Privacy Policy
This version is effective from : 1st August 2025
1. INTRODUCTION
This privacy notice (the “Privacy Notice”) explains how Platinum Guild International Hong Kong Limited processes your personal data in connection with your use of https://platinumguild.com/ and https://platinumguildcircle.com/ (each referred to as the “Site”), our mobile application either the Apple App Store and the Google Play Store (the “App”), (collectively, the Site and our App being our “Platform”) and the provision of our products and services to you, including those we make available via the Platform or otherwise in connection with our business (the “Products and Services”).
This Privacy Notice also explains how we process your personal data if you are another individual that interacts with our business, including if you: are someone who has seen an online ad promoting our Products and Services or our business, work for businesses that provide goods or services to us, apply to work for us, visit our premises, attend events that we host, and are engaged by us to promote our business, including if you are an influencer or other talent.
Please take a moment to read this Privacy Notice as it provides you with important information about your personal data, including the rights you have in relation to it. Your access to and use of our Platform is also subject to our Terms of Use, and your purchase of any Products and Services from us will be subject to our Terms of Sale.
This Privacy Notice is intended to meet the requirements of privacy laws of the United Kingdom (“UK”) and the European Union (“EU”), in particular the EU’s General Data Protection Regulation, the UK GDPR, and other similar European privacy laws (for ease of reference, collectively, the “GDPR”). However, as an international business we may be subject to other privacy laws and process personal data relating to individuals located in territories.
Any changes we make to this Privacy Notice will be posted on our Platform, including to reflect any changes to our use of personal data or to comply with applicable law or regulatory requirements. Where possible we may notify you of these changes by email, but we encourage you to check this page regularly to keep up to date.
2. ABOUT US
The Platform and our Products and Services are made available by Platinum Guild International Hong Kong Limited (“PGI”, “we”, “us, “our”). PGI is a company registered in Hong Kong (No: 64468307) with its registered office at 10th Floor, OTB Building, 160 Gloucester Road, Wan Chai, Hong Kong.
PGI is the controller of your personal data for the activities described in this Privacy Notice, except where we say in this Privacy Notice that we are a processor (where we process personal data on behalf of our clients when providing our Services).
Please contact us using our contact details in the How to contact us section.
3. How To Contact Us
If you want more information or have any questions about our processing of your personal data or this Privacy Notice you can contact us using the following methods:
Email [email protected]
Post: 10th Floor, OTB Building, 160 Gloucester Road, Wan Chai, Hong Kong.
4. HOW WE COLLECT AND RECEIVE PERSONAL DATA
We collect and receive personal data through the following methods:
- Personal data you provide to us. You may give us your personal data directly, for example, when you use or purchase our Products and Services, contact us with enquiries, complete forms on our Platform, subscribe to receive our marketing communications or provide feedback to us.
- Personal data we collect automatically, including through cookies and other similar technologies. When you access and use our Platform, we may collect Technical Data and Usage Data automatically, including through our use of cookies and other similar technologies. For more information about this data, please see our Processing Activities Schedule. For more information about our use of cookies and other similar technologies, please see the Cookies section.
- Personal data we receive from third parties. We may receive personal data from third
parties. Such third parties may include retailers, trading partners, manufacturers, sponsors and marketing campaign operators, event suppliers, analytics providers, data suppliers, third-party directories and third parties that provide technical services to us so that we can provide our Platform and our Products and Services. - Personal data that is publicly available. We may collect personal data that is available
from public sources (including media publications) or that you or a third party may otherwise publish (for example on websites, posts on social media platforms, or speeches at events).
5. PERSONAL DATA WE CONTROL
We may process or otherwise be a controller of the following personal data:
- Identity Data. Name (first, middle, and last); and title.
- Contact Data. Email address; telephone number; social media handle; and postal/delivery address.
