Privacy Policy

1. Our Commitment to You

At SnapTaxHK, your privacy is of utmost importance. We design and build the services and products you know and love with your privacy at the core.

We appreciate your trust in us and your personal information will be handled with care.

All of our products and services are designed with your privacy in mind.

2. Scope of application of this Privacy Policy

This Privacy Policy applies to websites, apps, events and other services operated by the Tower Therapy brand. For simplicity, we refer to all of these as "Services" in this Privacy Policy. For greater clarity, we will add a link to this Privacy Policy to all applicable services.

Some services may require their own unique privacy terms. If a particular service has its own privacy terms, that term (not this Privacy Terms) will apply to that service.

3. Information We Collect

Of course, if we don't have information about you, such as basic personal data, we can't provide content tailored to you. We also collect information about your use of our services, which we will explain in more detail below.

4. Information You Provide to Us

When you use our services, you will provide us with certain information. This information includes:

When you create an account, you must at least provide us with your phone number and some basic information required for service, such as your gender and date of birth.

When you subscribe or purchase paid services from us directly (not through the iOS or Android platforms), you provide us or our payment service providers with information such as your debit or credit card number or other financial information.
When you participate in surveys, focus groups or market research, you provide insights into our products and services, answer our questions and make recommendations.
When you choose to participate in one of our promotions or contests, we collect the information you use to register or enter.
If you communicate with our customer service team, we collect the information you provide during your interaction with that team.

5. Information We Obtain from Others

In addition to the information you provide directly to us, we also obtain information about you from others, including:

Members: Members may provide information about you when they use our services, such as when they interact with you or submit reports related to you.

Other Partners: We may obtain information about you from partners, such as when advertisements for our services are placed on partner services (in which case, they may pass along details of the successful activity to us). Where permitted by law, we may also receive information from third parties about individuals who are suspected or convicted of misconduct as part of our efforts to ensure member safety.

6. Information generated or collected by the system when you use our services

When you use our services, technical information is generated, such as which features you use, how you use those features, and the devices you use to access our services. Please see below for more information.

Usage Information: Using these services generates data about your activities within our services, such as how you use them (when you log in, features you have been using, actions taken, information displayed to you, referral web addresses, and ads you interact with).

Device Information: We collect information from the device you use to access our Services, including hardware and software, such as IP address, device ID and type, app settings and characteristics, app crashes, advertising IDs (these are randomly generated numbers that you can reset by going to your device settings and, in some cases, disable entirely), or other technology that may uniquely identify a device or browser.
Other information with your consent:
- Precise geolocation: If you agree, we can collect your precise geolocation (latitude and longitude) information through your device. With your explicit consent, our collection of your geolocation information may occur in the background, regardless of whether you use the Services. If you do not allow us to collect your precise geolocation information, we will not collect this information, and our services that rely on precise geolocation information may not function properly.
- Other Information: With your consent, we may collect other information, including photos and videos (for example, if you want to post photos, videos or participate in streaming features on our Services).

7. How We Use Information

The primary reason we use your information is to provide and improve our services. Additionally, we use your information to maintain your account and provide you with advertisements that may interest you. Please continue reading for detailed explanations of the various reasons we use your information, along with practical examples.

A. Managing Your Account and Providing Our Services

Creating and managing your account
Providing customer support and responding to your requests
Communicating with you about our services
Offering personalized fees, discounts, and other promotions, and completing purchase processes
Managing sweepstakes and contests

B. Helping You Connect with Other Members

Displaying member profiles to others

C. Providing New Services

Facilitating your registration for new features and apps, and displaying your profile
Managing your account in these new features and apps

D. Offering Promotional Content and Conducting Advertising and Marketing Activities

Executing and evaluating advertising campaigns within our services and the effectiveness of marketing activities outside our platform
Communicating with you about products or services we believe may interest you

E. Improving Our Services and Developing New Services

Conducting focus groups, market research, and surveys
Reviewing interactions with our customer service team to improve our service quality
Understanding how members typically use the services to improve content (e.g., we may decide to change the appearance or significantly modify existing features based on member feedback)
Developing new features and services (e.g., we may decide to create a new feature based on member requests)

F. Preventing, Detecting, and Combating Fraud and Other Illegal or Unauthorized Activities

Identifying and addressing ongoing, suspected, or alleged violations of our Terms of Use, particularly by reviewing reports and interactions between members
Further understanding and designing countermeasures against violations of our Terms of Use
Retaining and handling data related to violations of our Terms of Use to prevent recurrence
Enforcing or exercising our rights, such as those stipulated in our Terms of Use
Informing individuals who submitted reports about the actions we took following their reports

G. Ensuring Legal Compliance

Complying with legal requirements
Assisting law enforcement

We process your information based on the following legal grounds as described in the privacy terms:

Providing Our Services: We process your information for the purposes outlined in A, B, and C to fulfill our contract with you.

