Privacy Policy

Hong Kong Privacy Compliance Statement

FUTURE OUTLOOK TECHNOLOGY LIMITED (“ManaBuy”, “we”, “us” or “our”) respects personal data privacy and is committed to handling personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and the applicable Data Protection Principles.

1. Collection of Personal Data

When we collect personal data directly from you, including through account registration, order placement, payment, customer support requests, promotional activities, or use of our website or mobile application, we will take reasonably practicable steps to inform you of:

• the purposes for which the personal data is collected and will be used;
• whether the provision of the personal data is mandatory or voluntary;
• the consequences of failing to provide personal data that is mandatory for the relevant service or transaction;
• the classes of persons to whom the personal data may be transferred or disclosed, where applicable; and
• your rights to request access to and correction of your personal data, and the means by which such requests may be made.

We may provide this information in this Privacy Policy, in a notice displayed on the relevant webpage or application screen, or in a separate Personal Information Collection Statement presented at or before the time personal data is collected.

2. Purposes of Use

We may collect, hold, process, use and disclose your personal data for the following purposes:

• creating, verifying, administering and securing your ManaBuy account;
• processing orders, payments, refunds, chargebacks, fraud reviews and related transactions;
• delivering digital goods, game top-ups and related customer services;
• communicating with you about orders, account activity, service notices, support requests and disputes;
• detecting, preventing and investigating fraud, unauthorised transactions, abuse, security incidents and violations of our Terms of Service;
• complying with applicable legal, regulatory, tax, accounting, audit, anti-money laundering, sanctions and law-enforcement requirements;
• maintaining, improving and protecting our website, mobile application, services and systems;
• conducting internal analytics, research, service improvement and business administration; and
• where permitted by applicable law and with any consent required by law, sending direct-marketing communications about our products, services, promotions or offers.

We will not use your personal data for a purpose that is inconsistent with the purpose for which it was collected unless we have obtained your consent or are otherwise permitted or required to do so by applicable law.

3. Disclosure and Transfer of Personal Data

We may disclose or transfer personal data, on a need-to-know basis, to the following categories of recipients:

• payment processors, banks, card schemes and payment service providers;
• game publishers, authorised distributors, fulfilment providers and other service partners necessary to complete an order or deliver a digital product;
• cloud hosting, data storage, cybersecurity, analytics, customer support, communications and technology service providers;
• professional advisers, including legal advisers, auditors, insurers and accountants;
• government authorities, regulators, law-enforcement agencies, courts or other parties where disclosure is required or permitted by applicable law; and
• a purchaser, successor, assignee or prospective purchaser in connection with a merger, acquisition, financing, sale of assets, corporate restructuring or similar transaction.

Where we engage a service provider to process personal data on our behalf, we will take reasonably practicable steps to require that provider to protect the data and use it only for authorised purposes.

4. Cross-Border Data Transfers

Your personal data may be stored, processed or accessed outside Hong Kong by ManaBuy, its affiliates, payment providers, service providers or business partners. Where personal data is transferred outside Hong Kong, we will take reasonably practicable steps to ensure that the data receives a level of protection appropriate to the nature of the information and the applicable legal requirements.

5. Retention and Security

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, to provide our services, to resolve disputes, to enforce our agreements, or to comply with applicable legal, regulatory, tax, accounting and record-keeping obligations.

We maintain reasonable technical, organisational and administrative safeguards designed to protect personal data against unauthorised or accidental access, processing, erasure, loss, use, modification or disclosure. These measures may include access controls, encryption where appropriate, security monitoring, authentication measures, staff confidentiality obligations and incident-response procedures.

No method of transmission over the Internet or electronic storage is completely secure. While we take reasonable steps to protect personal data, we cannot guarantee absolute security.

6. Data Access and Correction Requests

Subject to the PDPO and any applicable legal exceptions, you may request:

• confirmation as to whether we hold personal data relating to you;
• access to personal data that we hold about you; and
• correction of personal data that is inaccurate.

