Privacy and cookies.

01Introduction

Statistical Inference Limited (hereinafter referred to as "we", "us", or "our") welcomes you (hereinafter referred to as "you" or the "User") on our website d2tr.com (hereinafter referred to as the "Platform"). This Privacy and Cookies Policy (hereinafter referred to as the "Policy") describes the types of information we gather from people visiting our Platform and/or using our Platform and Services. Any capitalized terms used in this Policy have the meaning defined in our Terms of Use. By accessing the Platform or using our Services, you agree to adhere to this Policy. If you do not agree to the terms of this Policy, please do not use the Platform or any of our Services. Each time you use the Platform or our Services, the current version of this Policy will apply.

02General principles

We may collect two types of information from Users: "Personal Data" and "Aggregate Information" (as defined below).

03Personal Data

3.1 Processing Personal Data in a secure, fair, and transparent way is extremely important to us.

3.2 We process Personal Data in accordance with the applicable privacy laws and best industry standards. In addition to terms defined in the Terms of Use, this Policy uses the following definitions regarding your Personal Data: "Controller" is a party that determines the purposes and means of the processing of Personal Data; we are the Controller with respect to your Personal Data. "Data Subjects" refers to those individuals who are our Users. "Incident" means: (a) a complaint or a request with respect to the exercise of an individual's rights under the applicable privacy laws; (b) an investigation into or seizure of the Personal Data by government officials; or (c) any breach of the security and/or confidentiality leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, the Personal Data. "Personal Data" is any data relating directly or indirectly to an identifiable Data Subject. "Processing" is collecting, recording, using, storing, amending, adapting, disclosing, transferring or transmitting, structuring, combining, deleting or destroying Personal Data. "Processor" is the party that processes Personal Data on behalf of the Controller.

3.3 We collect Personal Data that is voluntarily provided when a User on our Platform creates an account or logs into their account.

3.4 This information is used to assist us in helping you select the appropriate service package, to allow you to authenticate to the Platform, to send you e-mail notifications, newsletters or other marketing materials.

3.5 We also automatically collect and store information about our User's use of the Platform and our Services, including page scraping activities, so that information gathered by a User through our Platform or Services can be served up each time a User logs in to the Platform.

3.6 We will process User's Personal Data only to the extent strictly necessary for the purpose of using the Platform and/or providing Services in accordance with the Terms of Use and this Policy and any further written instructions from the User that are mutually agreed upon between us.

04How we use your Personal Data

4.1 We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data: (4.1.1) to perform the contract we are about to enter into or have entered into with you or your company; (4.1.2) where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or (4.1.3) where we need to comply with a legal obligation.

4.2 When we process your Personal Data, we are required to have a lawful basis for doing so. There are various different lawful bases on which we may rely.

4.3 Lawful bases we may rely on: consent — where you have given us clear consent; contract — where our use is necessary for a contract; legal obligation — where we must comply with the law; legitimate interests — where use is necessary for legitimate interests of us or a third party.

05Who we share your Personal Data with

5.1 Where you have ordered Services, we may share your Personal Data with third party contractors in order to perform such Services.

5.2 Payment processing services enable us to process payments by credit card or bank transfer. We only share the information necessary to execute the transaction with the financial intermediaries handling the transaction and we do not store any of your financial details ourselves.

5.3 We will also share Personal Data with law enforcement or other authorities if required by applicable law.

06Transfer outside your jurisdiction

6.1 We are a company incorporated in Hong Kong. Due to the global nature of our operations, we may collect, access, store, process, and transfer your Personal Data in Hong Kong and in any other jurisdiction in which we, our affiliates, service providers, or business partners operate.

6.2 By providing your Personal Data to us, you acknowledge and agree that your Personal Data may be transferred to, stored in, or otherwise processed in jurisdictions outside your country or region of residence, which may have data protection laws that differ from those in your jurisdiction.

6.3 We will take reasonable technical and organizational measures to safeguard your Personal Data during international transfers.

07Marketing

7.1 We would like to send you information about the website, our services, the services on sale and any special offers. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

7.2 We will ask whether you would like us to send you marketing messages when you provide consent to such marketing.

7.3 You can unsubscribe at any time by: (7.3.1) contacting us using the detail provided at the end of this Policy; or (7.3.2) using the 'unsubscribe' link in emails.

08User obligations

In supplying Personal Data to us, the User warrants that it has all necessary rights to provide such Personal Data for Processing in connection with the provision of the Services. To the extent required by applicable law, the User is responsible for ensuring that any Data Subject consents that may be necessary to this processing are obtained.

09Aggregate information

9.1 We may also collect aggregate information. Aggregate information is information about your activities on the Platform or in connection with the Services that cannot be used to identify, locate, or contact you. Aggregate information is anonymised and is used in a collective manner; no single person can be identified by that compiled information.

9.2 We may use aggregate information to improve the Platform and Services, to monitor traffic and general usage patterns, and for our other legitimate business interests.

10Security of Personal Data

10.1 We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures.

10.2 We restrict access to collected information to our employees, service providers and agents who need to know that information in order to operate, develop or improve our services.

11Integrity of your data

We process your Personal Data only for the purposes for which it was collected and in accordance with this Policy. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary.

12Children and special categories

12.1 Our Platform and Services are not directed to children and we will not request personally identifiable information from anyone who we know to be under the age of 18, unless we have obtained verifiable parental consent.

12.2 We do not collect any Special Categories of Personal Data about you, including details about your race, religion, sex life, political opinions, health, or genetic and biometric data.

13Business transfers

In the event that we sell substantially all of our assets, or one of our business units is acquired, Personal Data of Users will likely be one of the transferred assets.

14Your rights

14.1 You have a number of important rights free of charge. In summary, those include rights to: fair processing of information; access to your Personal Data; correction of mistakes; erasure in certain situations; data portability; objection to direct marketing or automated decisions; restriction of processing in certain circumstances.

14.2 If you would like to exercise any of those rights, please email or write to us using the details provided on the Platform.

14.3 We will endeavor to respond to all requests within 30 days of receipt.

15Cookies

15.1 When you access our Platform or use our Services, we may collect information regarding your IP address for the purposes of administering the Platform and tracking Platform usage.

15.2 We may also collect information about the websites that directed you to our Platform. Such information is anonymous and cannot be tied directly to you.

15.3 We may use "cookies" to enhance your experience. A cookie is a small data file placed on your computer's hard drive. You may choose to delete cookies at any time, but if you do, we may not be able to identify you upon your return to the Platform.

15.4 Our cookies cannot be used to read data from your hard drive or retrieve information from any other cookies created by other websites.

15.5 We also share website usage information with those interested in running targeted promotional campaigns on the Platform via pixel tags.

15.6 We will ask for your consent to place cookies on your device, except where they are essential to provide you with a service you have requested.

15.7 You can withdraw any consent to the use of cookies by using our privacy dashboard on the website.

16How to contact us

If you have any questions regarding this Privacy Policy or the Personal Data we hold about you, please contact us through the contacts provided on the Platform.