- Registration Data. Username; password; date of birth; security questions and answers;
and any other personal data that you may provide to register an account with us. - Professional Data. Job title; and organisation that you represent (where you or your
organisation supplies products or services to us). - Transaction Data. Details of Products and Services purchased from us or products and
services that we may purchase from you or the organisation that you work for, including payment information (such as payment card details, bank account details and billing address). - Technical Data. IP address; details of the Site/App/Platform that you are viewing, such as full web page URL; browser type, device type and operating system and any other information available to us about the device you are using; location data, including the geographic location (which may be approximate, like the city or region you are in, or more precise) of a device derived from IP address, GPS signals or information about a device’s connection with local Wi-Fi equipment; diagnostic data (including crash logs, launch time, hang rate and energy use, and any other data collected for technical diagnostics purposes), and any relevant unique identifiers assigned to a device or browser (including cookie identifiers).
- Communications Data. Marketing preferences; and service communication preferences.
6. OUR PROCESSING ACTIVITIES
We process your personal data for the following purposes:
- to provide you with our Platform;
- to provide you with Products and Services;
- to deal with customer services and enquiries, carry out surveys and obtain feedback, and to manage public relations;
- to carry out insight, analytics, data improvement, and personalisation;
- to carry out online and other advertising and marketing activities; and
- for business administration and legal compliance purposes, including to exercise or defend legal claims.
For more information about our processing activities, including the personal data that is processed in connection with those activities, please see our Processing Activities Schedule.
7. COOKIES
Where indicated in this Privacy Notice, cookies, web beacons, pixel tags and other similar technologies (“Cookies”) may be used for the purposes described in this Privacy Notice. In addition to the information set out in this Privacy Notice, you can find out further information about the Cookies that we use on our Platform, and learn how you can manage your consent to the use of non-essential Cookies, by visiting our Cookie Notice / Cookie Preferences.
You can also manage your Cookie preferences using functionality provided by your browser, but please be aware that to use some parts of our Platform you will need to allow essential Cookies. If you block essential Cookies, some parts of our Platform may not work properly, or you may not be able to access our Platform.
For more general information about Cookies and managing Cookies, including blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.
On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.
8. SHARING PERSONAL DATA
We only share personal data with third parties or other entities within our group of companies) when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data and to maintain the confidentiality and security of it.
The circumstances where we may typically share personal data are set out below, though there may be other circumstances where we need to share personal data that are not set out below.
- Third party business partners. This may include retailers, trading partners, manufacturers, sponsors and marketing campaign operators, event suppliers, analytics providers, data suppliers, third-party directories and third parties that provide technical services to us so that we can provide our Platform and our Products and Services.
- Third-party suppliers who provide applications/ functionality, data processing or IT services. We share personal data with third parties who support us in providing our Platform and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services.The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal Platinum Guild International 20250801 data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics.
- Payment providers and banks. We share personal data with third parties who assist us with the processing of payments.
- Delivery and courier companies. We share personal data with suppliers who assist us in the delivery of our Products and other documents, information and materials.
- Advertising partners. We share personal data with third party advertising partners. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities. For more information, please see the Advertising and Marketing Activities section.
- Third-party marketing and customer relationship management specialists. We share personal data with specialist suppliers who assist us in managing our marketing database and activities, and sending out our marketing and account-related communications.
- Third-party suppliers who assist us in administering our promotions. We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
- Event partners and suppliers. When we run events, we will share personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share personal data with such organisations for use in relation to the event.
- Auditors, lawyers, accousntants and other professional advisers. We share personal data with professional services firms who advise and assist us in relation to the lawful and effective anagement of our organisation and in relation to any disputes we may become involved in.
- Law enforcement or other government and regulatory agencies and bodies. We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
- Business partners. We may also disclose personal data to third parties:
- if we sell or buy any business or assets, in which case we may disclose personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
- Other third parties.Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
9. YOUR RIGHTS
You have the following rights in relation to your personal data:
- Your right of access. If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
- Your right to rectification. If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them
- Your right to erasure. You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
- Your right to restrict processing. You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
- Your right to data portability. You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
- Your right to object. You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
- Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
- Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the How to contact us section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
- Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the How to contact us section. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.html.
