Effective Date: August 5, 2025
This Privacy Policy (the "Policy") explains how Keno ("we," "us," or "Keno") collects, uses, stores, discloses, and protects your personal data when you use our mobile application and related services (collectively, the "Services"). We are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region ("Hong Kong") and other applicable data protection laws. By using the Services, you acknowledge and agree to the practices described in this Policy.
1. Scope of This Policy
This Policy applies to all users of the Services, including individuals who register an account ("Account"), browse the application, or interact with other users. It covers personal data collected directly from you, automatically through your use of the Services, and from third parties (where applicable).
2. Personal Data We Collect
We collect personal data necessary to provide, improve, and secure the Services. The types of data we collect include:
2.1 Data You Provide Voluntarily
Account Registration Information: Name, email address, date of birth, gender, and password (hashed for security).
Profile Information: Photos, bio, relationship preferences, hobbies, interests, and "bottom line" preferences (e.g., core values, non-negotiable priorities) you choose to share to facilitate matching.
Interaction Data: Messages, responses to story-driven prompts, participation in group activities, and feedback you provide through the Services.
Contact Information: If you contact our support team (e.g., via feedbackkenoassist@outlook.com), we may collect your communication details and inquiry content.
2.2 Data Automatically Collected
Usage Data: Information about how you use the Services, such as features accessed, time spent on the app, matches viewed, and interactions with other users.
Device Data: Information about your device, including device model, operating system, unique device identifiers (e.g., IDFA, UDID), IP address, and mobile network information.
Technical Data: Data collected through cookies, web beacons, and similar tracking technologies to analyze usage patterns and improve service performance.
2.3 Data from Third Parties
We may receive data from third-party service providers (e.g., payment processors, identity verification services) if you choose to use their services in connection with the Services. This data is collected in accordance with their privacy policies, and we process it only as permitted by law.
3. How We Use Your Personal Data
We use your personal data for the following purposes, based on your consent, our legitimate business interests, or legal obligations:
3.1 To Provide and Improve the Services
Facilitate Bottom Line Matching by analyzing your profile preferences and matching you with compatible users.
Enable story-driven interactions and community features, such as group chats, event participation, and shared activities.
Personalize your experience, including tailored recommendations for matches, content, and features.
3.2 To Ensure Security and Safety
Verify your identity and prevent fraudulent activities, account misuse, or violations of our User Agreement.
Monitor and address harmful behavior (e.g., harassment, spam) to protect the Keno community.
Respond to security incidents and enforce our policies.
3.3 To Communicate with You
Send account notifications (e.g., match alerts, password reset requests, service updates).
Respond to your inquiries, feedback, or support requests via email or in-app messages.
Provide information about new features, events, or promotions (you may opt out of marketing communications at any time).
3.4 For Legal and Administrative Purposes
Comply with applicable laws, regulations, or court orders in Hong Kong or other jurisdictions.
Resolve disputes, enforce our agreements, and protect our legal rights.
4. How We Share Your Personal Data
We do not sell your personal data to third parties. We may share your data only in the following circumstances:
4.1 With Service Providers
We engage trusted third-party providers to assist with service operations (e.g., cloud hosting, data analytics, payment processing). These providers are contractually obligated to protect your data and use it only to perform services on our behalf.
4.2 With Other Users
Your profile information (e.g., photos, bio, interests) and public interactions (e.g., group posts) may be visible to other users to facilitate connections, as permitted by your privacy settings.
Messages and private interactions are shared only with the intended recipient(s).
4.3 For Legal Reasons
We may disclose your data if required by law, court order, or government authority, or to protect our rights, property, or the safety of users or the public.
4.4 In Business Transfers
If Keno undergoes a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction, provided the receiving party agrees to protect it under this Policy.
5. Your Rights Under Hong Kong Law
Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the following rights regarding your personal data:
5.1 Right to Access
You may request access to the personal data we hold about you. To make a request, contact us at feedbackkenoassist@outlook.com with the subject line "Data Access Request."
5.2 Right to Correction
If you believe your data is inaccurate or incomplete, you may request corrections. We will review and respond to valid requests within a reasonable timeframe.
5.3 Right to Erasure
You may request deletion of your data where: (a) it is no longer necessary for the purposes collected; (b) you withdraw consent (if processing was based on consent); or (c) deletion is required by law. We may retain data if necessary for legal or legitimate business purposes.
5.4 Right to Withdraw Consent
You may withdraw consent for data processing (e.g., marketing communications) by adjusting your account settings or contacting us. Note that withdrawing consent may limit your ability to use certain features.
5.5 Right to Data Portability
You may request a copy of your data in a structured, machine-readable format for transfer to another service provider, where technically feasible.
6. Data Security and Retention
6.1 Security Measures
We implement technical and organizational measures to protect your data from unauthorized access, loss, or misuse, including:
Encryption of data in transit (e.g., SSL/TLS) and at rest.
Access controls limiting data access to authorized personnel only.
Regular security audits and updates to our systems.
While we strive to protect your data, no transmission over the internet or storage system is entirely secure. You are responsible for safeguarding your account credentials.
6.2 Retention Period
We retain your personal data for as long as necessary to provide the Services, comply with legal obligations, or resolve disputes. After this period, we will anonymize or delete your data to prevent identification.
7. Third-Party Links and Services
The Services may contain links to third-party websites or services (e.g., social media platforms). This Policy does not apply to third-party practices, and we are not responsible for their privacy policies or actions. We encourage you to review their policies before using their services.
8. Children’s Privacy
The Services are intended for users aged 18 or older. We do not knowingly collect data from children under 18. If we become aware of such data, we will delete it promptly.
9. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes via in-app notifications, email, or a prominent notice in the Services. Your continued use of the Services after the effective date of changes constitutes acceptance of the revised Policy.
10. Contact Us
If you have questions, concerns, or requests regarding this Policy or your personal data, please contact our Data Protection Officer at:
Email: feedbackkenoassist@outlook.com
Subject Line: "Privacy Policy Inquiry"
We will respond to your inquiry within 30 days of receipt.
By using Keno, you confirm that you have read, understood, and agree to this Privacy Policy.