This Privacy Policy describes how Notey Limited (“we”, “us”, or “our”), a company based in Hong Kong and the owner of the Chinafy platform, collects, uses, discloses, and protects information in connection with our website, services, and related activities (collectively, the “Services”).
We are committed to protecting your privacy and ensuring compliance with applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and other relevant legislation.
1. Information We Collect
We collect and process the following types of information:
a. Information You Provide
• Contact details, such as your name, email address, company name, and phone number.
• Account-related information, when you register or communicate with us.
b. Information Automatically Collected
• Usage data, such as access times, IP addresses, browser types, pages visited, and device information.
• Cookies and similar technologies, as described in our Cookie Policy.
Note: Chinafy does not require access to customer application-layer content and does not store or permanently retain end-user personal data.
2. How We Use Your Information
We use the information we collect for the following purposes:
• To provide, maintain, and improve our Services;
• To manage customer relationships and respond to inquiries;
• To monitor, troubleshoot, and analyze usage;
• To protect the security and integrity of our Services;
• To comply with legal obligations;
• For marketing communications, where permitted by applicable law.
3. Legal Basis for Processing
If you are located in the European Economic Area, our legal basis for processing personal information includes:
• Your consent;
• The performance of a contract;
• Compliance with legal obligations;
• Our legitimate interests, such as improving and securing the Services.
4. Sharing of Information
We do not sell your personal information. We may share information in the following limited circumstances:
• To comply with legal obligations or in response to lawful requests by public authorities;
• With service providers and subprocessors who process data on our behalf in accordance with our instructions and applicable law;
• To protect the rights and safety of Notey Limited, Chinafy users, or the public;
• In connection with a business transaction, such as a merger, sale of assets, or acquisition.
• A current list of our subprocessors is available at https://www.chinafy.com/subprocessors
5. Data Security
We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
These include but are not limited to:
• Encryption of data in transit
• Access controls and role-based permissions
• Network isolation and multi-CDN architecture
• Regular audits and security monitoring via AWS CloudWatch and other tools
6. Data Retention
We retain personal data only as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law.
Where applicable, you may request deletion of your personal data by contacting us (see Section 12).
7. International Data Transfers
We are a company registered in Hong Kong S.A.R., China, and operate global infrastructure to deliver our Services. While we do not store or retain end-user personal data as part of our optimization process, certain operational data may be transferred to jurisdictions outside your country of residence, including the United States, where our primary infrastructure provider, Amazon Web Services (AWS), is located, and where some of our subprocessors operate.
For personal data subject to the laws of the European Economic Area (EEA), United Kingdom (UK), or other jurisdictions with international data transfer restrictions, we implement appropriate safeguards, including the use of Standard Contractual Clauses, to ensure adequate protection of personal data in accordance with applicable legal requirements.
8. Your Rights
Subject to applicable laws, you may have the right to:
• Access the personal data we hold about you;
• Request correction of inaccurate or incomplete data;
• Request deletion of your data;
• Object to or restrict processing;
• Withdraw consent where processing is based on consent;
• Lodge a complaint with a supervisory authority.
• To exercise these rights, please contact us using the information in Section 12.
9. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance user experience, perform analytics, and deliver personalized content.
You can manage cookie preferences via your browser settings. For more details, please refer to our Cookie Policy.
10. Children’s Privacy
Our Services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from children. If we become aware of such collection, we will take steps to delete the information promptly.
11. Third-Party Services and Links
Our Services may link to third-party websites or include third-party integrations. We are not responsible for the privacy practices of such parties and encourage you to review their respective policies.
12. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact:
Notey Limited (Attn: Chinafy Privacy Team)
Notey, 20/F, Lee Garden 3, 1 Sunning Road, Causeway Bay, Hong Kong
Email: privacy@notey.com
Subject: Privacy Inquiry