10. INFORMATION SECURITY
We are committed to keeping personal data secure and we have implemented information security policies, rules and technical measures to protect personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, our personnel and data processors (third parties that process personal data on our behalf) are obliged to respect the confidentiality of the personal data relating to users of our Platform and those who purchase our Products and Services.
11. HOW LONG WE KEEP YOUR PERSONAL DATA
We will only keep your personal data for as long as necessary for the purposes set out in this Privacy Notice. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.
12. THIRD-PARTY LINKS AND SERVICES
This Privacy Notice only applies to personal data processed by us. Our Platform may contain links to third-party websites, apps or services. We have no control over these third-party websites, apps or services and this Privacy Notice does not apply to your interaction with the relevant third parties.
13. THIRD-PARTY APP STORES
If you download and install our App[s] from an app store (such as Google Play or the Apple AppStore), you must first register for a user account with the provider of the app store (e.g. Google or Apple) and agree to that app store’s user agreement. We have no influence over the terms of such user agreement and are not a party to it. When downloading, installing and using our App[s], certain information may be transmitted to the provider of the app store including identifiers relating to you or your device and the time of download. For further information on the type of information that may be shared with, or collected by, the provider of the app store, please see the relevant app store provider’s privacy notice. We have no influence over this process and are not responsible for the privacy practices of the provider of the app store.
14. PERSONAL DATA OF MINORS
Our Platform and Products and Services are not intended for use by, or targeted at, minors (individuals under the age of 18). However, this does not prevent minors from providing personal data to us. Where we do process personal data of minors, we will comply with all applicable laws and regulations relating to that processing.
15. IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Where we are required by law to collect personal data, or we need to collect personal data under the terms of a contract we have with you, and you fail to provide that personal data, we may not be able to fulfil any obligations that we owe to you, and we may not be able to enter into or perform a contract with you. This may apply where you do not provide personal data that we need to provide our Products and Services or to process an application to register an account. In these circumstances, we may have to cancel the provision of the relevant Products and Services to you, in which case we will notify you.
16. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Transfers to us – where we receive personal data.
We are located in Hong Kong. Therefore, your personal data may be processed by us in Hong Kong for the purposes set out in this Privacy Notice. In addition, it may be transferred by us to other countries (as described below).
Transfers by us – where we send personal data
We may transfer personal data to third parties (as described in the Sharing personal data section) that are located in countries that do not have data protection laws that protect personal data to the same standard as the GDPR. These third countries may not give you the same rights as under the GDPR in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns.
When transferring personal data to third countries, we usually rely on one of the following:
- Adequacy decisions: We may transfer your personal data to countries or organisations that have been deemed to provide an adequate level of protection for personal data by the European Commission, the UK Government, or any other relevant government body. This may include transfers to organisations that participate in the Data Privacy Framework listed here.
- Contractual safeguards: We may use specific contracts approved by the European Commission, the UK Government, or any other relevant governmental body to safeguard personal data. The contracts that we usually rely on are referred to as “Standard Contractual Clauses” or “SCCs”, although we may from time to time use other approved mechanisms. To find out more about the SCCs we use, please see here (EU) and here (UK). You can also contact us using the contact details set out in the How to contact us section.
Processing Activities Schedule
This Schedule sets out detailed information about the purposes for which we process the personal data described Personal data we control section and the lawful bases we rely on to do so.
This Schedule is split into the following sections – please click on the link below to be taken to the relevant section:
- Providing our Platform and carrying out other online activities
- Provision of Products and Services
- Customer Services, Feedback and Relationship Management
- Insight and Analysis, Data Improvement and Personalisation
- Online Advertising Activities
- Advertising and Marketing Activities
- Business Administration, Compliance and Legal Affairs
Providing our Platform and carrying out other online activities
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Delivery of our Platform Technical Data |
To provide our Platform to you, including ensuring that we are showing you the correct notices and information, and recording your preferences in relation to our Cookies.
