jurisdiction. If your use of this Service would be unlawful in your jurisdiction, please do not use this Service.




Minors under the age of 18 may not use this Service. We do not knowingly collect personal information from anyone under the age of 18, and no part of this Service is designed to attract anyone under the age of 18.

If we learn that personal information has been collected from a user under 18 years of age on or through this Service, then we will make reasonable efforts to cause this information to be deleted. If you are the parent or legal guardian of a child under 18 who has become a member of the Service or has otherwise transferred personal information to this Service, please contact us using our contact information below to have that child's account terminated and information deleted.




This Service collects two types of information: (a) information that personally identifies you that you provide directly when you use various services (such as your name and e-mail address) ("Personally Identifiable Information"); and information that does not personally identify you that may be gathered by means such as analyzing usage and navigation patterns (such as the number of users who log onto this Service on a daily basis) as well as device state information used in our automation and learning scenarios ("Non-Personally Identifiable Information").

Non-Personally Identifiable Information

"Non-Personally Identifiable Information" is information that, without the aid of additional information, cannot be directly associated with a specific person.

From time to time we may collect Non-Personally Identifiable Information such as how many users visit a specific page on this Service, how long a use stays on a page, the user's operating system and browser type and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving this Service. We collect this information through the use of technologies such as "cookies" and "IP addresses," which are discussed in greater detail below.

We analyze Non-Personally Identifiable Information gathered from users of this Service to help us better understand how this Service is being used. By identifying patterns and trends in usage, we are able to better design this Service to improve users' experiences, both in terms of content and ease of use.

We may share Non-Personally Identifiable Information we collect under any of the above circumstances with third parties and our affiliate companies to develop targeted recommendations of products or content and services that we hope you and other users will find of interest. We may combine Non-Personally Identifiable Information we collect with additional Non-Personally Identifiable Information collected from other sources and share this aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of users of this Service and the most popular features or services accessed. However, please be assured that this information does not contain any Personally-Identifiable Information.

Personally-Identifiable Information

"Personally-Identifiable Information," in contrast to "Non-Personally Identifiable Information", is information such as a name or e-mail address that, without more, can be directly associated with a specific person.

Any information that you submit on this Service will be used (a) to authenticate your identity for access to our services; (b) to carry out your requests and respond to your inquiries; (c) in accordance with the terms of this Privacy Policy; and (d) as otherwise disclosed at the point where such information is collected. In addition, we may use your information as follows:

Company and Marketing Communications. We may use your name and e-mail address to send you notifications regarding new services offered by this Service that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such e-mails at the time of registration or through your account settings, though we reserve the right to send you notices about your account even if you opt out of all voluntary e-mail notifications.

Affiliates. We may share some or all of your Personally-Identifiable Information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include a parent company or any subsidiaries, joint venture partners, or other companies that we control or that is under common control with us.

Third Party Service Providers. We may share your Personally-Identifiable Information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through this Service. These service providers may have access to Personally-Identifiable Information to the extent needed to perform their functions but are not permitted to share or use such information for any other purpose.

We reserve the right to disclose any Personally-Identifiable Information or Non-Personally Identifiable Information if we believe disclosure is appropriate in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies; in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.




We want to be sure that we keep only the most accurate and up to date information about you in our records. If you wish to update your account information, log into your account. If you forget your password, you can reset it via the registered user sign-in page. If you wish to cancel your registration, please contact We will retain in our files some personal information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your personal information will be completely removed from our databases in response to your requests. Even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users. Additionally, we keep a history of changed information to investigate suspected fraud with your account.




In our contracts with our contractors, affiliates, vendors and suppliers, we prohibit them from disclosing Personally-Identifiable Information received from us, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to information that you provide directly to those third parties or that those third parties collect for themselves.




This Privacy Policy only addresses the use and disclosure of information we collect from you on or relating to this Service. Other websites that may be accessible through this Service have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you review that website's privacy policy. We are not responsible for the policies or practices of third parties.




We have reasonable and appropriate security measures in place in an effort to protect against loss, misuse and alteration of the information under our control. For example, this Service encrypts sensitive information such as your password and your Personally-Identifiable Information using secure socket layer (SSL) technology to provide for the secure transmission of the information from your computer or mobile device to our servers. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. In addition, we cannot control the actions of others with whom you share your information. Therefore, we cannot guarantee or warrant the security of any information transmitted to or from this Service and are not responsible for the theft, destruction or inadvertent disclosure of your information.

If you have registered on this Service, access to your account is protected by your password. We recommend that you do not disclose your password to any other person, that you include a combination of letters and numbers in your password and that you change your password often. You are solely responsible for maintaining the confidentiality of your password and account and are fully responsible for all activities that occur under your password or account. You agree to notify us immediately of any unauthorized use of your user name, password or account, either with or without your knowledge. We will not be liable for any loss that you may incur as a result of someone else using your user name, password or account. However, you could be held liable for losses incurred by us as a result of the misuse of your user name, password or account.



As we continue to develop our business, we may sell or purchase assets or other businesses. In the event of a merger, acquisition or other sale of all of our assets or assets relating to this Service, all Personally-Identifiable Information, Non-Personally Identifiable Information and any other information that we have collected about our users will be transferred to such entity as one of the transferred assets. If any bankruptcy or other reorganization proceeding is brought by or against us, all such information may be considered as asset of ours and may be sold or transferred to third parties.




This Privacy Policy and our Terms of Use constitute the entire agreement relating to the use of this Service. Our failure to enforce any right or provision of this Privacy Policy does not constitute a waiver of that right or provision. If any provision of this Privacy Policy is held to be invalid or unenforceable for any reason, the remaining provisions will continue in full force without being impaired or invalidated in any way.




If you have any questions regarding our Privacy Policy, please contact our privacy officer at:

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