Data & Privacy Policy

Subscriber’s Perspective & User’s Perspective

Introducing TESSR

At TESSR, we value your privacy and are committed to protecting your personal data and information we collect and/or receive. This Data and Privacy Policy outlines our practices, including your rights and choices, regarding the collection, process, use, disclosure and safeguard of your personal data and information in connection with our Software services in compliance with the laws of Hong Kong and the General Data Protection Regulation (“GDPR”).

This Data and Privacy Policy only applies to the information we, TESSR (hereinafter referred to as “TESSR”, “we”, “us” or “our”) collect or receive through your use of our Software services on our website at (www.app.tessr.us) (“Software”).

This Data and Privacy Policy may be updated from time to time to reflect changes in our privacy practices or legal requirements. The updated version of the Data and Privacy Policy will be posted on our website with the revised effective date. We will notify you about the changes that may affect our obligations or your rights via email.

By continue accessing and using the Software, you (and whom you act on behalf) agree and consent to our use of your personal data and information in line with the terms of this Data and Privacy Policy and any amendments, revision and/or updates thereof. If you do not agree, please do not proceed to use the Software. You have the right to withdraw your consent at any time by discontinuing your use of the Software. The withdrawal of consent shall not affect the lawfulness of us processing your Personal Data based on your consent before withdrawal.
Collection of Information

To subscribe to the Software and enjoy the benefit of our services, you will be required to provide us with your information necessary for creating and managing your account with us. We only collect personal data and information that is necessary for the purposes of performing the services related to the Software. In this event, we receive and store information from you including:-
1. Identifiers and Personal Information
  
  When you subscribe to the Software, you are required to create an account and provide us your name, display name, email address, and contact details as the identifiers. We may also collect your personal information including your phone and mobile phone number, date of birth, occupation and industry. This information is essential for user identification, authentication, communication and account management purposes.
2. Account Information
  
  We receive and store information related to your account with us, including email, account usernames, account passwords, security questions, profile pictures, authentication keys etc. We collect this information to ensure the security of your account.
3. Usage Data
  
  For better user experience and to improve the Software, we gather data and information on your preference and interaction with the Software. This information includes your subscription plan, the features, product and/or service you use, purchase and/or express interest in, session duration, user activity logs and any errors or crashed encountered. We use this information for any analytical and statistical purposes, performance enhancement and improvement of the Software and/or other related purposes.
4. Device and Log Information
  
  Certain information with regards to the device used to access the Software will automatically be collected when you log in to your account, such as your IP address, browser type, operating system, device identifiers and timestamps. This information is utilised for troubleshooting technical issues, maintain security and to ensure the compatibility of the Software.
5. Artwork
  
  The thumbnails, review files, previews, photos, videos and any other works uploaded by you (“Artworks”), as well as the information related to such Artworks including the file size, length, authors, comments etc. will automatically be stored in the Software. The Artwork and information are stored for your usage of the Software’s function as a work tracking, management and media review software. We will at our best effort protect the privacy of the Artworks however we cannot guarantee the data transmission or storage system to be 100% secure. You shall upload any Artworks at your own risk.
6. Payment Information
  
  Any payment for the subscription of plans and purchase of services and/or products in the Software shall be billed directly to you and/or automatically via our payment processor, Stripe.
  
  For any payment billed directly to you, we will issue invoice with our bank details to you for your payment. We may request proof of payment for reconciliation, but we do not store any sensitive information and financial information such as credit card or bank account details on our database.
  
  For any payment made through Stripe, we do not have access to nor store any sensitive information and financial information such as credit card or bank account details on our database. Stripe may collect your personal information, contact details, account information and financial information to verify and facilitate the transaction. You can find Stripe’s Privacy Policy at (https://stripe.com/en-gb-hk/privacy). You may contact Stripe’s Data Privacy Officer at ([email protected]) if you have any concerns or inquiries with regards to their Privacy Policy.
7. Cookies
  
  Cookies are small data files sent from the Software and stored on your device(s) when you visit or use the Software.
  
