Privacy Policy

Last Updated on 10th February 2020. This Privacy Policy is effective immediately for Users after that date.

Fulfillment Group Limited (“Fulfillment Group Ltd.”, “we,” “us,”), registered under the laws of Hong Kong, with company number 67760803-000-05-19-9, having its seat and registered address at Unit 802, 8/F., China Insurance Group Building, 141 Des Voeux Road Central, Hong Kong, respect your privacy and is committed to protecting it through our compliance with this Privacy Policy. This policy describes:

  • the types of information that we may collect from you when you, as an individual, access or use our Website – and other online services, including the Fulfillment Group Ltd. cloud-based platform that may be offered by Fulfillment Group Ltd. to its clients (the “Platform”), (collectively, our “Services”); and
  • our practices for collecting, using, maintaining, protecting and disclosing that information.
    This policy applies only to information we collect through our Services and in the electronic communications sent through or in connection with our Services.

The definitions of the terms in this Privacy Policy have been referred by the Terms and Conditions of the Fulfillment Group Ltd. Website.


Fulfillment Group Ltd. qualifies as a Data Controller under the Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 (General Data Protection Regulation (the “GDPR”)). As such, we aim to comply with all legal obligations which the GDPR implies on Data Controllers.

Fulfillment Group Ltd. strives to offer its visitors and Users the many advantages of Internet technology and to provide an interactive and personalized experience. For these purposes, we, from Fulfillment Group Ltd., may use personally identifiable information – like your name, e-mail address, address, telephone number, etc., which are subject to the terms of this Privacy Policy. We, and we suppose you too, do not tolerate spam. We will therefore never sell, barter, or rent your email address to any unauthorized third parties.


Fulfillment Group Ltd. may collect and use information of and regarding its Users. We collect only data which is essential to our operations and enables us to provide you with better user experience.

The information, through which the person may be identified, may include data, which the User voluntarily enters, uses or provides when using the Services of the Website Fulfillment Group Ltd., the Platform, or submits when opting in for the use of certain Services. Fulfillment Group Ltd. collects and uses the information for the purposes, outlined in the Terms and Conditions, as well as to offer new services to the User or to familiarize them with new functionalities on the Website or the Platform.

We collect two types of information from and about our Users, including information:

  • by which you may be personally identified; and/or
  • about your internet connection, the equipment you use to access our Services and your usage details (i.e. your Internet Service Provider).

The information we collect on or through our Services may include:

  1. Personal information: Your full name, email address and other information you may provide on the Website or the Platform, such as your address, mobile phone number and website, place of work and position.
    We may collect this information in order to contractually provide you with the Services you opt in for or to respond to any queries.
  2. Preferences: Your preferences and settings such as time zone and language;|
    We may collect this information in order to enhance your User experience.
  3. Searches and other activities: The search terms you have looked up and results you selected;
    We may collect this information in order to enhance your User experience.
  4. Browsing information: How long you used our Services, which features you used, etc.;
    We collect this information in order to enhance your User experience.
  5. Communications: Between you and Fulfillment Group Ltd. support staff regarding the Services.
    We collect this information in order to respond to queries and provide assistance to you as a User of the Website and/or the Platform.
  6. Transactional information: If you make payments or purchases through our Services, we may collect and store information about you to process transactions.
    We may collect this information in order to fulfil our contractual obligations towards you.

The legal basis for the above processing is GDPR art. 6(1)(a) and (b), since the processing is either consented to voluntarily or is necessary in order to facilitate entering into a contract and/or the performance of such contract.


2.1. How we collect and store information depends on the pages you are visiting, the activities in which you elect to participate and the services provided. For example, you may be asked to provide information when you register for access to certain portions of our Website or the Platform, or when you make a payment.

2.2. Like most websites, Fulfillment Group Ltd. also collects information automatically and through the use of electronic tools that may be transparent to our visitors and Users. For example, we may log the name of your Internet Service Provider or use “cookies” technology to recognize you and hold information from your visit (for more information, please view our separate Cookie Policy). Among other things, the cookies may store your username and password, sparing you from having to re-enter that information each time you visit, or may control the number of times you encounter a particular part of the Website or the Platform. As we use additional technologies, we may also gather information through other means. In certain cases, you can choose not to provide us with information, for example by setting your browser to refuse to accept cookies.


3.1. Like other websites, we collect information to enhance your visit and deliver more individualized content. We respect your privacy and do not share your information with anyone, except in cases when that proves necessary.

3.2. We will retain the information we collect from you for a period of five years. After the expiry of this period we undertake to delete any information we have collected from you.

3.3. Aggregate information and information that does not personally identify you, may be used in many ways. For example, Fulfillment Group Ltd. may combine information about your usage patterns on the Website or the Platform with similar information obtained from other Users to help enhance our site and Services. We may use tools to track activity. Any such tools may include information about you, personally, and may allow us to identify you individually. Yet, in any such case, this information will only be visible to us, if you have already decided to provide it voluntarily.

