Privacy Policy and Personal Information Collection Statement


This Privacy Policy becomes effective from July 23, 2022.
Sportatous Limited ("the Company", "we", "our" or "Sport-a-tous") respect your right to privacy and protect your personal information. This Privacy Policy explains how we collect, share and use your personal information, and how you can exercise your data subject rights, when you visit and use our website http://www.envai.com.hk/ (“our Website”). By visiting our Website or using our applications or software we provide or any information or content appearing from time to time (collectively “the Platform”), you accept and consent to the practices set out below. The “personal information” under this Privacy Policy refers to any information, in electronic form or other form, that is able to directly or in combination with other information identify an individual or reflects an identified individual’s activities, including but not limited to name, identification number, correspondence address, residential address, account information, financial information.
Our Platform is not intended for and may not be used by minors. By using our Platform, you represent that you are an adult and that you are able to legally enter into contractual agreements. Upon the discovery of any fact that we have collected personal information of the juvenile without the consent of his/her parents or legal guardian, we will have such personal information deleted or anonymized according to applicable laws and regulations.

I. What personal information does the Company collect

We may collect the following personal information from you, when you visit our Website or use our Services:
i. Personal information that you provide to us voluntarily
If you contact us for any enquiries or for any other purposes via the contact information listed on our Website or submit any enquiry to us via the “contact us” section in the Website, we may collect your name, Hong Kong identification number/passport number, the company you work for, position title, email address (one or more), address, telephone number, fax number and other information about you that you provide to us, so that we are able to understand and respond to your enquiries or any other requests. ii. Information that we collect automatically
When you visit our Website, we may use cookies and similar technology to collect certain information about you automatically from you and the devices you use to improve the quality and relevance of our Website to our visitors.
Specifically, the information we collect automatically may include your Internet Protocol ("IP”) address, device type, unique device identification numbers (device ID), browser-type, general geographic location (e.g. country or city-level location), and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
This information may be collected using cookies and similar tracking technology, as explained further under our “Cookies Policy”.
iii. Information that we receive from third parties
We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

II. How do we use your personal information

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your personal information. Specifically, it includes the following purposes:
i. Create an account.
ii. Fulfill your transaction or service request, including but not limited to processing subscription and payment, performing corresponding consultation, training or service.
iii. Handle your application for communication service, inquiry, complaint and response.
iv. Incorporate into our user database.
v. Send you newsletter (e.g. news and information pushed to you through EDM software).
vi. Contact with you, such as sending you information about consultation or service that you may be interested in; inviting you to participate in our activities; market research or satisfaction survey; sending you marketing information. If you do not want to receive such information, you can contact us to unsubscribe at any time (see "how to contact us").
vii. Send you important notification.
viii. Conduct internal audit.
ix. Comply with and enforce applicable legal requirements or relevant industry standards.

III. How do we entrust, share, transfer and publicly disclose your personal information

i. Entrust
In some cases, we may entrust other companies to process your personal information on our behalf. For example, a third party hosting our Website, a third party involved in managing the content of our Website, a third party providing e-mail delivery of communications and news publications, or a third party service provider and business partner who otherwise processes your personal information on our behalf for the purposes described in this Privacy Policy or for the purposes we inform you when we collect your personal information. We will sign a confidentiality agreement with the company, organization or individual we entrust to process personal information, requiring them to process personal information in accordance with our requirements, this Privacy Policy and any other relevant confidentiality and security measures.
ii. Share
We will not share your personal information with any company, organization or individual other than our company, except for the following circumstances:
(i) Sharing with explicit consent: after obtaining your explicit consent, we will share personal information within the scope of your authorization with the third party designated by you.
(ii) Sharing under statutory circumstances: any competent law enforcement department, regulatory and government agency, court or other third party, if we believe it is necessary to disclose it in order to i) comply with any applicable laws and regulations; ii) exercise, establish or defend our legitimate rights, or iii) protect the material interests of you or others.
(iii) Share with our group companies: your personal information may be shared within our group companies. We will only share your personal information in our group companies for specific, explicit and legal purposes, and only share the information necessary for the provision of services.
(iv) Share with business partners: we may share your order information, account information, company name, etc. with business partners and other third parties to ensure the smooth completion of the service provided for you. However, we will only share personal information for lawful, legitimate, necessary, specific and explicit purposes and will only share such personal information as is necessary for the provision of the services. Our partners include:
Agents, advisers, auditors, contractors, financial institutions, and service or technical support providers: we may share your personal information with third parties supporting our functions or operations, including third parties providing payment services and information processing services for us. The purpose of sharing this information is to realize the function of the services. For example, we need to share your order number and amount with the third-party payment institutions (including banks and financial institutions) so that they can confirm your payment instruction and allow you to complete the payment.

