Privacy Policy

Last updated: May 14, 2026

FLYTECH TECHNOLOGY (HK) LTD. (hereinafter referred to as “we”, “us” or “Flytech”) is committed to implementing robust management and protection of personal data and privacy. In compliance with the Hong Kong Personal Data (Privacy) Ordinance (PDPO), and with reference to local regulatory requirements as well as the EU General Data Protection Regulation (GDPR), we have established this Privacy Policy as the guiding principle for privacy protection. This Policy safeguards the personal data and privacy rights of individuals, and mitigates potential impacts arising from personal data incidents.

This Policy applies to all external individuals interacting with Flytech, including but not limited to customers, website visitors, on-site visitors, investors, users of our self-service kiosk products and solutions, corporate client personnel, supplier and contractor representatives, and business enquirers (hereinafter referred to as “you”). Any violation of this Policy by our staff will be subject to disciplinary action. Suppliers and business partners failing to comply with this Policy may face termination of business cooperation.

Flytech may revise this Policy from time to time in response to changes in business operations, personal data processing practices or legal regulatory updates. We encourage you to read this Policy carefully and review it periodically to stay informed of the latest version.

1. Personal Data We Collect

When you enquire about our services, browse our website, cooperate with us as a business partner or customer, we may collect your personal data according to the nature of interaction, including:

• Full name, job title
• Contact telephone number, email address, mailing address
• Company and affiliated organization information
• Device and network information automatically collected when browsing our website, including IP address, browser type, operating system, device model, language preference, access time and visited pages
• Location data (precise or approximate) generated by your device when accessing our website and services
• Log and usage data of our website and self-service system
• Information collected through Cookies and similar tracking technologies on our official website https://www.kioskhk.com/

We do not collect or process any sensitive personal data including racial origin, religious belief, political opinion or sexual orientation. The specific personal data collected shall vary according to the purpose of collection and use.

2. Purposes of Processing and Use of Personal Data

In compliance with the Hong Kong PDPO and applicable laws, we collect, process and use your personal data for the following legitimate purposes:

• Provision of Products and Services: to provide one-stop self-service kiosk solutions including design, manufacturing, customization and after-sales support for self-ordering terminals, self-payment kiosks and other self-service equipment for retail, food service and public sectors; to perform contract obligations and follow-up service communication.
• Business Communication and Marketing: to reply to your enquiries, send service updates, product information, policy revision notices and promotional communications; to maintain and update contact information for business interaction.
• Operation and Administration: for customer relationship management, business partner management, internal operational analysis and service experience optimization.
• Website and System Operation: to maintain website security, fix system faults, conduct internal traffic analysis and improve service functions.
• Security and Risk Prevention: to prevent fraud, protect the security of our website, systems and business operations.
• Legal Compliance: to comply with statutory obligations, respond to legal requests, and exercise and defend legal rights.

3. Processing Principles of Personal Data

We abide by the following principles in collecting, processing and using your personal data under applicable regulations:

• Notice and Consent: We will provide clear and sufficient information on data collection purposes and scope, and collect and process your personal data only after obtaining your consent where required by law.
• Purpose Limitation: Personal data will only be used for the stated collection purposes; we will not conduct unauthorized secondary use, and continuously monitor data usage status.
• Legitimate Data Processing Scenarios: When you contact us, browse our website or use our services, we may process relevant personal data, and combine data from website access, device records and business communication for legitimate record-keeping and service follow-up.
• Accuracy and Update: We take reasonable measures to ensure personal data is accurate and up-to-date. We will correct or delete incorrect information in a timely manner and confirm data accuracy with you periodically when necessary.
• Scope Restriction: The scope of personal data processing is strictly limited to the business purpose required, and we avoid excessive data collection and use.

4. Disclosure of Personal Data

We will not disclose or share your personal data with any third party unless one of the following circumstances applies:

• With Your Explicit Consent: We will disclose your data only after obtaining your clear approval.
• Group Affiliates: We may share personal data with our group affiliates to fulfill business service and cooperation needs.
• Authorized Service Providers: We may disclose necessary personal data to third-party service providers acting on our behalf, including network analytics platforms and advertising remarketing service providers such as Google Analytics and Google Ads Remarketing. We will sign confidentiality agreements with such third parties to restrict their data processing scope and oblige them to protect data security.
• Business Transaction Arrangements: In the event of merger, asset sale, financing or business acquisition, your personal data may be transferred as part of business assets.
• Legal and Government Requirements: We may disclose relevant personal data to regulatory authorities, judicial institutions or government departments as required by Hong Kong laws, court orders or statutory investigations.

5. Retention of Personal Data

We only retain your personal data for the period necessary to fulfill the collection purpose, unless extended retention is required by Hong Kong laws, tax regulations or judicial procedures.