Essential Cookies are used on our Platform for this purpose. Please see the Cookies section for further information |
Legitimate interests – to provide our Platform effectively.
Compliance with a legal obligation. Performance of a contract. |
| Support, maintenance and security
Identity Data Contact Data Technical Data Registration Data |
To administer and protect our Platform and users (including troubleshooting, fixing errors, analysis, testing, system maintenance, support, and security, including for fraud monitoring and prevention).
To respond to user enquiries/offer support to users. We may use your information to respond to your enquiries and solve any potential issues you might have with the use of our Platform. To request feedback and to contact you about your use of our Platform. Essential Cookies are used on our Platform for this purpose. Please see the Cookies section for further information. |
Legitimate interests – to run our business and to protect us and our users from harm.
Compliance with a legal obligation. |
| Provision of location based and other special features Technical Data |
To provide you with location-based and other special features through our Platform by accessing your device’s location or other functions. For example:
|
Consent through permissions granted on your device.
Consent can be updated or withdrawn at any time through your browser or device settings, as follows:
|
| Set up and manage user accounts
Identity Data Contact Data Communications Data Registration Technical Data |
To set up and manage user accounts, including to verify users when logging into accounts and secure areas of our Platform, which may be required to access to certain features, functionality, or benefits of our Platform.
To contact users about their accounts. |
Performance of a contract.
Legitimate interests – to provide secure and effective access to the Platform. |
| Platform development and improvement
Technical Data |
To develop and improve our Platform, including content that we make available, through insight and analysis that we carry out in relation to the use of our Platform as described in the Insight and analysis section.
Non-essential Cookies are used on our Platform for this purpose. Please see the Cookies section for further information. |
Consent (where non-essential Cookies are used on our Platform)
Legitimate interests – to improve and enhance our Platform (where non-essential Cookies are not used). |
Provision of Products and Services
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Supply of Our Products and Services
Identity Data Contact Data Transaction Data Professional Data |
To register you as a customer (as an individual or corporate customer).
To process and deliver your order for our Products and Services, including to manage and collect any fees or charges from you (or your organisation). To maintain our customer databases. To keep a record of transactions for our Products and Services. |
Performance of a contract.
Legitimate interests – to provide the Products and Services in an effective, safe and efficient way, and to exercise our rights in relation to transactions, including to receive payment of monies owed to us. Compliance with a legal obligation. |
| Returns and Refunds
Identity Data Contact Data Transaction Data |
To process any return or cancellation that you request in relation to an order for our Products and Services. | Performance of a contract.
Legitimate interests – to help with your return or cancellation, provide a good standard of service and improve our customer services. |
Customer Services, Feedback and Relationship Management
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Customer services and general enquiries
Identity Data Contact Data Transaction Data Professional Data Communications Data |
To manage and respond to any enquiry that you submit to us. | Legitimate interests – to help with your enquiry, provide a good standard of service and improve our customer services. |
| Managing our relationship with you or the organisation you work for
Identity Data Contact Data Transaction Data Professional Data Communications Data |
To manage our relationship with you or the organisation you work for (where your organisation is a customer of, or supplier to, us), including to contact you about any matter concerning an order for our Products and Services that you have placed, to contact our suppliers about goods or services that we have purchased or may purchase from them, and to provide you with other important information (including about changes to our terms and conditions or this Privacy Notice). | Performance of a contract.
Legitimate interests – to provide those that we work with the best experience and to ensure effective business administration. Legitimate interests – to effectively manage our supply chains. Compliance with a legal obligation – to comply with our consumer rights and privacy obligations. |
| Public Relations and Media
Identity Data Contact Data Professional Data Communications Data |
To respond to media enquiries and requests (including interview requests, requests for comment, and requests for information) that we receive, or address reports in the media that concern us, we may process personal data relating to journalists, reporters and other media professionals.