  We differentiate between Session Cookies and Permanent Cookies and use cookies for the general functionality of the Software and to enhance functionality, for preferences, and to improve performance. As cookies are necessary for the proper functioning of the Software, they cannot be disabled or controlled in the Software settings.
  
  However, you have the option to deactivate or restrict the transmission of cookies by adjusting your web browser settings. Please note that blocking cookies will limit your ability to log into your TESSR account and prevent you from using it.
  
  We may also use cookies from the third-party services/ data processors that provide the additional functionalities or services on the Software.
  
  The cookies are set automatically when you access our site. Therefore, by accessing and/or using the Software, you consent to the use of cookies.
  
  In your browser settings you have the ability to delete any cookies that are already stored on your device at any time.
(your information in Item 2(a) – (g) above shall hereinafter collectively be referred to as “Personal Data”)
How We Use Your Personal Data / Data Processing

We collect and process your Personal Data for the purposes directly related to the provision of our services in the Software and in accordance with the requirements of any Applicable Laws. We use the collected Personal Data to provide, analyse, administer and enhance the features and functionality of the Software, such as:-
1. To verify your identity, secure your account, and to communicate important updates, notifications and administrative messages.
2. To personalise your experience, tailor content, and improve user interfaces and experience.
3. To develop new features, identify areas for improvement, optimise overall user satisfaction.
4. For effective customer service and troubleshooting, we may use your information to respond to your inquiries, address support requests and provide technical assistance in relation to the Software.
5. We analyse usage patterns and trends to gain insights into user behavior, preferences and Software performance. Any data used for analytics and insights is aggregated and anonymised to protect your privacy.
6. Certain information is collected and retained for legal and regulatory compliance.
Non-Disclosure

In the following limited circumstances, we may disclose your Personal Data to third parties.
1. Legal Requirements
  
  Disclosure of your Personal Data may be required by any Applicable Laws or when we believe good faith that such disclosure is necessary for compliance of legal obligations or court order, prevention of fraud or protecting our rights. This may include disclosure of your Personal Data to court of applicable jurisdictions, competent governmental authorities, regulatory bodies and other relevant entities when necessary.
2. Disclosure to Contractors
  
  To deliver and maintain the Software and its related services, we may engage third party service providers. In such event, we may be required to disclose your Personal Data to such third-party service providers to fulfill their obligations. The third-party service providers will be contractually bound to maintain the confidentiality and security of any Personal Data disclosed to them, and use your Personal Data only to the extent necessary to perform the services on our behalf. In the event the disclosure of Personal Data involves transfer of data to place(s) outside Hong Kong, we will comply with the Hong Kong Personal Data (Privacy) Ordinance. In the event you are a resident of the European Union (EU) and the disclosure of Personal Data involves transfer of data to a third country or to an international organization, the EU General Data Protection Regulation (GDPR) will apply.
3. Aggregated and Anonymised Data
  
  We may aggregate and anonymise your Personal Data to create statistical, analytical or research reports. Aggregated and anonymised data does not personally identify you and the reports do not disclose any of your Personal Data. We may disclose such reports to third parties for purposes such as industry analysis, market research and understanding of usage trends.
4. Marketing
  
  In the event we intend to use any of your Personal Data for any direct marketing of any external products or services, we will inform our intention to you and will seek your prior consent. We will inform you the kinds of Personal Data that we intended to use and the classes of marketing subjects and marketing activities in relation to which the Personal data is to be used. Upon your consent to such marketing event, we will notify you when your Personal Data is used for the first time. You have the right to revoke your consent at any time.
Data Security

We prioritise the security of your Personal Data and will utilise measures to protect the Personal Data from unauthorised access, disclosure, alteration or destruction.

Data Processors

We prioritise the security of your Personal Data and will utilise measures to protect the Personal Data from unauthorised access, disclosure, alteration or destruction.