• General Retention Principle: Personal inquiry and business contact data will be retained for up to 7 years after the last interaction, in compliance with Hong Kong PDPO and accounting record requirements.
• Business Relationship: We retain necessary data during ongoing business cooperation for follow-up service and transaction arrangement.
• Legal and Litigation Needs: Data will be retained during tax audit, government investigation or litigation proceedings.

Upon expiry of the retention period, we will permanently delete, destroy or anonymize your personal data in a secure manner.

6. Security and Storage of Personal Data

We adopt reasonable technical and organizational security measures including system encryption, firewall protection and internal access control mechanisms to protect your personal data from unauthorized access, intrusion, alteration, leakage and destruction.

Due to the open nature of the Internet, absolute security of online data transmission cannot be fully guaranteed. We will make every reasonable effort to protect your personal data, but cannot warrant 100% security during internet transmission. You shall acknowledge and bear the relevant transmission risks.

If we detect any personal data security breach, we will take remedial measures and notify relevant parties in a timely manner in accordance with Hong Kong PDPO requirements.

7. Cross-Border Transfers

As a member of a multinational enterprise, your personal data may be transferred to and processed by our group affiliates and authorized service providers outside Hong Kong within the original legitimate collection purpose.

All cross-border data transfers will comply with this Policy and the Hong Kong Personal Data (Privacy) Ordinance, as well as relevant data protection laws of the destination jurisdiction. We will ensure overseas recipients maintain an equivalent level of data protection.

8. Your Privacy Rights Under Hong Kong PDPO

Subject to the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and applicable regulations, you enjoy the following rights:

• Right to Refuse Provision: You may choose not to provide personal data; however, this may affect our ability to provide complete website functions and services.
• Right to Withdraw Consent: You may withdraw your consent to data collection and processing at any time. After withdrawal, we will stop relevant processing, without affecting the lawfulness of processing conducted prior to withdrawal.
• Right of Access: You may request access to a copy of your personal data we hold and details of processing purposes.
• Right to Rectification: You may request correction or completion of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where permitted by law; we will comply unless retention is required for legal obligations.
• Right to Restrict Processing: You may request restriction of our processing of your personal data under statutory circumstances.
• Marketing Opt-out: You may unsubscribe from our marketing emails at any time via the unsubscribe link in emails or by contacting us directly.

For users located in the European Economic Area or California, you also retain relevant rights under GDPR and CCPA respectively as specified in applicable regulations. We may verify your identity before handling your rights request.

9. Personal Data Management Mechanisms

We integrate personal data privacy protection into enterprise risk management. We have established a complete personal data protection management system, conduct regular internal reviews and effectiveness assessments, and arrange external audits when necessary to ensure compliance with Hong Kong PDPO and internal policies. Our internal audit covers the whole process of data collection, processing, storage and transmission to standardize operational procedures.

10. Staff Privacy Training and Awareness

We provide regular privacy protection training to all internal staff, strengthen awareness of personal data protection, and conduct periodic effectiveness evaluations to ensure all personnel comply with this Policy and Hong Kong privacy regulations in daily operations.

11. Cookies and Tracking Technologies

When you visit our official website https://www.kioskhk.com/, we use Cookies and similar tracking technologies (web beacons, pixels) to collect browsing information in accordance with legal requirements and your consent. Session Cookies are deleted after closing the browser; persistent Cookies are stored on your device until manual deletion or expiry.

We use Cookies to maintain website basic functions, record access preferences, conduct traffic analytics and deliver targeted advertising via third-party platforms including Google Analytics and Google Ads. You may adjust your browser settings to reject or clear Cookies at any time; please note that disabling Cookies may affect partial website functions. You may also opt out of Google Analytics tracking via official opt-out tools.

12. Disciplinary and Compliance Measures

We adopt a zero-tolerance attitude towards any act violating this Privacy Policy and Hong Kong personal data regulations. Once a violation is verified, we will conduct a thorough investigation and impose disciplinary sanctions on relevant personnel, including warning, demerit and bonus deduction; serious violations will result in employment termination and referral to relevant regulatory authorities for legal handling.

13. Amendments to This Privacy Policy

We may amend this Privacy Policy from time to time to adapt to legal updates and business changes. The revised version will be updated with the latest date at the top of this page. Your continued use of our website and services after policy revision shall be deemed acceptance of the updated Policy. For material amendments, we will post a notice on our official website or notify you by email.

14. Contact Information

If you have any enquiries, comments or concerns regarding this Privacy Policy, or wish to exercise your privacy rights, please contact us:

Email: flytech@flytech.com.hk

Postal Address:
FLYTECH TECHNOLOGY (HK) LTD.
Room 01, 6/F, Block A, Tonic Industrial Centre, 26 Kai Cheung Road
Kowloon Bay, Hong Kong

You may also file a complaint to the relevant data protection authority in Hong Kong if you consider your privacy rights are not properly respected.