Legitimate Interests: We process your information for the purposes outlined in D, E, and F based on our legitimate interests. For example, we analyze user behavior to continuously improve our products, recommend products you may be interested in, promote our own services, process information to help protect member safety, and handle data as necessary to exercise our rights, assist law enforcement, and defend ourselves in legal proceedings.

Compliance with Applicable Laws and Regulations: We process your information for the purposes outlined in G when necessary to comply with applicable laws and regulations and to demonstrate our compliance with applicable laws and regulations. For example, we retain traffic data and transaction data to meet our accounting, tax, and other statutory data retention obligations and respond to valid access requests from law enforcement. We also retain data to demonstrate member consent and any choices they may have made to opt out of certain features or processing.

If you choose to provide us with information that may be considered “special” or “sensitive” in certain jurisdictions, such as your sexual orientation, you consent to our processing of that information in accordance with this privacy policy. Sometimes, we may seek your consent to collect specific information, such as your precise geolocation or to use your information for certain specific reasons. In some cases, you can withdraw your consent by adjusting your settings (e.g., related to our collection of precise geolocation) or deleting your content (e.g., information you entered in your profile that may be considered “special” or “sensitive”). In any case, you can withdraw your consent at any time by contacting us via email.

8. How We Share Information

Because our goal is to help you build meaningful relationships, it goes without saying that Member Information is primarily shared with other Members. We also share certain types of Member Information with service providers and partners who help us perform our services, with other companies for the special reasons set forth below, and even with legal authorities in certain circumstances. Please continue reading for more details on how we share your personal information with others.

9. Share with other members

When you voluntarily disclose information on the Services, including your public profile, you are sharing it with other members. Be careful with your information, and make sure you are sharing it with other members if you are willing to make it public. When you voluntarily disclose information on the Services, including your public profile, you are sharing it with other members if you are willing to make it public. Be careful with your information, and make sure you are sharing it with other members if you are willing to make it public. When you voluntarily disclose information on the Services, including your public profile, you are sharing it with other members if you are willing to make it public. Be careful with your information, and make sure you are sharing it with other members if you are willing to make it public.

If you choose to limit what others can see to all or part of your profile, or to specific content or information about you, that information will be displayed based on your settings.

If someone submits a report about you (for example, alleging that you have violated our Terms of Use), we may communicate with the reporter about the actions we take as a result of their report.

10. Sharing with our service providers and partners

We work with other vendors to help us operate, publish, promote, and improve our services. These vendors help us with a variety of tasks, including data management and maintenance, analysis, customer service, marketing, advertising, payment processing, and security operations. We also share information with vendors who publish and help promote our services. For example, we share limited information about you with advertising vendors in a hashed, non-human-readable form.

Before we work with any vendor or partner, we will conduct a rigorous review process. All our vendors and partners must agree to fulfill strict confidentiality obligations.

11. Corporate Transactions

We may transfer your information in connection with a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change in corporate ownership or control, whether in whole or in part.

12. When required by law enforcement agencies/laws

We may disclose your information when reasonably necessary: (i) to comply with legal process, such as a court order, subpoena or search warrant, to cooperate with a government/law enforcement investigation, or other legal requirement; (ii) to assist in the prevention or detection of crime (in each case, depending on applicable law); or (iii) to protect the safety of any person.

13. To enforce legal rights

We also share information: (i) if disclosure may mitigate our liability in actual or threatened litigation; (ii) as necessary to protect our own legal rights and those of our members, business partners, or other stakeholders; (iii) to enforce our contract with you; and (iv) to investigate, prevent, or otherwise take action regarding illegal activity, suspected fraud, or other wrongdoing.

14. With your consent or at your request

We may ask you to agree to share your information with third parties. In this case, we will clearly state the reason for sharing such information. We may ask you to agree to share your information with third parties. In this case, we will clearly state the reason for sharing such information. We may ask you to agree to share your information with third parties. In this case, we will clearly state the reason for sharing such information.

In any of the above situations, we use and share non-personal information (i.e., information that does not identify you by itself, such as device information, general demographic data, general behavioral data, and geolocation in de-identified information forms) and personal information in a hashed, non-human-readable form. We also share this information with other companies and third-party vendors (particularly advertisers) to develop and serve targeted ads on our services and on third-party vendors’ websites or apps, and to analyze and report on the ads you see.