To make a data access request, data correction request, or other privacy-related enquiry, please contact us at:

We may need to verify your identity before processing a request. We may charge a fee for a data access request where permitted by the PDPO, and will notify you of any applicable fee before processing the request.

7. Direct Marketing

We may use your name, contact details, account information, purchasing preferences and usage information to send you information about ManaBuy’s products, services, promotions and offers, but only where permitted by applicable law and, where required, with your consent.

You may withdraw your consent to receive direct-marketing communications at any time by using the unsubscribe function in the relevant communication or by contacting us at [email protected]. Withdrawal of consent will not affect the lawfulness of processing that occurred before the withdrawal.

8. Updates to This Statement

We may update this Hong Kong Privacy Compliance Statement from time to time to reflect changes in our services, data-handling practices or legal obligations. The latest version will be published on our website and will take effect on the date stated in the updated Privacy Policy.

1. Information We Collect

To provide our services and improve the user experience, we may collect the following types of personal information:

1.1 Information You Provide

The personal information you voluntarily provide to us while using our services includes, but is not limited to:

• Identity Information: such as name, gender, email address, phone number, username, profile picture, etc.
• Account Information: including information provided during account creation (e.g., password, registration date, account type) and any data related to your account activities.
• Payment Information: such as credit card number, payment account information, billing address, etc., used for processing orders and payments.
• Communication Records: such as records of your interactions with our customer support, including emails, phone calls, and online chat logs.

1.2 Information We Automatically Collect

When you use our services, we automatically collect certain technical information, including but not limited to:

• Device Information: such as device type, operating system version, IP address, browser information, device identifiers, geographical location data (e.g., GPS data), etc.
• Usage Data: including logs of your visits to our website or app, behavioral data (such as pages visited, click history, time spent on pages), and interactions with our services.
• Transaction Information: including your order history, purchased product details, payment method, payment status, etc.

1.3 Information We Collect From Third Parties

In some cases, we may collect your personal information from third parties, including:

• Social Media Account Information: If you log in using a social media account, we may collect your public information (such as name, profile picture, etc.) from the social platform.
• Partner-provided Information: We may obtain information about you from our business partners, advertisers, or third-party providers, such as purchase records or usage data related to our services.

2. How We Use Personal Information

We use the personal information we collect for the following purposes:

2.1 Providing and Improving Our Services

We use your personal information to provide and enhance our services. This includes:

• Account Management: We use your account information to create, maintain, and manage your account, ensuring you can easily access and use our platform.
• Transaction Processing: We use your payment information to process orders, complete payment transactions, and provide related financial records.
• Customer Support: We use your communication records and account information to respond to your requests, provide customer support, and resolve issues you encounter while using our services.

2.2 Personalizing and Optimizing User Experience

We analyze your personal information and usage data to provide a more personalized experience and improve our services, including:

• Personalized Content and Advertising: Based on your preferences, browsing history, and purchase behavior, we may send targeted advertisements, product recommendations, or promotional offers to improve your experience.
• Optimizing Website and App Functionality: By analyzing your behavior data, we continually improve the features and layout of our website and app to enhance your overall user experience.

2.3 Security and Fraud Prevention

We use your personal information to ensure the security of our services and to prevent fraudulent activities. This includes:

• Account Security: We use your account information to verify your identity, prevent unauthorized access, and protect your account.
• Fraud Detection: By analyzing your transaction data and device information, we can detect and prevent fraudulent activities.

2.4 Legal Compliance and Dispute Resolution

We use your personal information to comply with legal obligations and protect our legitimate interests. This includes:

• Compliance with Legal Requirements: We may use your personal information to comply with applicable laws, regulations, and government requests.
• Dispute Resolution: In case of a dispute or legal proceeding, we may use your personal information to protect our legal rights.

