99commerce Privacy Policy
Last Updated: December 2025
1. Introduction and Commitment to Privacy
99commerce Limited ("Company", "we", "us", "our", or "99commerce"), a company registered in Hong Kong with business address at Thomson Communications Building, 8 Thomson Road, Wan Chai, Hong Kong, is committed to protecting your privacy.
This Privacy Policy ("Policy") describes how we collect, use, process, share, and protect personal information when you:
Visit or use our website and related digital properties (the "Site");
Purchase products or services from us;
Interact with our marketing communications;
Use our Services.
This Policy applies to all users, customers, and visitors of the Site and Services. By accessing or using the Site and Services, you acknowledge that you have read and understood this Policy and consent to our collection, use, and sharing of your personal information as described herein.
2. Information We Collect
2.1 Information You Provide Directly
Account Registration and Account Information
When you create an account or register with us, we collect information such as:
Full name
Email address
Phone number
Mailing address
Password and account credentials
Account preferences
Communication preferences
Purchasing Information
When you make a purchase, we collect:
Product and service details
Quantity and pricing information
Billing and shipping addresses
Payment method information (credit card, digital wallet)
Order history and preferences
Transaction details
Delivery and return information
Communications
When you communicate with us, we collect:
The content of your emails, messages, or inquiries
Your contact information
The date and time of communication
Your requests, feedback, or complaints
Survey and Feedback
If you participate in surveys, contests, promotions, or provide feedback, we collect:
Your responses and opinions
Contact information
Demographic information (age, location, interests)
Participation details
2.2 Information Collected Automatically
Website Usage Information
When you visit the Site, we automatically collect:
Device information (device type, operating system, device ID)
Browser information and type
Internet Protocol (IP) address
Pages visited and time spent on each page
Links clicked and interactions with content
Referring website or source
Search queries and keywords entered
Website navigation patterns
Timestamp and date of visits
Error and crash information
Cookies and Tracking Technologies
We use cookies, web beacons, pixels, JavaScript, HTML5 local storage, and similar tracking technologies to:
Remember your preferences and login information
Understand your browsing behavior
Measure Site performance and functionality
Track advertising effectiveness
Enable personalized content and recommendations
Conduct analytics and research
Prevent fraud and enhance security
For more information about our use of cookies, please refer to our separate Cookie Policy.
Location Information
We may collect:
City and state/region (inferred from IP address)
GPS data (if you permit location services)
General location information based on device settings
Mobile Application Information
If you access the Site via mobile application, we may collect:
Mobile device identifiers
Device model and operating system
App version and update information
Push notification preferences
App usage and behavior
2.3 Information from Third Parties
Third-Party Service Providers
We receive information from third-party service providers, including:
Payment Processors (Stripe, PayPal, Klarna): transaction and payment information
Analytics providers (Google Analytics): website usage data
Advertising partners (Meta, TikTok, Pinterest, Snapchat, Outbrain, Taboola): ad interaction data
Social media platforms: profile information (if you connect your account)
Data brokers and enhancement services: demographic and behavioral data
Email service providers (Klaviyo): engagement and preference data
Publicly Available Sources
We may obtain information from public sources, including:
Social media platforms
Public directories
Business registries
News and media outlets
Affiliate and Partner Networks
We may receive information from business partners, affiliates, and networks regarding your interactions with their services.
3. How We Use Your Information
3.1 Providing Products and Services
We use your personal information to:
Create and manage your Account
Process and fulfill your orders
Provide customer support and service
Resolve disputes and complaints
Deliver products and services
Respond to your inquiries and requests
Send order confirmations and shipping updates
Facilitate returns and refunds
Maintain transaction records
3.2 Marketing and Communications
We use your information to:
Send promotional emails and marketing communications
Notify you about new products, services, and offers
Personalize marketing messages based on your interests
Conduct email campaigns and newsletters
Display targeted advertisements
Create lookalike audiences for advertising
Analyze marketing effectiveness
Conduct surveys and gather feedback
You have the right to opt out of marketing communications at any time by following the unsubscribe instructions in our emails or contacting us directly.
