Privacy Policy (Hong Kong)

Effective Date: September 23, 2024

1. Policy

Welcome to Yeti Confetti Kids! We, Lirvana Labs, Inc. (“Company” or “we” or “us” or “our”), are committed to processing personal information (“Data”) that we may collect from or about you when you use our software program Yeti Confetti Kids (the “Service”), in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”). This Privacy Policy describes the Data we may collect from you and how we may use and disclose it.

By using the Service, you agree to the collection and use of your Data in the manner described in this Privacy Policy.

Failure to supply Data requested by the Company may result in the Company being unable to process your registration, request for information or services, enquiries and/or provide services or products to you if the processing of such Data is necessary for such purpose(s).

In this Privacy Policy, any representation of “you”, “your”, or any equivalent expression refers to the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. “Group Company” means Company and its holding companies, branches, subsidiaries, representative offices and affiliates, wherever situated, and any one of them. Affiliates include branches, subsidiaries, representative offices and affiliates of the Company’s holding companies, wherever situated (collectively, the “Group”).

2. Data Collection

We collect a variety of Data that you provide directly to us through, but not limited to, the following ways:

1. using the Service through any media, including website and mobile apps;
2. signing up for a user account;
3. updating a user profile;
4. signing up or agreeing to receive messages from us; and
5. sending email messages and attachments to the Company.

The Data that we may collect, use and hold from time to time may include:

1. Personal Identification Data

While using our Service, we may ask you to provide us with certain Data that can be used to contact or identify you or to process payment for the Service. This may include your:

• Child preferred name (not first and last name nor legal name)
• Teacher preferred name
• Teacher and parent email addresses
• Phone number
• Other contact details

2. Usage Data; Use of Cookies

When you use our Service, we and our service providers (which are third parties that work on our behalf) collect information by using cookies. Cookies are text files that are downloaded to your device when you visit a website or use an app.

We may use cookies and similar technologies to collect and aggregate certain information, including which pages of our websites were visited, the order in which they were visited, when they were visited, the websites from which you linked to our websites and which hyperlinks were “clicked”.

We may also collect your information, including your device information, browser type, IP addresses, information on how you interact with us, unique device identifiers and other diagnostic data. Through such information, we may be able to determine from an IP address your internet service provider and the general geographic location of your point of connectivity. To find out more about cookies visit aboutcookies.org or allaboutcookies.org.

Most web browsers automatically accept cookies, but you may refuse to accept cookies by modifying the browser settings on your computer. If you choose to decline cookies, you may be unable to use certain features of our sites.

3. Third-Party Platform Information or Analytics Data:

We may use third-party login services or analytics services, which may include overseas vendors, to collect user information and analyze data about how users interact with our platform to improve user experience and service performance.

We may offer you the option of registering to use our services via Google Sign-On. In this case, additional registration is neither necessary nor possible.

To log in via Google Sign-On, you will be redirected to the Google page. There, you can log in with your user data. This will link your Google profile and our service. As a result of the link, Google will automatically send us your information – your email address in particular, depending on your privacy settings.

By linking your Google profile with our service, Google receives event data (in particular, information about actions you take on our website, in our app or our store, such as visits to our website, installation of our app and purchases of our product) depending on your privacy settings.

For more information on how Google processes your personal data, including the legal basis on which Google relies and the options for exercising your rights with regard to the processing of your personal data by Google, please refer to Google's privacy policy. To protect your personal data, we have concluded an order processing contract with Google.

4. Information needed to comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.

5. Any other information you choose to provide to us in connection with your use of the Service.

3. Purposes of Collection

We may use the Data for the following purposes:

1. To provide and maintain our Service , including monitoring the usage of our Service.
2. To improve the Service through means including but not limited to third-party analytics services.
3. To conduct research and statistical analysis (Data may be used in aggregate form and in such circumstances, individual data will not be divulged).
4. To manage your account with us : to manage your registration as a Service user. The Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
5. For the performance of a contract : the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or any other contract with us through the Service.
6. To process billing and payment .
7. To contact you : To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
8. To provide you with news, special offers and general information about other goods, services and events which we or any Group Company offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
9. To manage your requests : To attend and manage your requests, enquiries and complaints to us.
10. For business transfers : We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Data held by us about our Service users is among the assets transferred.
11. To comply with any legal, governmental or regulatory requirements in Hong Kong or any other applicable jurisdiction, including disclosure or notification requirements.
12. For other legal requirements : We may use or disclose Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of users of the Service or the public and protect the legitimate interests of the Company.
13. For other purposes : We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our Service, products, marketing and your experience.

In some instances, you may also be requested to provide certain data which may be used to better tailor the type of information presented to you. In most cases, this type of data is optional. However, where the requested product or service is a highly personalized service, failure to provide the requested data may prevent us from providing such a product or service to you.

4. Use of Data in Direct Marketing

Only with your consent (which includes an indication of no objection), will we use your Data to provide you with marketing communications (including by email, SMS, mobile application, social media, instant messenger or other means that become available from time to time) relating to the Service or any news, special offers and general information about other goods, services and events which we or any Group Company offer that are similar to those that you have already purchased or enquired about.

We will not use your Data for direct marketing purposes unless we have received your consent. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from you shall override any previous instruction given to us in this regard in relation to all of your Data collected or held by us from time to time.

You may opt out of marketing communications from us by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly via email at support@lirvanalabs.com.

