Privacy Matters

1. Your Privacy

7ition Limited (the “Company” or “we”) respects your legal rights of privacy when collecting, storing, using and transferring personal data.  It is our policy to comply with the legal requirements in relation to personal data protection. “Personal data” means any personally identifying information or sensitive data (such as name, contact details, photo) from which it is practicable for the identity of an individual to be ascertained.

2. Personal Data We Collect

This Privacy Statement explains how we will process and safeguard your personal data, and the rights and choices you have with respect to your personal data.  This Privacy Statement applies to: personal data you provide us when you use the Shwiggle APP or other services made available within the Shwiggle APP.  The Shwiggle APP allows users to create drawings or stories and comment on them.  In the process of providing our services, we may collect the following personal data:
– Email address and/or phone number: When you create a Shwiggle APP account, we will ask you to provide your email address and/or phone number for registration verification and password resetting purposes. It will be used to identify users, enable users to log in and reset password. 
– Username: A user registers with a username.  This is used to identify a user and other users can search for a user by his/her username.
– User Image: If provided, the user image will be the user’s profile picture.

– Other user-generated content: Content generated by you  and made public when using our services can be viewed by others.  Content that is created to be shared with friends can only be viewed by the friends added to that drawing or story.

3. Purposes for which we will use your personal data

We collect your personal data in your dealings with us (e.g. use of our application).  The personal data collected from you will be used for the following purposes: (a) processing and administering your user account; (b) for identification and verification purposes, such as during registration and to help you find other users you know and connect with them on the Shwiggle APP; (c) for marketing and promotional purposes, such as sending you updates on our latest offers and promotions; (d) contacting you regarding your enquiries; (e) evaluate, develop and improve our services, and conduct troubleshooting activities; (f) verify accounts and activity, such as investigating suspicious activity, detecting unauthorised, fraudulent use or abuse of our services, and notifying you in case any unauthorised use occurred; (g) enforce our Terms of Service and other usage policies; and/or (h) any other purposes ancillary to or directly related to the above purposes.
Failure to provide the requested personal data may result in the Company not being able to provide some or all of our services to you.

4. Disclosure

We will take all practicable steps to keep your personal data confidential but we may disclose or transfer such personal data to the following parties (including inside or outside of Hong Kong):
– any other Shwiggle APP users, including information about you (such as your username and email address) and contents you post or send (depending on your personal settings);
– any agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services to the Company with respect to its operationsor business developments;
– any person to whom the Company is under an obligation to make disclosure under the requirements of any law binding on the Company or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which the Company is expected to comply;
– the affiliates or associated or group companies or offices of the Company;
– any person with your express or implied consent;
– any other person under a duty of confidentiality to the Company; and/or
– if we decide to sell any relevant part of our business, to any actual or proposed assignee, transferee or successor (including for direct marketing purpose).

5. direct marketing

We may use your personal data or transfer your personal data to our associated companies or actual or proposed assignee, transferee and successor for use in direct marketing.  The products and services marketed include: The personal data that may be used or transferred includes the name, contact details and use of services information (as updated from time to time).  We may not so use or transfer the personal data without your consent.

6. Security

Except as mentioned in paragraph 4 above, your personal data, however stored, will be accessed only by our employees or contractors who are authorized to do so. Employees and contractors designated to handle personal data will be instructed to do so only in accordance with this Privacy Statement.

7. Your right to access and correction

You may at any time request access to and correction of your personal data in our records.  To exercise any of your rights, you can contact us at the address, facsimile number or email below, marking your communication “Confidential.” We are required to respond to your requests as required under applicable law but we may charge you a reasonable fee for doing so.

8. personal data privacy officer

The person to whom (1) requests (i) for access to personal data or correction of personal data, (ii) for general information regarding our policies and practices with respect to personal data and (iii) about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:

Privacy Officer
P.O. Box 10210
General Post Office
Hong Kong


9. retention of personal data

We will keep your personal data only for as long as necessary to fulfil the purposes for which the personal data was collected.  We may also retain archived personal data for statistical purpose. Personal data which is no longer required will be destroyed.

10. amendments

The Company may amend or update this Privacy Statement from time to time.