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PRIVACY POLICY

1. Introduction & Compliance

PENGAMINC LIMITED values your privacy. This Privacy Policy explains how we collect, use, store, process, and protect your personal data when you visit our Platforms or purchase Products. We process all personal data in strict accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO).

2. Data We Collect

We collect the following operational data streams:

  • • Identity & Contact Metrics: Full name, email address, phone number, billing and shipping addresses supplied during checkout or account creation.
  • • Transaction Data: Historical purchase records and payment tokens processed via encrypted third-party payment infrastructure.
  • • Technical Analytics: IP addresses, cookies, device parameters, and usage logs derived from your interactions with our Platforms.

3. Purpose of Processing

Your data is used strictly for necessary business operations, including:

  • • Fulfilling, processing, and distributing product orders;
  • • Membership verification and account management;
  • • Customer support administration and technical troubleshooting;
  • • Direct marketing communication regarding new product launches or promotions (executed strictly subject to your prior opt-in consent; you may opt-out at any time).

4. Data Sharing & Disclosure

We do not sell, rent, or trade your personal data. We disclose essential elements of your data under strict confidentiality obligations only to authorized partners supporting our infrastructure, including logistics carriers, secure payment gateways, and technical operators maintaining our Platforms.

5. Cross-Border Data Transfers

To facilitate global distribution, your personal data may be stored on secure cloud infrastructure located outside of Hong Kong. The Company implements stringent technical and contractual safeguards to ensure that any such international cross-border processing satisfies an equivalent standard of protection as required under the Hong Kong PDPO.

6. Data Security and Retention

We utilize commercial encryption and restricted access controls to shield your data from unauthorized loss, leakage, or compromise. Personal records are retained only for the exact duration required to fulfill operational or statutory obligations.

7. Your Rights

Pursuant to the HKSAR PDPO, you have the right to request access to your personal data, request corrections to inaccurate entries, or request the deletion of your account. To exercise these rights, please contact our Data Compliance Officer via email at play@pengaminc.com.