5. Links to Other Websites

Our sites may provide links to third-party content, websites, mobile applications or services. We do not endorse, sponsor, control, or otherwise accept responsibility for this material, except to the extent that we otherwise control it. You should be aware that this Privacy Policy does not cover third-party websites, and we, therefore, cannot be responsible for the content or practices of any such website, even if it links to our Service or even if the website is operated by a company affiliated or otherwise connected with us. We recommend that you review the Privacy Policy at each website to determine how that site protects your privacy.

6. Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment information. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Apple Store In-App Payments
  Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
• Google Play In-App Payments
  Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
• Stripe
  Their Privacy Policy can be viewed at https://stripe.com/us/privacy

7. Transfer of Data

Data collected or held by us relating to you will be kept confidential, but we may disclose or transfer such Data inside or outside Hong Kong, for the purposes specified above, to the following classes of transferees:

• any third party engaged in connection with us who provides education, training, career development, professional development, self-enhancement or other related services or products;
• any agent, contractor or other third-party service provider who provides administrative, telecommunications, technological, digital, computer, payment, data processing, storage of analytics, cloud, printing, research, distribution or other services to the Company in connection with the operation of the business (including, without limitation, website or app developers, insurers, banks, lawyers, and accountants);
• your school, your parents or your employer (as the case may be), if any of them is paying for the services or products we are providing;
• any Group Company or third party involved in the marketing of the Service and other related services and products we provide;
• third-party reward, loyalty, co-branding and privileges programme providers and co-branding partners of us or a Group Company;
• financial institutions engaged by the Company or you for billing and payment purposes;
• any actual or proposed assignee, transferee, participant or sub-participant of all or a substantial part of our rights or business; and
• any person to whom the Company is under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice or guidelines binding on us, including, without limitation, as required by any applicable regulators, governmental bodies, industry recognized bodies, the Courts, and where otherwise required by law.

We will only disclose Data limited to that which is necessary to the above parties for the relevant purposes, who may process (including, without limitation, by recording, organizing, structuring, storing, adapting, altering, retrieving, using, aligning, combining or erasing) your Data for the relevant purposes set out above.

8. Retention of your Data

We will retain your Data only for as long as is necessary for the purposes set out in this Privacy Policy, unless otherwise required or permitted under applicable law.

We may retain personal data for longer than the duration of the business relationship for legal and/or regulatory reasons, or for analysis or record-keeping. Where we no longer require your personal information for the purposes under this Privacy Policy, or otherwise required under law, we will take appropriate steps to securely delete or destroy your personal information.

To the extent permitted under applicable law, we will delete your data upon receiving such a request from you. To make such a request, please contact our Education Partnership team at partner@lirvanalabs.com.

We will handle such requests as soon as practicable.

9. Data Security

The confidentiality and security of your Data are important to us. We uphold a high data security standard by taking technical and organizational measures necessary to secure your Data against unauthorized or accidental access, processing, erasure, loss or use. Data is treated as confidential information by the Company and all employees and contractors designated to handle Data will be instructed to do so only in accordance with this Privacy Policy.

Currently, we store Data in the region where they were collected, that is, Data collected in Hong Kong is only stored in Hong Kong. Where Data is stored electronically, it will be kept on a secured server and will be encrypted and/or password-protected (or under some equivalent form of protection) and accessible only by authorized personnel of the Company or its contractors. The network transmission of Data is protected by the Cloud Service Mesh service provided by Google, which ensures that all communications between workloads are encrypted, mutually authenticated, and authorized. Please note that we do not guarantee the security of Data, as no method of internet transmission or storage is completely secure.

In the event of unauthorized or accidental access, processing, erasure, loss or use of your Data, we will notify you and the Office of the Privacy Commissioner for Personal Data of Hong Kong as soon as practicable of the incidents, the breach and its possible consequence, the action we have taken or will take, and any action you may take, pursuant to the applicable law or regulation. We will promptly notify you by email, regular mail, telephone or push notification and if it is too difficult to reach all the owners of the Data, we will make a public announcement in a reasonable and effective manner.

10. Children

If you are under 18, by providing us with your personal data, you agree that you have informed your parents and guardians about this Privacy Policy prior to such provision, and they have approved of such provision by you based on the terms of this Privacy Policy.

11. Data Access and Correction

You have the right to:

1. check whether we hold Data relating to you and to access such Data;
2. require us to correct any Data relating to you which is inaccurate;
3. ascertain our policies and practices in relation to Data and to be informed of the kind of Data held by the Company;
4. request us to cease using and/or processing your Data; and
5. change your preference in respect of our use of your Data.

To exercise these rights, please contact our Education Partnership team at partner@lirvanalabs.com .

We will handle such requests as soon as practicable. We are entitled to charge a reasonable fee for processing your Data access request.

12. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. All versions of the Privacy Policy are dated with the effective date of that version of the Privacy Policy. Our processing of the Data we collected about you will be governed by the most recent Privacy Policy in effect.

13. Contact Us

For any inquiries regarding this Privacy Policy or the handling of your Data, please contact us at:

Yeti Confetti Kids (Hong Kong Office)
Room 12, Smart-Space IT Street, Unit 311, L3, Core D, Cyberport 3, 100 Cyberport Road, Hong Kong

Email: partner@lirvanalabs.com
Phone: +852 95788997

Attention: Education Partnership Team