We, TROME SMART SOLUTIONS HK Limited (“Trome”) appreciate your interest in our products and services. Trome recognizes the importance of your privacy. For the purposes of this Privacy Policy (the “Policy”), the terms “Trome,” “we,” “us,” and “our” refer to Trome and all of its subsidiaries and affiliates. “You,” or “your” refers to you, as a user of our website (www.tromehk.com) and services, whether operated by us or on our behalf (the “Services”). This Policy describes Trome’s collection, use and processing of that information and informs you on how to opt out of certain uses of information. By accessing Trome’s website and the use of the services provided, you consent to the collection and use of certain personal information as further described in this privacy policy. It is important that you read this Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing your Personal Information so that you understand how and why we are using your data. This Policy supplements those other notices and is not intended to override them.

By visiting our website, submitting information and/or purchasing any products, you agree to let us collect and use your personal information as described in this Privacy Policy. Therefore, before you provide us with any personal information, you should read through this Privacy Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check it occasionally. This Privacy Policy is incorporated into, made subject to and is governed by, that certain Terms and Conditions (“Terms”) by and between us and you (“you”).

The Services are also intended for adult use only and is not directed towards children, minors, or anyone under the age of 18.

Personal Information We Collect

Trome collects certain personal information about you during your interactions with our Services.

• Identity and Contact data: e.g. last name, first name, e-mail address, telephone number, login data (username and password);
• Purchase Data: e.g. data related to online purchases of products or services;
• Location data: to you with more precise and useful services, Trome may ask you to enter your address or postcode;
• Other Information You Volunteer: We may also collect any other information you voluntarily provide in the course of your communications with Trome;
• Navigation Data: your navigation software on Internet (“Browser”) may share with the website an approximation of your geographic location through information on wireless access points close to you and on your device IP address. If you think that sharing your approximate location through your Browser is invasive, you may revoke your consent at any time by changing your Browser’s settings (or the settings of your operating system);
• Aggregated Data: We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy Policy.

How We Collect Your Personal Information:

Information You Voluntarily Provide

You may give us your Personal Information by filling out forms, registering for an account with us, purchasing our products, or corresponding with us by mail, phone, email, or otherwise. This includes Personal Information you provide when you:

• use the tools on our website;
• purchase our products, place orders using our Services or shop with us;
• submit inquiries to us.

Information We Collect When You Use Our Services

• Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
• Information Collected by Cookies set on the site as further described in the Cookie Policy and Other Technologies.We may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. If you remove or reject cookies, it could affect the availability and functionality of our services. For more information about cookies, please visit: www.allaboutcookies.org.

Information We Collect From Third Parties

We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user.

• Third Party Service Providers. We collect Personal Information from service providers including where we operate accounts on third-party platforms, such as online application submission and management platforms and email platforms.
• Third Party Advertising Partners. We collect Personal Data received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
• Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles Aggregate Data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
• Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. The website do not currently provide this kind of setting. For more information about DNT signals, please visit https://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

How We Use Your Personal Information

Our primary purpose for collecting Personal Information is to provide you with products and services you request. We may also use your Personal Information for the following business purposes:

• to provide you with information, products and/or services you request;
• to communicate with individuals in written, electronic, and verbal form;
• to manage our customer relationship with you;
• to obtain payment for services and products that we provide to you;
• for our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you;
• to customize the advertising and content you see;
• to send promotional newsletters or catalogues;
• for internal business purposes such as complying with our internal policies or improving our Services;
• to analyze how our Services are being accessed and used;
• to verify information when you register or create an account with us;
• to protect our interests, including establishing, exercising and defending legal rights and claims;
• as necessary to comply with legal requirements, to enforce our Terms and Conditions of Use, Terms and Conditions of Online Sales and to prevent fraud, co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities; and
• for purposes disclosed at the time you provide your information or as otherwise set forth in this Policy.

How We Share Your Personal Information With Third Parties

Trome may, without giving notice, share personal information with its affiliates and with other third parties that provide services on behalf of Trome for the sole purpose of providing you with valuable information and/or services as discussed in this Policy. In addition, Trome may share personal information with third parties that provide marketing and other services on behalf of Trome, or to comply with certain legal requirements. Trome may also share personal information with non-affiliated parties with whom Trome may have entered into joint marketing agreements. However, any such third party will not be authorized to sell, rent, trade, or otherwise use your Personal Information.

Service Providers. We may use third-party service providers to perform certain business services on behalf of us or the Service, and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, document management services, communications services, software and website development services, collection services, accounting and audit services, compliance services, quality control services, analytics services, and marketing services.

Internal Third Parties. We may share Personal Information with our parent company, subsidiaries and other companies owned by or controlled by Trome who may use the Personal Information for the purposes described above.

Business Transactions. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

Non-personal and aggregate information. Trome uses aggregated data to improve the design of this website and may share it with marketing and advertising agencies for this purpose. Any such information may be gathered through cookies, pixel tags, click-stream information as discussed above.

HOW WE PROTECT YOUR INFORMATION

Trome uses reasonable care to store and maintain personal information and to protect it from alteration, misuse, loss or destruction. Unfortunately, no transmission of data over the internet can be guaranteed to be absolutely secure. Therefore, even though Trome endeavors to protect personal information, security of any information you transmit to Trome, or that you may receive from Trome, cannot be guaranteed.

Internal access to Personal Information will be limited to individuals who need access to personal information in order to provide products and/or services or to maintain or services those products and/or services. Individuals having access to personal information are limited in number and committed to Trome's privacy and security policies.

How Long We Keep Your Information

We will retain and use your information as necessary to provide services to you, maintain a record of your transaction(s) and progress for reporting purposes, comply with our legal obligations, to resolve disputes and to enforce our agreements. We may also retain your information in an anonymized form for analysis, research, and marketing purposes.

UPDATING YOUR INFORMATION

You may update or correct the personal information we have collected at any time; in order for us to update our records simply send us an e-mail with your updated information to info@tromehk.com.

INFORMATION BY E-MAIL

In the event you provide your e-mail address we will include you in our mailing list. If you are currently on such list and if you would prefer to be removed and not to receive further information from us, simply send us an e-mail to info@tromehk.com. and we will remove you from such list.

UNSUBSCRIBE

In the event that you prefer Trome to make no further use of your personal information which you may have provided, please contact us at info@tromehk.com.

RIGHTS UNDER CALIFORNIA PRIVACY LAWS

California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Please contact us at info@tromehk.com. in the event that you want to inquire about any possible sharing of your private information. We will provide you with the requested information by e-mail to your e-mail address used for making such inquiry.

AMENDMENTS

Trome reserves the right to amend or supplement this Policy at any time and without prior notice. Amendments will take effect immediately after implementation. Your continued access to this website will be considered as acceptance of any such amendment or supplement. Therefore, you are encouraged to review our online privacy whenever you visit this website for the most current version.

CONTACT INFORMATION

In the event that you may have any questions regarding Trome and this Policy you may send us an e-mail at info@tromehk.com.