Hong Kong Cross Ocean Technology Ltd. PRIVACY POLICY

Thank you for visiting Hong Kong Cross Ocean Technology Ltd.’s (“HK Cross Ocean,” “we” or “our”) Internet website. In this Privacy Policy, we detail our practices regarding the information that we collect about you as you visit https://www.hkcrossocean.com/, as well as all associated websites linked to https://www.hkcrossocean.com/ by HK Cross Ocean, our subsidiaries and our affiliated companies (collectively, the “Site”) and use our services and/or software available on our Site (collectively, our “Services”).

Privacy Policy Updates

If we change our Privacy Policy, we will post our updated Privacy Policy and notice of the change on the Site so it is visible when users log-on for the first time after the change is posted. HK Cross Ocean encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Site and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.

Information Collection

We collect information from you when you visit our Site and use our Services. We collect information from you when you register with us, request our software, contact us with questions or comments or request information, including your name, title, company name, address, email address, phone number, type of business or industry, username and password and other personal information that you voluntarily transmit with your communication to us. We also may collect information about you and your use of our Site and Services on or through the Site and through communications with you initiated via e-mail or phone or in-person at facility and trade shows. When you use the Services offered on or through the Site you will be required to log-in to the Site and provide your username and password. We also will collect broad demographic information, which we will use in the aggregate.

We also collect information about you automatically as you visit our Site and use our Services. Please see the section entitled “Cookies and Other Tracking Devices” below for additional information.

How We Use Your Information

We primarily use your personally identifiable information to provide our Services to you, to respond to your inquiries, and to notify you about Services that we believe would be of interest to you. In particular, we use your information, which may include your personally identifiable information, for the following purposes:

  • To register you to use our software and our Services;
  • To communicate with you, including to respond to your inquiries (including via email) and provide the services that that you have requested, and for other customer services purposes;
  • Account verification;
  • To notify you about regarding goods or services that you have purchased;
  • As permitted by law, for marketing and advertising purposes, including, for example, to notify you via email or other means of products and services that may be of interest to you, upcoming events, trade shows, and seminars;
  • To tailor the content of information that we may send or display to you;
  • To send surveys or newsletters;
  • To better understand how users access and use our Sites and Services, both on an aggregated and on an individualized basis; and
  • To improve our Site and our Services.

We also will use aggregate information to analyze trends, improve the content and general administration of the Site, and track users’ movement.

Cookies and Other Tracking Devices

We and our third party service providers use cookies to track user activity and collect Site data. Using these cookies we collect the following types of information, without limitation: your IP address, browser type, domain name, access time, referring page(s), the number of visitors to each page of our Site, and page views. We may combine this data with the personal information we have collected from you.

Cookies. Cookies allow a web server to transfer data to a computer for recordkeeping and other purposes. We and our third party service providers use “cookies” on our Site to, among other things, better serve you with tailored information and facilitate your ongoing access to and use of the Site. There are two types of cookies: session-based and persistent cookies. We also may use third party cookies for analytics.

Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.

Persistent cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.

Third Party Cookies. We may engage third parties to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we may permit third parties to apply cookies to users of our Site, where permitted by law, and, subject to your right to opt-out through the Network Advertising Initiative (as discussed below). We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze site usage. Such third parties may combine the information that we provide about you with other information that they have collected.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable their web browsers’ ability to accept cookies will be able to browse the Site however, certain site features may not work if you disable cookies.

Web Beacons, Pixel Tags and Other Technologies. We may use web beacons, such as clear GIFs, web bugs or pixel tags, which are tiny graphics with a unique identifier similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs in connection with our Site to, among other things, track the activities of website visitors, help us manage content, and compile statistics about website usage. We and our third party service providers may also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, measure the success of our marketing campaigns, identify when our e-mails are viewed and track whether our e-mails are forwarded.

Site Analytics. As noted, we work with third party service providers who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Site. For example, we use a variety of third party web analytics to help us improve our Site’s performance and user experiences.


We do not share your personally identifiable information with third parties for their own marketing purposes. We will share certain information about you, including personally identifiable information (“information”), in the ordinary course of business to facilitate our ability to provide our Services to you. We also will share your information with third parties and for the purposes described below:

  • Service Providers. We may disclose your information to third party vendors, service providers, contractors, or agents that perform functions on our behalf. For example, these vendors may assist us in managing our Site and in performing Services that you have requested from us.
  • In response to Legal Process. We will disclose your information when we reasonably believe we are required to do so by law, regulation or other government authority or when we deem it appropriate or necessary to provide such information to law enforcement authorities.
    To Protect Us and Our Users. We will disclose your information when we believe it is necessary and/or appropriate to do so in order to enforce the HK Cross Ocean Terms of Service, to protect and defend the rights or property of HK Cross Ocean, or to protect the safety of our employees, agents, or users of our Site and our Services.
  • Business Transfers. We may transfer your information to a successor entity upon a merger, consolidation or other corporate reorganization, or a part of a bankruptcy proceeding.

Links to Third-Party Sites

The Site provides links to other websites or resources over which HK Cross Ocean does not have control (“External Websites”). Such links do not constitute an endorsement by HK Cross Ocean of those External Web Sites. You acknowledge that HK Cross Ocean is providing these links to you only as a convenience, and further agree that HK Cross Ocean is not responsible for the content of such External Websites. Your use of External Websites is subject to the terms of use and privacy policies located on the linked to External Websites.

Children’s Privacy

HK Cross Ocean recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This Site is not intended for children under the age of 13. HK Cross Ocean does not target its services or this Site to children under 13. HK Cross Ocean does not knowingly collect personally identifiable information from children under the age of 13.


We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. HK Cross Ocean may use firewalls, password protection, secure socket layer and other security measures to help prevent unauthorized access to your personally identifiable information.

Updating, Correcting and/or Deleting Personally Identifiable Information

You may update the information that you provided in your profile by contacting us at [email protected]. Upon your written request, HK Cross Ocean will update or delete, as applicable, the personally identifiable information that you have provided to us as soon as reasonably possible. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Notice to California Residents

If you are a California resident, The California Consumer Privacy Act of 2018 (CCPA) may provide you with additional rights regarding our use of your personal information. You are entitled to the following:


To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws.  If you make a request, we have 45 days to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected], or write to us:

Hong Kong Cross Ocean Technology Ltd.

Attn: General Counsel






Notice to EU Residents

We would like to make sure you are fully aware of all of your data protection rights under General Data Protection Regulation (GDPR).  Every user is entitled to the following:

  • The right to access– You have the right to request that we provide copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification– You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete the information you believe is incomplete.
  • The right to erasure– You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing– You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing– You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability– You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected], or write to us:

Hong Kong Cross Ocean Technology Ltd.

Attn: General Counsel






International Data Transfer

By using our Services, you understand that your information will be transferred to countries where we have facilities or in which we engage service providers outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.  These countries may change from time to time and we can provide a current list upon written request. We transfer information in order to operate efficiently, to improve performance, and to create redundancies in order to protect information in the event of an outage or other problem. We will process your personal information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

Whenever we transfer personal information beyond the country of origin, we will do so in accordance with applicable laws. For personal information originating in the European Union that is transferred to an HK Cross Ocean

entity outside the European Union that does not have an adequate level of protection as determined by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your personal information.

Processing of Personal Information

Our computer systems are currently based in the United States, so your personal data will be processed by us in the United States where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create a user account with our Site as a visitor from outside the United States, by using our Site you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Policy.

Contact Us

If you have any questions regarding this Privacy Policy, please contact [email protected].

This Privacy Policy was last updated November 1, 2021.