3.3 Website Improvement and Analytics
We use information to:
Analyze how users access and interact with the Site
Improve Site functionality, performance, and user experience
Identify trends and usage patterns
Conduct research and analytics
Test new features and functionality
Troubleshoot and resolve technical issues
Generate aggregated and anonymized reports
3.4 Advertising and Personalization
We use your information to:
Display personalized content and recommendations
Serve targeted advertisements across the internet
Create segments for audience targeting
Conduct retargeting campaigns
Measure advertising performance
Conduct cross-device targeting
Optimize ad delivery and frequency
3.5 Fraud Detection and Security
We use your information to:
Detect, prevent, and investigate fraud
Enhance security measures
Monitor for unauthorized access
Verify identity and eligibility
Prevent abuse and misuse of services
Comply with anti-fraud and security standards
3.6 Legal and Regulatory Compliance
We use your information to:
Comply with applicable laws and regulations
Respond to legal requests and court orders
Fulfill tax and financial reporting obligations
Maintain required records and documentation
Enforce our Terms of Service
Protect our legal rights and interests
Cooperate with law enforcement
3.7 Business Operations
We use information to:
Conduct business analytics
Improve products and services
Conduct internal audits and compliance reviews
Manage contracts and agreements
Handle billing and accounting matters
4. How We Share Your Information
4.1 Service Providers and Processors
We may share your personal information with third-party service providers who perform functions on our behalf, including:
Payment Processors: Stripe, PayPal, Klarna (payment processing)
Email Service Providers: Klaviyo (email marketing and communications)
Analytics Providers: Google Analytics, Hotjar (website analytics and user behavior)
Advertising Partners: Meta Pixel, TikTok Pixel, Pinterest Pixel, Snapchat Ads, Outbrain, Taboola (advertising and retargeting)
Hosting and Cloud Providers: AWS, Google Cloud, Snowflake (data storage and processing)
CRM and Data Platforms: Lark Base (customer relationship management)
Content Platforms: Shopify (ecommerce platform)
Fraud Detection: Risk management and fraud prevention services
Shipping and Logistics: Fulfillment and delivery partners
These service providers are contractually obligated to use your information only for the purposes specified and to maintain confidentiality and security.
4.2 Marketing and Advertising Partners
We may share aggregated, anonymized, or pseudonymized data with:
Advertising networks and exchanges
Social media advertising partners
Data brokers and enhancement services
Third-party audience platforms
Marketing analytics providers
This information may be used to create targeted audience segments, conduct advertising campaigns, and measure advertising effectiveness.
4.3 Third-Party Platforms and Services
If you connect your account to third-party social media or services (e.g., Meta, Google, TikTok), we may share relevant information with those platforms in accordance with your authorization.
4.4 Business Transfers
If 99commerce undergoes a merger, acquisition, bankruptcy, dissolution, reorganization, asset sale, or similar transaction, your personal information may be transferred as part of that transaction. You will be notified via email or prominent notice on the Site of any change in ownership and any material changes to the use of your personal information.
4.5 Legal Requirements and Protection of Rights
We may disclose your personal information when:
Required by law, regulation, court order, subpoena, or legal process
Necessary to enforce our Terms of Service and other agreements
Needed to protect the safety, rights, and property of 99commerce, users, or the public
In response to claims of unlawful activity
To investigate or prevent potential fraud or security threats
4.6 Affiliates and Subsidiaries
We may share information with our corporate affiliates and subsidiaries for purposes consistent with this Policy.
4.7 Consent and Direction
We may share your information with third parties if you have explicitly consented or directed us to do so.
