Privacy Policy.

01Introduction

This Privacy Policy ("Policy") explains how VESPERA TECHNOLOGY LIMITED ("Vespera", "we", "us" or "our") handles personal information when you visit www.vesperahk.com (the "Site"), contact us, or use any web or mobile product operated by us (collectively, the "Services").

We are committed to handling personal information responsibly and in accordance with applicable data protection laws, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and, where applicable to users in other jurisdictions, the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act as amended ("CCPA").

By accessing the Site or using the Services, you acknowledge that you have read this Policy. If you do not agree with it, please do not use the Site or the Services.

02Who we are / Data controller

For the purposes of applicable data protection law, the data controller is:

VESPERA TECHNOLOGY LIMITED
RM A1, 11/F WINNER BLDG, 36 MAN YUE ST, HUNG HOM, HONG KONG
Telephone: +852 6066 6034
Email: contact@vesperahk.com

Vespera is a technology company developing web and mobile products for the production, distribution and monetisation of serialised online fiction. Where a Vespera product is operated jointly with a partner, that partner may act as an independent or joint controller for specific processing activities; in such cases a separate notice will be provided within the relevant product.

03Information we collect

We may collect the following categories of information:

• Information you provide directly: name, company or organisation, email address, telephone number, and the content of your message when you submit an enquiry form or correspond with us; account registration details where a product requires an account; and any content you voluntarily submit to a Service.
• Technical and usage information: IP address, browser type and version, device type, operating system, language preference, referring URL, pages viewed, features used, access times, and approximate location derived from an IP address.
• Cookies and similar technologies: identifiers stored on your device as described in Section 06.
• Transaction information: where a Service offers paid access, records of the access model, transaction date and amount. Payment card details are processed by our payment service providers and are not stored on our servers.
• Reading and preference information: titles followed, chapters read, bookmarks and reading settings, used to provide and improve the reading experience.

We do not knowingly collect sensitive personal data (such as health, biometric or political information) through the Site.

04How we collect information

We collect information (a) directly from you when you fill in a form, create an account, subscribe to communications or contact us; (b) automatically through server logs, cookies, pixels and similar technologies when you interact with the Site or the Services; and (c) from third parties such as analytics providers, payment providers, app stores and business partners, where permitted by law and consistent with their own privacy notices.

05How we use information / Legal bases

We use personal information to:

• operate, maintain and secure the Site and the Services;
• respond to enquiries, provide support and communicate with you about our products;
• create and administer accounts, deliver purchased access and process transactions;
• personalise the reading experience, remember preferences and synchronise reading progress across devices;
• analyse aggregate usage to improve performance, content and product design;
• detect, investigate and prevent fraud, abuse, security incidents and violations of our Terms of Service;
• comply with legal obligations, respond to lawful requests and enforce our agreements; and
• send service or marketing communications where you have consented or where otherwise permitted by law.

Where the GDPR applies, we rely on the following legal bases: performance of a contract, compliance with a legal obligation, our legitimate interests in operating and improving the Services (balanced against your rights), and consent where required. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

We do not sell personal information, and we do not share it for cross-context behavioural advertising.

06Cookies and similar technologies

The Site uses cookies and local storage to keep it working and to understand how it is used. Categories include:

• Strictly necessary: required for core functionality, security and session management. These cannot be switched off in our systems.
• Preferences: remember choices such as language, theme and reading settings.
• Analytics: help us understand aggregate traffic and feature usage. Our corporate website currently uses only first-party, non-advertising measurement.

You can control or delete cookies through your browser settings. Blocking strictly necessary cookies may prevent parts of the Site from functioning. Mobile applications may use device identifiers with equivalent controls available in your device settings. Where a consent banner is required in your jurisdiction, non-essential cookies are set only after you consent.

Some externally hosted resources used by the Site (for example web fonts and embedded map services) are provided by third parties that may receive technical information such as your IP address in order to deliver those resources. See Section 13.

07Sharing and disclosure

We may disclose personal information to:

• Service providers: hosting, content delivery, analytics, email delivery, payment processing, customer support and security vendors who process information on our instructions and under contractual confidentiality obligations.
• Professional advisers: auditors, insurers, lawyers and accountants where necessary for the operation of our business.
• Business partners: publishers, licensors and distribution partners, but only where relevant to a service you have requested and subject to appropriate safeguards.
• Authorities: where required by law, court order, or a valid request from a regulator or law enforcement agency, or where necessary to protect the rights, property or safety of Vespera, our users or others.
• Corporate transactions: in connection with a merger, financing, reorganisation or transfer of business assets, subject to continued protection of the information and notice of any change of controller.

We require recipients to use personal information only for the purposes for which it was disclosed and to apply appropriate security measures.

08International data transfers

We are based in Hong Kong and our service providers may process information in other jurisdictions. Where personal information is transferred to a country with different data protection laws, we take reasonable steps to ensure an adequate level of protection, including contractual safeguards, standard contractual clauses where applicable, and technical measures such as encryption in transit.

09Data retention

We retain personal information only for as long as necessary for the purposes described in this Policy, including to provide the Services, comply with legal, accounting and reporting obligations, resolve disputes and enforce agreements. Retention periods vary by category: enquiry correspondence is generally retained for up to 24 months, account information for the life of the account plus a reasonable wind-down period, and technical logs for up to 12 months unless a longer period is required for security or legal reasons. When information is no longer needed, it is deleted or anonymised.

10Data security

We implement administrative, technical and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include encrypted transport (TLS), role-based access controls, least-privilege principles, logging and periodic review of our practices. No method of transmission or storage is completely secure; if you believe your interaction with us is no longer secure, please contact us immediately at contact@vesperahk.com.

11Your rights and choices

Subject to applicable law, you may have the right to:

• request access to the personal information we hold about you and receive a copy;
• request correction of inaccurate or incomplete information;
• request deletion of your information, subject to legal retention requirements;
• object to, or request restriction of, certain processing;
• request portability of information you provided to us;
• withdraw consent where processing is based on consent; and
• opt out of marketing communications at any time by using the unsubscribe link or contacting us.

To exercise a right, email contact@vesperahk.com with the subject line "Data Subject Request". We may need to verify your identity before acting on a request and will respond within the period required by applicable law. You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data in Hong Kong or with the relevant supervisory authority in your place of residence.

12Children's privacy

The Site is a corporate website and is not directed at children. Our reader products may contain age-restricted content and are intended for users who have reached the age of digital consent in their jurisdiction. We do not knowingly collect personal information from children under the age of 13 (or the applicable local minimum age). If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

13Third-party links and embedded services

The Site may link to third-party websites or embed third-party resources such as web fonts and map services. These third parties operate under their own privacy policies and terms. We do not control and are not responsible for their content or data practices. We recommend reviewing their policies before providing any personal information to them. External map links on our Contact page will take you to a third-party map service, whose own terms and privacy policy will then apply.

14Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, products or legal obligations. The "Effective date" at the top of this page indicates when the Policy was last revised. Where changes are material, we will take reasonable steps to notify you, such as by posting a prominent notice on the Site or within the relevant Service. Your continued use of the Site or Services after the revised Policy takes effect constitutes acceptance of the changes, to the extent permitted by law.

15Contact us

For any question about this Policy, to exercise a data protection right, or to raise a privacy concern, please contact:

VESPERA TECHNOLOGY LIMITED
RM A1, 11/F WINNER BLDG, 36 MAN YUE ST, HUNG HOM, HONG KONG
Telephone: +852 6066 6034
Email: contact@vesperahk.com
Website: www.vesperahk.com

We aim to acknowledge privacy enquiries within five business days.