Privacy Policy

Effective Date: May, 1st 2021

Introduction

We, at INSTPOWER Co., Limited, have defined this Privacy Policy to explain and describe the personal data we collect, for what purposes we do it, as well as your privacy rights and the way you can exercise them.

This Privacy Policy applies to our use of personal data collected by us or provided by you in relation to your use of our website (instpower.com), (hereafter, the « Website ») and/or mobile application (hereafter, the « App »).

INSTPOWER Co., Limited, as a company based in Hong Kong, has the obligation to inform you about how your personal data is collected and processed and this in line with Privacy Commissioner for Personal Data of Hong Kong (hereafter, the « PCPD»).

All changes to this Privacy Policy will be published on our Website and App.

INSTPOWER Co., Limited acting as Data controller

The controller of personal data is INSTPOWER Co., Limited, having its registered office at Suite 1808, 18th Floor, On Hong Commercial Building,145 Hennessy Road, Wanchai, Hong Kong, Company No. is 2916536

If you have any questions on our Privacy Policy or on our privacy practices that are not addressed in this Privacy Policy, please contact us:

By email support@instpower.com

Purposes of the processing for which the personal data are collected and the legal basis for the processing

We collect and process personal data when it is necessary for operating, providing or improving our services offered to our users. We collect and process personal data in order to:

Deliver the services for which you subscribed
Charge you for the delivered services
Collect statistical data
Perform technical maintenance of our services
Provide marketing services directly conducted by INSTPOWER Co., Limited
Provide predictive marketing services
Provide targeted marketing services
Provide you with discounts and commercial gestures (loyalty programs, Special Offers etc...) including from third parties (such as telecom operators,…). These third parties will share your data with us and we will process this data in accordance with our privacy policy.
Handle your requests about our services, to send newsletters and/or marketing emails, to inform you about our services, to ask feedback about our services or inform you of changes and improvements of our services
Verify that your usage of our services does not infringe our Terms and Conditions or any laws or regulations

Legal base for these processing is the performance of the service contract that you accepted at the moment of onboarding.

Based upon pickup location (of the Batteries), time and return of pickup information, INSTPOWER Co., Limited will inform you with marketing information on promotions, new services and offerings from 3rd parties.

Legal base for these processing will be based upon your consent given at the moment of your onboarding.

INSTPOWER Co., Limited will also collect technical information in order to manage/improve availability of the service and to maintain/improve quality. This technical information will be anonymised and will subsequently not be subject to PCPD.

Personal data processed by INSTPOWER Co., Limited

INSTPOWER Co., Limited limits personal data collected to what is needed in relation with the above-mentioned purposes.

For delivering and charging the services to which you subscribed, the following data will be collected:

First and Last name
Email address
Business contact information (IP address)
Login and account information
Technical information (type of mobile device used, mobile network information, mobile operating system, type of mobile browser used and time zone setting)
Geolocalisation
Date and time of battery unlocking and returning batteries

For delivering marketing information to which you provided your consent, the following personal data will be processed:

Communication and marketing preferences
Interests, preferences, feedback and survey responses
Personal data submitted by the user
Rental information such as amounts spent, rental frequencies and patterns

Your personal data will be kept by INSTPOWER Co., Limited for a period defined as follows:

For the duration of the contract between you and INSTPOWER Co., Limited
For any period as defined by law or regulatory obligations

INSTPOWER Co., Limited does not address anyone under the age of 18 (hereafter, « Children »).

We do not knowingly collect personal data or identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with personal data, please contact us.

If INSTPOWER Co., Limited becomes aware that we have collected personal data from Children without verification of parental consent, we take steps to remove that information from our servers.

How long does INSTPOWER Co., Limited keep personal data ?

INSTPOWER Co., Limited only keeps personal data for the time strictly necessary in order to enable the use of our services and/or to fulfil the purposes identified above, and/or to comply with any legal or regulatory obligations.

If you have questions regarding the specific period of storage of your personal data, please contact us by email at support@instpower.com

Cookies and other tracking tools

Following cookies are being used:

Name of the cookie	Validity period	Content	Purpose
Language chosen	Eternal	Language chosen	Presents Website and App in language chosen by user
Google Analytics & Firebase & LiveChat	Eternal	Anonymous user flow tracking on web page and App	To track sales funnel and potential drop off points within it.

Recipients of personal data collected

During processing, your personal data will be processed by 3rd parties with whom INSTPOWER Co., Limited has a processing agreement that guarantees your privacy.

These 3rd parties will process your personal data on a need to know basis in order to:

Take care of payment services
Deliver call-centre services
Host the Instpower application

These 3rd parties are:

Name of the 3rd party	Services provided
Stripe	Payment services
Amazon Web Services	Website and app hosting services
Google Play	App distribution services
Apple developer account	Software development services
Amazon	Automated email services
Google API	Geolocalisation
Facebook for developers	Software development and advertisement services
Firebase	Software development services

Personal data shared with these 3rd parties will be limited to the extent of enabling these 3rd parties to deliver the service as requested by INSTPOWER Co., Limited.

INSTPOWER Co., Limited could, in a number of situations, have the legal obligation to share your personal data with police and/or judicial instances for instance:

To comply with a legal obligation
To protect and defend the rights or property of INSTPOWER Co., Limited
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect INSTPOWER Co., Limited against legal liability

Having access to executing your rights

As a customer you have the following rights:

To obtain from INSTPOWER Co., Limited which personal data is processed, for which purpose, the category of personal data, the retention period if available
To obtain rectification of the personal data processed by INSTPOWER Co., Limited
To obtain the right of erasure (Right To Be Forgotten)
To obtain the restriction of processing
To obtain the right to object automated individual decision-making

In order to execute your rights, you can send your request to:

By email: support@instpower.com
Via our website page: instpower.com