5. Data Retention
5.1 Retention Periods
We retain your personal information for the period necessary to:
Fulfill the purposes for which it was collected
Comply with legal and regulatory obligations
Resolve disputes and enforce agreements
Conduct legitimate business operations
General Retention:
Account information: retained while your Account is active and for years after Account closure
Transaction and payment information: retained for 7 years to comply with tax and financial regulations
Email marketing preferences: retained until you unsubscribe or opt out
Website analytics data: typically retained for 24 months
Advertising and tracking data: retained for up to 13 months from last interaction
User-generated content: retained as long as your Account is active
5.2 Secure Deletion
Once information is no longer needed for the specified purposes, we will securely delete, anonymize, or aggregate it unless retention is required by law.
6. Your Privacy Rights
6.1 Hong Kong Personal Data (Privacy) Ordinance
As a Hong Kong-registered company, we comply with the Personal Data (Privacy) Ordinance (PDPO). You have the following rights:
Right of Access
You have the right to request access to personal data we hold about you. To submit an access request, please contact us using the information provided in Section 13.
Right of Correction
You have the right to request correction of inaccurate or outdated personal data. If you request correction, we will update your information within a reasonable timeframe.
Right to Object
You have the right to object to the use or disclosure of your personal data for certain purposes, including direct marketing.
6.2 Direct Marketing Opt-Out
We collect and use your personal information for direct marketing purposes, including promotional emails, newsletters, and targeted advertisements. You have the right to opt out of direct marketing:
(a) Email Marketing: Click the "Unsubscribe" link in any marketing email
(b) SMS Marketing: Reply "STOP" to any promotional SMS
(c) Postal Mail: Contact us to opt out of mailed promotional materials
(d) Phone: Request to be added to our do-not-call list
To manage your marketing preferences, please contact us at [contact information].
6.3 International Privacy Rights (GDPR, CCPA, etc.)
For Residents of the European Economic Area (EEA) and United Kingdom (UK)
If you are located in the EEA or UK, you have additional rights under the General Data Protection Regulation (GDPR):
Right to access, correction, and deletion of personal data
Right to restrict processing
Right to data portability
Right to object to processing
Right to withdraw consent
Right to lodge a complaint with a data protection authority
For California Residents
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
Right to know what personal information is collected
Right to delete personal information
Right to correct inaccurate personal information
Right to opt out of the sale or sharing of personal information
Right against discrimination for exercising your rights
For Other U.S. State Residents
Other U.S. states may provide similar privacy rights. Please contact us if you believe you are entitled to additional privacy protections under your state's privacy laws.
6.4 Exercising Your Rights
To exercise any of your privacy rights, please submit a written request to the contact information provided in Section 13. We will respond to your request within thirty (30) days or as required by applicable law.
7. Data Security
7.1 Security Measures
We implement comprehensive technical, administrative, and organizational security measures to protect your personal information, including:
Encryption of data in transit and at rest (SSL/TLS protocols)
Secure password storage and authentication
Regular security audits and vulnerability assessments
Access controls and role-based permissions
Intrusion detection and prevention systems
Firewalls and network security
Employee training and data protection awareness
Contractual security requirements for third-party processors
7.2 Security Limitations
While we employ industry-standard security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal information. Any transmission of data is at your own risk.
7.3 Breach Notification
If we discover a breach of personal data security that compromises your personal information, we will:
Notify affected individuals without undue delay
Provide information about the breach and our remedial actions
Notify relevant authorities as required by law
Cooperate with investigations
8. Third-Party Links and Services
8.1 Third-Party Websites
The Site may contain links to third-party websites, platforms, and services. This Privacy Policy applies only to the Site and does not apply to third-party websites or services.
We are not responsible for the privacy practices, security measures, or content of third-party websites. We recommend reviewing the privacy policies of any third-party services before providing your personal information.
8.2 Third-Party Integrations
Our Site integrates with various third-party services, including:
Social Media Platforms: Meta, TikTok, Instagram, Pinterest, Snapchat
Analytics and Measurement: Google Analytics, Hotjar, Mixpanel
Advertising Networks: Google Ads, Meta Ads Manager, Taboola, Outbrain
Payment Processors: Stripe, PayPal, Klarna
Marketing and Email: Klaviyo, Attentive
Content Delivery: AWS, Shopify
Data Infrastructure: Snowflake, BigQuery
Each third-party service has its own privacy policy governing how they collect, use, and protect your information. We encourage you to review their policies.