V. Transfer

We will not transfer your personal information to any company, organization or individual except for the following circumstances:
(i) Transfer with explicit consent: with your explicit consent, we will transfer your personal information to other parties.
(ii) In the case of merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require the company or organization to seek your authorization again.
iv. Publicly Disclose
We will only publicly disclose your personal information under the following circumstances:
(i) Obtain your explicit consent.
(ii) Public disclosure based on law or reasonable basis: we may publicly disclose your personal information when required by law, legal proceedings, litigation or public and government authorities.

IV. How does the Company keep your personal information secure

i. We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
ii. In general, our daily operations may allow employees limited access to your personal information, and provide, disclose and use your personal information to authorized persons, processes and transactions. We will require employees assigned to process personal information to comply with this Privacy Policy.
iii. We will strictly select business partners and service providers, and implement the requirements of personal information protection into the business contracts, auditing, assessment and other activities of both parties.
iv. We review our information collection, storage and processing practices from time to time to guard against unauthorized access, processing or use.
In brief, we will make reasonable efforts to protect your personal information. Nevertheless, no measures can be impeccable, and no product or service, website, information transmission, computer system or network connection is absolutely safe. Although we will do our best to protect your personal information, we cannot guarantee the security of your date transmitted to our Website. Any transmission is at your own risk.
V. How does the Company store and how long does the Company store your personal information
We will store the personal information that we collect from you in accordance with applicable laws and regulations. The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. By submitting your personal data you agree to this transfer, storing or processing of data outside Hong Kong. If we transfer some information to other regions outside Hong Kong, we will comply with the requirements under applicable laws and regulations. We will require such data receivers to take appropriate measures to protect your personal information at a level that is equivalent to the personal protection afforded by applicable laws and regulations, and to process your personal information pursuant to this Privacy Policy.
Unless otherwise required by applicable laws and regulations, we would store your personal information for a period of time as below:
i. We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
ii. When we have no ongoing legitimate business need to process your personal information or the statutory retention period under applicable laws and regulations expires, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

VI. Your Data Subject Rights

You are entitled to any statutory data subject rights provided under Hong Kong laws, such as to access, correct, update and delete your personal information collected and processed by us, as well as withdraw your consent. You may exercise your rights by contacting us using the contact details provided in the section “How to contact us”. We respond to all requests we receive from individuals in accordance with the required time period and other requirements under applicable data protection laws. You have the right to opt-out of any marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” section below.

VII. Other Websites

Our Website contains hyperlinks to other pages for your convenience and information. This Privacy Policy does not apply to any other web pages that re-direct via our Website. When you access a third party web page, please note that we do not assume any responsibility for the collection, use of the information and privacy policies of the relevant websites.

VIII. Updates of this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technology or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

IX. How to contact us

If you have any questions or concerns about our use of your personal information or regarding this Privacy Policy, please contact us using the following details:
Mail to:
Sportatous Limited
Flat 03 11/F., Global Trade Square, 21 Wong Chuk Hang Road, Wong Chuk Hang, Hong Kong
E-mail: support@sportatous.com

Cookies Policy

The aim of this Cookies Policy is to inform visitors of our website about the nature, function and use of cookies, and to assist you in your choice of computer settings. By visiting our website or using our Services, you accept and consent to the practices set out below. For more about how we collect and use your personal information and how you can exercise your statutory data subject rights please refer to our Privacy Policy.

I. What is a cookie

A cookie is a kind of plain text file stored on computer or mobile device by network server. The content of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to the web browser. A cookie usually contains identifiers, site names, and some numbers and characters. Cookies allow websites to store data such as user preferences.

II. How are cookies used

Our purpose of using cookies is the same as that of most websites, that is, to improve the user experience. Specifically, it has the following purposes:
i. With cookies, websites can save settings such as the computer's language, font size, and other browsing preferences. This means that you don't have to reconfigure user preferences each time you visit.
ii. Login and authentication. We use cookies to verify your identity. When you use our website member account to log in to our Website, we will store a unique ID number and login time in an encrypted cookie on your device. By using this cookie, you can move directly from one page on the site to another without having to log in again on each page. You can also save your login information to avoid logging in every time you return to the site.
iii. Statistical analysis. For example, we use cookies to count the number of user visits, as well as to know your access sources.
iv. Security. We use cookies to ensure the security of our Website.

III. Managing your cookies

You can manage or delete cookies according to your preferences. For example, you can also block the necessary cookies by changing your browser settings. As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser’s help menu for more information. Please note that when you turn off the cookies or turn on “Do-Not-Track” function on your browser, the cookies would not continue to collect your personal information and accordingly certain features of the website that were designed to give you a good experience in browsing our Website might be disabled.
You may also contact us to change your cookies settings via the contact information contained in our Privacy Policy.
Last updated: 1 May 2024