List of data processors(s)

Name	Amazon AWS
Service	Data storage, CDN (content delivery cache for profile avatar)
Data processed	Email, name, address, mobile phone number, date or birth, company address, IP address
Website	https://aws.amazon.com/compliance/gdpr-center/

Name	Google GCP & Firebase
Service	Data processing, notifications
Data processed	Display name, IP address
Website	https://cloud.google.com/security/gdpr

Name	Microsoft 365 Outlook
Service	Email service
Data processed	Email, display name
Website	https://privacy.microsoft.com/en-gb/privacystatement

Name	Mailchimp
Service	Email service
Data processed	Email, display name
Website	https://www.intuit.com/privacy/statement/

The external data processor is authorised to process the Personal Data collected on our behalf solely for the purposes of providing the Software services and as instructed by us, save and except as required by any Applicable Laws.

Data Retention

We retain your Personal Data for as long as it is necessary to fulfill the purposes outlined in this Data and Privacy Policy, unless an extended retention period is necessary, validly consented, in the public interest, scientific or historical research purposes or statistical purposes or any such erasure is prohibited by law, as the case may be. We will take all practicable steps to erase Personal Data when it is no longer required for the purposes for which the Personal Data is used.
Your Rights
1. Access, Correction, Update and Erasure
  
  You have the right to access, correct, update, erase and/or restrict the processing of your Personal Data provided to us.
  
  Access
  
  You have the right to make a request to understand whether we hold any specific Personal Data that belongs to you and request for a copy of such data. If we do hold such data, we will within forty (40) days, or within one (1) month if you are a resident of the EU, supply a copy of such data to you or you may access such data in the account settings of the Software where available.
  
  Correction
  
  If you find any of your Personal Data is inaccurate, you may request to make the necessary correction. Upon such request, we will within forty (40) days, or within one (1) month if the Personal Data if you are a resident of the EU, make the necessary correction to the data or you may make such correction in the account settings of the Software where available.
  
  Erasure
  
  You may request us to erase your Personal Data that is no longer applicable. Upon such request, we will within one (1) month check the necessity of such data and take practicable steps to make such erasure if such data is no longer required for the purposes for which the Personal Data is collected or processed, or if it is no longer accurate.
  
  Restriction of Processing
  
  If you are a resident of the EU, you may request us to restrict the processing of your Personal Data in the event of the following:
  1. If you contested the accuracy of your Personal Data we process, you may request us to restrict the process of your Personal Data for a period enabling us to verify the accuracy of the Personal Data;
  2. If the data processing is unlawful and you oppose the erasure of your Personal Data and requests the restriction of use instead;
  3. We no longer require your Personal Data for the purposes of data processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or
  4. If you object the processing of Personal Data and pending the verification of whether our legitimate grounds for the processing overrides those of yours.
  If you wish to make any request for access, correction, update, erasure and/or restriction of the processing of your Personal Data as aforementioned, you may contact our support team at ([email protected]).
  
  We will make reasonable efforts to fulfill your requests, subject to any legal or contractual restrictions. Please note that we may verify your identity, including request the provision of additional information necessary to confirm your identity before allowing the exercise of your aforementioned rights.
2. Opt-out
  
  You may choose to opt-out of receiving any marketing communications from us by contacting our support team. However, we may still send you important notifications or administrative messages related to your account and the Software.
3. Data Portability
  
  You may request a copy of the Personal Data provided to us in a structured, commonly used and machine-readable format by contacting our support team.
Complaints

If you believe that our data practices do not adhere to this Privacy and Data Policy or to the applicable privacy laws and regulations in Hong Kong, you have the right to lodge a complaint with the Hong Kong Privacy Commissioner for Personal Data at ([email protected]).

For data subjects from the EU, if you believe that our data practices do not adhere to this Privacy and Data Policy or to the EU General Data Protection Regulation (GDPR), you have the right to lodge a complaint with the data protection authority in your jurisdiction.

In either case, you shall copy us on the complaint or notify us regarding the said complaint.
Contact

If you have any questions, concerns or request regarding this Data and Privacy Policy or our data practices, please contact our support team at ([email protected]).

We take your privacy seriously and will address any inquiries or concerns promptly and in accordance to any Applicable Laws.

Last updated: 29 September 2023