We may also send these persons corporate communications and other information by email for media and public relations purposes. |
Legitimate interests – to ensure that our business is fairly and accurately represented in the media.
Legitimate interests – to provide the right information to those who request it or otherwise have an interest in receiving it. |
Insight and Analysis, Data Improvement and Personalisation
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Insight and Analysis
Technical Data Usage Data |
To carry out insight and analytics, including:
|
Legitimate interests – to develop and improve our Platform and our Products and Services and to support other activities described in this Privacy Notice (where non essential Cookies are not used).
Consent (where non-essential Cookies are used). |
| Data improvement
Identity Data Contact Data |
To improve the quality of our data through the use of services and the data of third party data suppliers, including to:
Some of activities set out in this section, may be used by us to support the activities described in the Personalisation section. |
Legitimate interests – to ensure the effective and efficient use of data and to support other activities described in this Privacy Notice.
Compliance with a legal obligation. |
| Personalisation
Technical Data Usage Data |
To tailor the information and experiences provided to our users and customers, so that they are more likely to be of interest and relevance, including in relation to:
The activities described in the Insight and analysis/a> and Data improvement/a> sections may be relied on to carry out this activity. Non-essential Cookies are used our Platform for this purpose. Please see the Cookies/a> section for further information. |
Legitimate interests – to give users and customers the best experience, and to support our marketing and advertising activities, where non-essential Cookies are not used.
Consent (where non-essential Cookies are used). |
Online Advertising Activities
We may share your personal data with, or otherwise use the services of, third-party social media and advertising technology companies (“Advertising Partners”), so that we can advertise our business, including our Platform and our Products and Services, on websites, apps, and other digital platforms, including social media, that are operated by third parties (“Third-party Sites”).
Our online advertising activities are explained in more detail below. If you see one of our ads, this may be the result of one or a combination of these activities.
Please note:
- Some of the advertising that you see based on these activities may be personalised to you. Please see the Personalisation section for further information.
- We may be joint controllers with our Advertising Partners, or our Advertising Partners may be independent controllers, in relation to the activities described in this section. For more information, please see the Advertising and Social Media Partners section.
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Advertising on Third party Sites using Cookies and our Advertising Partners’ tools
Technical Data Usage Data |
To display ads for our Products and Services or that promote our business to you when you visit Third-party Sites, including to:
Non-essential Cookies are used on our Platform to recognise you as a user of our Platform. Please see the Cookies section for further information. In addition, our Advertising Partners may use non-essential Cookies on Third-party Sites, as well as other data that they have independently collected, for this purpose. We are not responsible for these technologies and you should separately review the information provided to you on the Third-party Site about these technologies. |
Consent (where non-essential Cookies are used on our Platform).
Legitimate interests – to |
Advertising and Marketing Activities
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Marketing communications
Identity Data Contact Data Communications Data |
To promote our Platform, our Products and Services, or to otherwise promote our business (including events), via email, telephone or post.
To ensure that the marketing content that is provided to you is more likely to be of interest, our marketing communications may be personalised. For more information, please see the Personalisation section. |
Consent (where marketing via email).
Legitimate interests (where marketing via telephone and post) – to grow our business. You can unsubscribe from our email marketing by clicking the ‘unsubscribe’ link in our emails. You can also ask us to stop using your personal data for our direct marketing activities by contacting us using the details set out under the How to contact us section. |
Business Administration, Compliance and Legal Affairs
| Purpose and Personal Data Processed | Description | Lawful Basis |
| Business administration and legal compliance
Identity Data Contact Data Registration Data Professional Data Transaction Data Technical Data Communications Data |
To comply with our legal obligations.
To enforce our legal rights or defend against potential legal claims. To protect the rights of third parties. To facilitate a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets. |
Legitimate interests – to operate our business effectively.
Compliance with a legal obligation. |