Privacy Policy


Company Name

Lae Technologies Limited and all group companies including related parties such as Lae Technologies Hong Kong Limited


June 20th 2018


Our products

VOTE tokens

This Policy

This Policy applies to the use of personal data collected by us in relation to our products. It aims to give you information on how we collect and process your personal data, including any data you may provide through our website.

What data do we collect?

We may collect personal data from you when accessing our website. This is to enable you to access the full extent of our services. Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous).

The list below exemplifies what data we may collect. The list is not exhaustive:

  • Given name

  • Family name

  • Address

  • Date of birth

  • Telephone number 

  • Image of passport

  • Selfie 

  • Image of recent utility bill displaying address 

  • Any other identity documents or due diligence related documentation that we may request

Other types of personal data we may collect include:Cryptographic hashes of personal data listed above

  • Digital identifying information sent by your mobile, computer or access device including but not limited to IP address and web log information

  • Verification reports issued by our partners at your request. 

We may require you to provide additional information to verify your identity, address or any other information in your account, such as your date of birth, copy of ID, citizenship, country of residence, and other information.

How do we use your data?

We use your data in accordance with local laws and regulations and connected to the following:

  • to verify your identity when you are dealing with us

  • to determine your eligibility for any of our products or services

  • to determine your compliance with the terms and conditions that apply to any of our products or services and applicable law

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • to improve our website based on your information and feedback

  • to answer your queries and requests

  • to comply with our legal and regulatory obligations

  • to carry out market analysis and research

  • to monitor use of our products and services

  • to assess, maintain, upgrade and improve our products and services

  • to carry out education and training programs for our staff

  • to manage and resolve any legal or commercial complaints or issues

  • to carry out planning and forecasting activities and other internal business processes

  • to keep you informed about our activities

Third party marketing and opting out clauses

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of our services.

Data Protection Regulation

Hong Kong and Isle of Man data protection laws

Contact Details

Our Complaint Procedure

Please send any privacy related enquiry to

Policy terms

1. Important information

Welcome to our Privacy Policy. We respect your privacy and we are committed to protect your personal data. Here we set out how we will protect your personal data when you visit our website and how your privacy rights are protected. We recognise our responsibility when dealing with your data and the need to comply with local regulations when it comes to the collection, holding, processing, use and/or transfer of personal data under the regulation in the form. 

We recommend you read this Privacy Policy carefully and be mindful of regular updates and any specific privacy policies we may provide. We keep our Privacy Policy under regular review and will make the latest version available on our website. You will find the website link in the form. 

Our website is not intended for children and we do not knowingly collect data relating to children.

2. Third party links

Our website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites and therefore we are not responsible for their privacy policies or the way they treat your data. Please read the privacy policies on the websites you visit.

3. What data do we collect?

Without your personal data we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

In addition to the list provided in the form, we also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.  

4. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5. How do we use your data

We strive to protect your choices regarding certain personal data uses, particularly around marketing and advertising and you will only receive communication from us in regards to the provision of the services, or otherwise requested by you.

6. How and where do we store your data

We may transfer and store your personal data in various countries around the world which will have different levels of protection of your data. We are based in the jurisdiction in the form and abide by local laws and regulations. Whenever we transfer your personal data abroad we ensure a similar degree of protection is afforded to it.

Security is important to us, and to protect your personal data we have put appropriate technical and organisational measures in place. Notwithstanding those security measures, it is important to remember that the transmission of data via the internet may not be completely secure. Please do not use our website if you do not want to take that risk. 

7. Who do we share your data with?

We may share your data with the following parties

  • our staff who need the information to discharge their duties

  • related entities within our corporate group

  • our partners, agents and service providers

  • payment system operators and financial institutions

  • professional advisers who we engage to provide advice on our business

  • government authorities who ask us to disclose that information, or to other institutions and third parties as required by law

Third parties we contract with are bound by contracts with confidentiality and non-disclosure clauses and may not use your personal information for any reason other than specified in this Privacy Policy.

8. Data security and retention

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used in an unauthorised manner, altered or disclosed.

We will only retain your data for as long as reasonably necessary to fulfil the purposes we collect it for, including the purposes of satisfying any legal, regulatory, tax or accounting requirements.We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

9. What happens if our business changes hands?

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. 

Personal data provided by users will, where it is relevant to any part of our business, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by us.

In the event that any of your personal data are to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10. Information about how we use cookies

We use cookies to optimise your use of the website. A cookie is a small file of letters and numbers that helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The information collected will help us directing online advertising to you.

11. How can you access your data?

You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). You will not have to pay a fee to access your personal data. However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

12. Contacting us

If you have any questions about this Privacy Policy, please see the contact details in the form.