2.5 Marketing and Advertising Activities

We may use your personal information for marketing and advertising purposes, including:

• Advertising and Market Analysis: Based on your personal information and usage data, we may send you targeted ads or promotions via email, SMS, or in-app notifications.
• Promotional Campaigns: We may use your information to send updates on products, services, or events, including discounts, promotions, and special offers.

2.6 Research and Development

We use your personal information for data analysis, research, and surveys to improve our services and technology:

• User Behavior Analysis: By analyzing your usage data and behavior patterns, we can better understand user needs and optimize product features.
• Product Innovation: We conduct research based on your feedback and usage patterns to develop new features or services that enhance your user experience.

2.7 Mergers and Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of the transaction. We will ensure that any such transfer complies with privacy protection requirements and notify you accordingly.

3. How We Share Personal Information

We may share your personal information with third parties in the following situations:

• Service Providers and Partners: To provide or support our services, we may share personal information with our third-party service providers, such as payment processors, data storage providers, customer support, advertising services, data analytics, etc.
• Advertising Partners: For targeted advertising and market analysis, we may provide anonymous or aggregated user data to advertising partners.
• Legal Compliance: We may disclose your personal information when required by law or government authorities. For example, in response to a subpoena, law enforcement requests, or to prevent fraud.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to relevant parties as part of the transaction.
• Other Third Parties: We may disclose your personal information to other third parties when we have a legitimate reason or with your consent.

We ensure that all third parties with whom we share your personal information comply with strict privacy protection agreements and take appropriate security measures to protect your data.

4. Your Rights

Under applicable laws, you have the following privacy rights:

• Access: You have the right to request a copy of the personal information we hold about you.
• Correction: If your personal information is inaccurate, you have the right to request that we correct or update that information.
• Deletion: You may request that we delete the personal information we hold about you, provided that the data is no longer necessary or you withdraw your consent.
• Data Portability: In certain cases, you have the right to request that we provide your personal information in a structured, commonly used format and transfer it to another company.
• Restriction of Processing: In certain cases, you have the right to request that we suspend or limit the processing of your personal information.
• Objection: You have the right to object to our processing of your personal information based on legitimate interests, especially in relation to direct marketing.
• Withdrawal of Consent: You may withdraw your consent for any data processing activities based on consent, such as direct marketing, at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

If you wish to exercise your privacy rights, please contact us using the details provided in the "Contact Us" section below.

5. Data Security Measures

We take the security of your personal information seriously and implement a variety of technical and administrative measures to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include:

5.1 Encryption Technologies

• Transmission Encryption: We use encryption technologies (such as SSL/TLS encryption protocols) to protect your personal information transmitted through our platform, ensuring the security of the data during transmission.
• Storage Encryption: We encrypt sensitive information, such as payment details and account passwords, to enhance the security of data stored in our systems.

5.2 Access Control

• Authorized Access: We only allow authorized personnel to access your personal information, and all access is strictly managed and monitored.
• Multi-factor Authentication: To further enhance security, we may require multi-factor authentication when logging in or performing sensitive operations, ensuring that only verified users can access their accounts and information.

5.3 Firewalls and Security Monitoring

We use firewalls, intrusion detection systems, and other security tools to monitor and protect our network infrastructure, preventing unauthorized access, attacks, or malicious activity.

5.4 Regular Security Audits

We conduct regular security reviews and vulnerability scans to identify and patch potential security weaknesses and assess the effectiveness of our security measures to ensure continuous improvement in data protection.

5.5 Data Backup and Recovery

We regularly back up stored data and ensure that in the event of system failure or other unforeseen incidents, we can quickly recover your data, minimizing the risk of data loss.

5.6 Security Incident Response

In the event of a data breach or other security incidents, we will promptly initiate our security response procedures, notify affected users, and take corrective actions to mitigate any damage.

Although we have implemented these security measures, please note that no technology can guarantee 100% security, and we cannot guarantee the absolute security of your information during transmission and storage.