8.3 Pixel Tags and Tracking
Third-party platforms may use pixel tags, cookies, and tracking technologies on our Site to collect information about your browsing behavior. This information may be used for:
Advertising and retargeting
Analytics and measurement
Audience segmentation
Conversion tracking
You can manage your preferences and opt out through the privacy settings of those platforms or by using browser controls.
9. Cookies and Tracking Technologies
9.1 Cookie Use
We use cookies and similar tracking technologies to:
Remember your login information and preferences
Understand your browsing behavior
Measure Site performance and functionality
Track advertising effectiveness
Enable personalized content and recommendations
Prevent fraud and enhance security
Conduct analytics and research
9.2 Types of Cookies
Essential/Functional Cookies: Required for Site operation (login, security, preferences)
Analytics Cookies: Track how you use the Site and help us improve functionality
Marketing/Advertising Cookies: Track interactions with ads and enable personalized advertising
Third-Party Cookies: Set by third-party services for advertising and analytics
9.3 Cookie Management
You can control cookies through your browser settings:
Accept or reject cookies
Delete stored cookies
Set your browser to warn you before accepting cookies
Block third-party cookies
However, disabling cookies may affect Site functionality. For more detailed information about cookie management and our use of cookies, please refer to our separate Cookie Policy.
10. Children's Privacy
10.1 Age Restriction
The Site is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18 years of age.
10.2 Parental Concerns
If you are a parent or guardian and believe we have collected personal information from your child, please contact us immediately at the information provided in Section 13. We will take prompt action to remove such information and terminate the child's Account if applicable.
11. International Data Transfers
11.1 Data Transfer Locations
We are based in Hong Kong and operate globally. Your personal information may be transferred to, stored in, and processed in countries outside of Hong Kong, including:
United States (servers, analytics, payment processing)
European Union (service providers, analytics)
Singapore (regional data centers)
Other jurisdictions where our service providers operate
11.2 Data Protection Standards
When we transfer personal information outside Hong Kong, we ensure that:
The receiving country has been recognized as having adequate data protection laws
Appropriate safeguards are in place (Standard Contractual Clauses, Binding Corporate Rules)
Recipients are bound by contractual obligations to protect your information
Your rights are protected to the extent permitted by law
11.3 Your Consent
By using the Site and providing your personal information, you consent to the transfer, storage, and processing of your information in jurisdictions outside Hong Kong as described herein.
12. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:
Posting the updated Policy on the Site with a new "Last Updated" date
Sending you an email notification if the changes are material
Requesting your renewed consent if required by applicable law
Your continued use of the Site following publication of changes constitutes your acceptance of the updated Privacy Policy.
13. Contact Information
For questions, concerns, requests, or complaints regarding this Privacy Policy or our privacy practices, please contact us:
99commerce Limited
Thomson Communications Building
8 Thomson Road
Wan Chai
Hong Kong
Email: privacy@99commerce.com
Postal Mail: 99commerce Limited, Thomson Communications Building, 8 Thomson Road, Wan Chai, Hong Kong
Response Time: We will respond to inquiries and requests within thirty (30) days or as required by applicable law.
14. Hong Kong Data Protection Compliance
This Privacy Policy has been drafted to comply with the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong. Our commitment to data protection is aligned with:
Collection, use, and disclosure of personal data in accordance with statutory requirements
Transparent practices and clear notification
Individual rights and access to personal data
Security and confidentiality of personal data
Accountability and compliance measures
If you have concerns about our compliance with Hong Kong privacy laws, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) at:
Website: www.pcpd..org.hk
Email: enquiry@pcpd.org.hk
Phone: +852 2827 8800
End of Privacy Policy and Terms of Service
