This Privacy Policy explains how Newborn Town Inc. entities (collectively, “Newborn Town”, or “we”, “us”, “our”) collect your information through our website at (“Site” or “Website”). This Privacy Policy is subject to any service agreement between Newborn Town and you. By using the Adverting Service or this Site, you acknowledge that you have read and understood this Privacy Policy. Please review this Privacy Policy before using the Advertising Service or this Site. You represent that you have the legal right to accept these Privacy Policy on your behalf or on behalf of any party or person you represent. If you do not agree to this Privacy Policy, please stop using the Site.

We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make material changes to this Privacy Policy we will notify you by means of a prominent notice on this Site prior to the change becoming effective.

  1. Introduction

This Privacy Policy of Newborn Town’s Website applies to information collection and use including while you are visiting and using the Site.

  1. What Information We Collect

As you navigate through this Site, some of your personal information may be actively collected (for example, names, Email addresses, company name, occupations, and related information) or passively collected (which you did not actively provide) such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection. In order to improve our service quality, it may be necessary to ask for personal information to fulfill your requests and provide a better service. Newborn Town is entitled to take measures to validate the authenticity of personal information you provide. If you give us personal information of somebody else, we will assume that you have their permission to do so. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others.

  1. How We Use Your Information

The provision of personal information by you may be necessary where in our legitimate interest for the following purposes: (i) to provide you with Newborn Town products or services or information in relation to the same; (ii) to contact you and respond to your requests and enquiries; (iii) for business administration, including statistical analysis; (iv) to personalise your visit to the Site and to assist you while you use the Site; or (v) to improve the Site by helping us understand who uses the Site.

  1. Disclosure of Your Personal Information

We may use selected third parties to provide us with services, including companies that assist with programming and technical aspects of hosting and operating the Site, who may have access to your personal information. Our affiliates may also have access to your personal information including through or in connection with this Site for the purposes set out in this Privacy Policy.

The servers used in the operation of the Site automatically identify a computer by its IP address. Although, we will not be able to identify the computer using its IP address once you have left the Site. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.

  1. International Transfers

When you are located in the EEA, personal information collected from you, including via the Site, will be transferred to recipients in countries located outside the EEA (including in Singapore where the Site is hosted) which do not provide a similar or adequate level of protection to that provided by countries in the EEA. You hereby expressly consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA.

  1. Your Data Rights

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

  1. Security of Your Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We will only keep your personal information collected on the Site for as long as the time necessary for the purpose of the service or as required by laws and regulations and in any event in relation to personal information collected by us on the Site we will only keep this personal information for a limited period of time for legal purposes or for legitimate business purposes.For personal information collected via Google Analytics the following retention periods apply:

  1. The Protection of Minors

We attach great importance to the protection of information about minors. The content of the website is usually provided to adults. We do not collect information about minors. If we find out, we will delete them as soon as we receive the notice. Minor is defined in accordance with the laws applicable to the Privacy Policy and cultural practices in various countries and regions.

  1. Outside Sites and Linking

The Site may contain links and pointers to other sites on the Internet that are owned or operated by third party vendors and other third parties (the “Outside Sites”). Newborn Town is not responsible for the availability of, or the content located on or through, any Outside Site, including any webcasting or other form of transmission received from any Outside Sites. You should contact the site administrator or Webmaster for those Outside Sites if you have any concerns regarding such links or the content located on such Outside Sites. Newborn Town permits certain third party links to the home page of its Site, provided that Newborn Town is provided with notice of such links and does not thereafter object to such linking. Newborn Town reserves the right to revoke unilaterally any consent that it may at any time give to any linkage, including linkages to the home page. The Outside Sites are being provided to you only as a convenience and any link or pointer contained on this Site does not imply endorsement of the Outside Sites.

  1. Copyright

All Site content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of Newborn Town, or its respective content providers, and are protected by Hong Kong SAR and international copyright laws. All software used on the Site is the property of Newborn Town or its respective software suppliers, and such software is protected by Hong Kong SAR and international copyright laws and other applicable laws and treaties. Users of this Site shall not transmit/post any information to this Site that infringes the copyright or other intellectual property rights of others.

  1. Trademarks

All trademarks, service marks and trade names related to Newborn Town and used on the Site (collectively the “Marks”) are solely owned by Newborn Town. The Marks may not be used in connection with any product or service that is not a product or service of Newborn Town or that is likely to cause confusion among customers, or that in any manner disparages or discredits Newborn Town.

  1. Online Conduct

Any conduct by a person that in Newborn Town’s sole discretion restricts or inhibits any other person from using or enjoying the Site, is prohibited. You agree to use the Site only for lawful purposes and in accordance with that prohibition. You agree that you will not post on the Site or transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including, but not limited to, any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national, or international law.

  1. Termination of Usage

Newborn Town may, without incurring any liability to you, terminate access by you or suspend any access to all or part of the Site, without notice, for any conduct that Newborn Town, in its sole discretion, believes is in violation of any applicable law or this Agreement, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Site.



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