15. Your Rights and Choices

We want you to have control over your information, so here are the options and tools available to you:

Access/Update Tools for the Service: These tools and account settings can help you access, correct, or delete the information you have provided to us that is directly associated with your account. If you have any questions about these tools and settings, you can contact our customer service team here for assistance.

Device Permissions: Mobile platforms may have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications, and advertising identifiers. You can change the settings on your device to consent to or oppose the collection or processing of the corresponding information, or to display the corresponding notifications. Of course, if you do so, some services may not function fully.

Uninstall: You can stop all information collection by the app by using the standard uninstall process on your device to delete the application. Please remember that uninstalling the app does not close your account. To close your account, please use the corresponding function on the service.

Account Closure: You can close your account directly using the corresponding function on the service.

We also want you to understand your privacy rights. Depending on where you live, you may have the following rights:

Access/Understand: You may have the right to request a copy of the information we hold about you, and in certain circumstances, to obtain this data in a portable format. To exercise this right directly within the service, you can make a request here.

Delete/Remove: You may be able to request that we delete the personal data we hold about you. To exercise this right, you can make a request here.

Correct/Amend/Update: To correct the information you have provided to us, you can usually edit your profile directly within the service. If you believe the information we hold about you is incorrect, you can contact us here to correct the inaccurate parts.

Object/Restrict: You may also have the right to object to certain processing practices or request that we restrict certain processing practices. To exercise this right, please contact us.

To protect you and all our members, we will ask you to provide proof of identity before responding to the above requests. Please note that we may refuse your request, including if we cannot verify your identity, if the request is illegal or invalid, or if it may infringe on trade secrets, intellectual property, privacy, or other rights of others. If you wish to receive information about other members, such as any message copies you received from them through our service, the other members must contact us and provide their written consent before the information is released. We may also ask them to provide proof of identity before we can respond to the request. Additionally, we may not be able to fulfill certain requests to object to or restrict the processing of personal information, especially if it would prevent us from providing services to you.

16. Information Retention Period

We retain your personal information only as long as necessary for legitimate business purposes (as described in Section 4) and as permitted by applicable law. If you decide to stop using our services, you can close your account and your profile will no longer be visible to other members. Please note that we will automatically close your account after two years of inactivity. After your account is closed, we will delete your personal information as follows:

To protect the safety of our members, we have implemented a safety retention period, where we retain your information for 3 months after account deletion or 1 year after account ban in case we need to investigate illegal or harmful behavior. The information retained during this safety retention period is based on our legitimate interests and the legitimate interests of potential third-party victims.

After the security retention period, we will delete your data and only retain limited information for specific purposes as follows:
- We retain limited data to comply with legal data retention obligations: in particular, we retain transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for as long as the user may challenge the transaction, and "traffic data"/logs for one year to comply with legal data retention obligations. We also retain records of the consent given to us by members for five years to demonstrate our compliance with applicable laws.
- b) We retain limited information based on legitimate interests. We retain customer service logs and support data and inaccurate download/purchase locations for five years to support our customer service decisions, enforce our rights, and enable us to defend ourselves in the event of a claim regarding the existence of past accounts and subscriptions. We delete this information three years after your last account is closed to ensure proper and accurate financial forecasts and reporting, to provide personal data for one year in anticipation of potential litigation, to establish, exercise or defend legal claims, and to prevent members from being banned from opening new accounts, as long as necessary to ensure the safety and vital interests of our members.
- c) Finally, we retain information based on our legitimate interests if there is an outstanding or potential issue, claim or dispute that requires us to retain the information (particularly if we receive a valid legal subpoena or request to retain the information – in which case we need to retain the information to comply with our legal obligations – or if it is necessary as part of legal proceedings).

17. Job seekers, contractors and supplier representatives

If you are a job seeker, the personal information we process about you may vary depending on the job you are seeking, but will generally include information you provide to us when applying for a job, as well as professional qualifications, background and reference information shared with us by recruiters or other third parties. We use this information to support the recruitment process, which may further lead to the conclusion of an employment contract. For contractors and vendor representatives, we may process Identity Information and Job-Related Information as necessary to manage our relationship with you and your employer, as necessary to perform the service agreement, and to establish, exercise or defend potential legal claims. We may share personal information with service providers and companies that assist us with recruitment and technical data processing (for example, if you have a business relationship with an employee of a subsidiary). We will only retain your personal data for as long as it is necessary for these purposes.

18. Changes to our Privacy Policy

Because we are always looking for new and innovative ways to help you build meaningful relationships, and we work to ensure that our explanation of our data practices is always up to date, this policy may change from time to time. We will notify you of any content changes before they take effect, giving you time to review the changes.