3.4. We may use personally identifiable information, collected on the Website or the Platform, to communicate with you about our Terms of Service and Privacy Policy; services and products offered by or through the Fulfillment Group Ltd. Website and/or Platform; and other topics we think you might find of interest. Personally identifiable information collected by Fulfillment Group Ltd. may also be used for other purposes, including but not limited to Website and Platform administration, troubleshooting and other communications with you.

3.5. Certain third parties who provide technical support for the operation of our Website and Platform – our Web hosting service for example – may have access to such information. We will use your information only as permitted by law. We may also disclose your information in response to a court order, at other times when we believe we are reasonably required to do so by the applicable law, in connection with the collection of amounts you may owe to us, and/or to law enforcement authorities, whenever we deem it appropriate or necessary. Please note we may not provide you with notice prior to disclosure in such cases.


4.1. Fulfillment Group Ltd. won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you.

4.2. We may share your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (4) when we have a good faith belief that doing so will help prevent imminent harm to someone.

4.3. If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others. We will object to requests for information about users of our services that we believe are improper.

4.4. Certain third parties who provide technical support for the operation of our Website and Platform and our Web hosting service for example – may have access to such information.

4.5. If your personal data is transferred outside the EU/EEA, we will enter into EU standard contractual clauses approved by the European Commission prior to such transfer to ensure the required level of protection for the transferred personal data. If you require additional information and/or wish to obtain a copy of the standard contractual clauses (including relevant safeguards put in place), you can request this by contacting us as set out in section 10.


5.1. Right to withdraw your consent
You may withdraw your consent for collecting your personal information at any time. To do so, please contact us at

5.2. Right to change or review your information
If you would like to review, change or delete personal data we have collected from you or you had submitted or permanently delete your account, please contact us. For more information regarding the termination or deletion of your information, please refer to Section 7: Termination of this Privacy Policy.


6.1. We take reasonable steps to accurately record the personal information that you provide to us, as well as any subsequent updates.

6.2. We encourage you to review, update, and correct the personal information that we maintain about you. You may request that we delete personal data about you that is inaccurate, incomplete, irrelevant for legitimate purposes, or are being processed in a way which infringes any applicable legal requirements.


7.1. As mentioned, you may at any time review or change the personal information we maintain about you by contacting Fulfillment Group Ltd. Upon your request, we will delete your contact information and personal data from our active databases.

7.2. This Privacy Policy is effective until terminated by either party. If you no longer agree to be bound by this Privacy Policy, you must cease the use of Fulfillment Group Ltd. Website. If you are dissatisfied with Fulfillment Group Ltd. Website, its’ content, or any of these terms, conditions, and policies, your sole legal remedy is to discontinue using the Website. Fulfillment Group Ltd. reserves the right to terminate or suspend your access to and use of the Website, or parts of it, without notice, if we believe, in our sole discretion that such use is in violation of any applicable law, or harmful to our interests or the interests of another person or entity, or where Fulfillment Group Ltd. has reasons to believe that their use is in violation of this Privacy Policy or the Terms of Use.

7.3. Termination of your usage of the Platform will be subject to other agreements you may have concluded with Fulfillment Group Ltd.


Fulfillment Group Ltd. does not knowingly collect personal information from children under the age of 18. If we learn that we have personal information on a child under the age of 18, we will delete that information from our servers. Fulfillment Group Ltd. encourages parents to go online with their kids.


9.1. Changes to This Policy

Fulfillment Group Ltd. reserves the rights to change this Privacy Policy at any time. Please check this page periodically for changes. Your use of the services after any such amendment or change in the Privacy Policy shall be deemed as your express acceptance to such amended/changed Privacy Policy and an assent to be bound by such changed/amended Privacy Policy. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

9.2. Governing Law

This Privacy Policy and the use of the Website are governed Hong Kong law. The parties undertake to first try to resolve the dispute with by negotiation. If the parties fail to reach an amicable resolution through negotiation, Fulfillment Group Ltd. agrees to submit the dispute to the competent Court of Hong Kong.


10.1. Fulfillment Group Ltd. is controlled, operated and administered entirely within Hong Kong.

10.2. If you are accessing Fulfillment Group Ltd. Website or Platform from another jurisdiction, please be advised that you are transferring your personal information to Fulfillment Group Ltd. in Hong Kong and, by using the Website and/or the Platform, you consent to that transfer and to abide by the applicable laws concerning your use of the Website, the Platform and your agreements with us.

10.3. This statement and the policies outlined in this Privacy Policy are not intended to and do not create any contractual or other legal rights in or on behalf of any party.

10.4. Fulfillment Group Ltd. may provide a translation of the English version of the Privacy Policy into other languages. You understand and agree that any translation of the Privacy Policy into other languages is only for your convenience and that the English version shall govern your rights and responsibilities. In case there are any inconsistencies between the English version of the Privacy Policy and its translated versions, the English version of the Terms shall prevail.


If you believe Fulfillment Group Ltd. does not adhere to this Privacy Policy, in order to address a question, to resolve a complaint regarding the Website, the Platform or Fulfillment Group Ltd. Services, or to receive further information regarding the Services, please contact Fulfillment Group Ltd. using one of the following methods:

Address: Unit 802, 8/F., China Insurance Group Building, 141 Des Voeux Road Central, Hong Kong


Telephone: +852 91467858

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