6. Cookies and Similar Technologies

To provide a better user experience, we use cookies and other similar technologies (such as web beacons, pixel tags, etc.). These technologies help us collect and store certain information about you, including:

6.1 Purpose of Using Cookies

• Enhancing User Experience: We use cookies to remember your login status, settings preferences, and other personalized features, ensuring a smoother experience while using our services.
• Analysis and Optimization: By using cookies, we collect data about your visits to our website and use of our apps, such as pages visited, time spent, click behavior, etc. This information helps us optimize the structure and functionality of our website, improving your user experience.
• Advertising: We may use cookies for targeted advertising, delivering relevant content based on your interests and browsing history to improve the relevance of ads.

6.2 Third-party Cookies

In certain cases, our services may use third-party cookies, such as:

• Advertising and Analytics Partners: We may partner with advertisers, analytics companies, and other third parties who use their cookies for targeted advertising, statistical analysis, and market research.
• Social Media Plugins: If you log in via social media or share our content on social media platforms, those platforms may use cookies to track your activities.

6.3 Cookie Management

• Disabling Cookies: Most browsers allow you to manage and control the use of cookies. You can disable cookies or delete stored cookies through your browser settings. However, please note that disabling cookies may affect your experience on certain services, and some features may not function properly.
• Opting Out of Ad Tracking: If you do not wish to receive personalized ads, you can opt out of cookie-based ad tracking. The specific method for opting out can be found in the privacy policies or opt-out options provided by relevant advertising partners.

6.4 Web Beacons and Pixel Tags

We may use web beacons or pixel tags to collect information about your visits and interactions. These technologies are typically embedded in web pages or emails to track whether an email is opened or a webpage is visited.

6.5 Use of Similar Technologies

In addition to cookies, we may also use other similar tracking technologies, such as local storage, HTML5 storage, etc., to store user settings, preferences, or other content. The usage and management of these technologies are similar to cookies.

You can reject cookies through your browser settings, but this may affect your experience with certain features of our services. For more information on cookie management and choices, you can refer to our Cookie Policy.

7. Children's Privacy Protection and Parental Responsibility

We are committed to protecting children's privacy. Our services are not intended for children under the age of 18, and we do not knowingly collect any personal data or non-personally identifiable information from children under 18. As a parent or legal guardian, please do not allow your child to submit personal data to us. As a parent or legal guardian, you have the right to know whether your child has provided personal information to us, and you can request that we delete the relevant information. You can exercise this right by contacting us at [email protected].

We strongly encourage parents and guardians to supervise their children's internet use, especially regarding how personal information is handled, to ensure the privacy and safety of children. We comply with applicable privacy protection laws and regulations (such as the Children's Online Privacy Protection Act, COPPA), ensuring that we obtain parental or guardian consent when processing personal information of children under 18 and providing parents with the ability to access, delete, and modify their child's information.

8. Privacy Policy Updates

We may update this Privacy Policy from time to time to reflect changes in services, legal requirements, or technology. Each time we make an update, we will publish the latest version of the Privacy Policy on our website or app and indicate the update date. Please review the Privacy Policy regularly to stay informed about the latest information. By continuing to use our services, you accept the updated Privacy Policy.

9. California Privacy Rights

Under the California Consumer Privacy Act (CCPA), if you are a resident of California, you have the right to:

• Know: Request to know what personal information we collect, use, disclose, and sell.
• Delete: Request that we delete the personal information we have collected, unless there is a legal exception.
• Opt-out of Sale: Request to opt out of the sale of your personal information, particularly for personalized advertising.
• Identity Verification: We may ask you to provide information to verify your identity. You may also authorize an agent to make a request on your behalf, but it must meet the relevant legal requirements.
• Non-Discrimination: Exercising the above rights will not affect the quality or price of goods or services you receive.
• Third-party Disclosure: You may also request to know if we have disclosed your personal information to third parties for direct marketing purposes.

To exercise these rights, please contact us at [email protected].

10. Contact Us

If you have any questions, concerns, or wish to exercise your privacy rights under this Privacy Policy, please contact us at: [email protected].