Privacy Policy

Last updated: November 10, 2026

Introduction

This Privacy Policy explains how HK HEUNGYEUNG TRADE LIMITED ("Berefab", "we", "our", or "us") collects, uses, shares, and protects information when you use the Berefab platform, websites, and related services (the "Services"). For the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO"), we are the data user of the personal data described in this policy. By using the Services, you acknowledge this policy. If you do not agree with it, please do not use the Services.

1. Information we collect

1.1 Information you provide

• Account information: name, company name, work email, country, and password credentials when you register.
• Account verification details: information we ask for to confirm that an account is genuine and used for legitimate advertising, where required.
• Campaign content: campaign settings, budgets, creative assets, audience definitions, and reporting preferences you configure in the platform.
• Communications: the content of support requests, contact form messages, and feedback you send us.

1.2 Information collected automatically

• Usage data: pages viewed, features used, session activity, and timestamps within your workspace.
• Device and connection data: IP address, browser type, device type, operating system, and approximate location derived from IP.
• Cookies and similar technologies: necessary cookies for sign-in and session security, plus analytics, advertising, and functionality cookies where you consent to them.

1.3 Information from advertising activity

• Delivery data: impressions, clicks, and completion events associated with campaigns you run.
• Audience and measurement data: audience segments and conversion events you choose to connect, processed to report on campaign performance.

2. How we use information

• To provide, operate, and maintain the Services.
• To deliver, pace, and measure the campaigns you configure.
• To generate reports, dashboards, and audience insights for your workspace.
• To verify accounts and prevent misuse, fraud, and invalid activity.
• To respond to support requests and communicate about your account.
• To improve the platform, including debugging, testing, and product development.
• To send product updates and marketing communications, where permitted and with consent where required.
• To meet legal, regulatory, and contractual obligations.

3. Legal bases

Under the PDPO, we collect personal data for purposes directly related to the services described in this policy. Where required, we rely on contract performance, legitimate interests (such as securing the platform and improving the Services), consent (such as for non-essential cookies and direct marketing), and compliance with legal obligations.

We will not use your personal data for direct marketing unless you have consented, or you have indicated no objection, in accordance with the requirements of the PDPO. You may withdraw your consent or opt out of direct marketing at any time by contacting privacy@berefab.com.

Where other data protection laws apply — for example, the EU GDPR, the UK GDPR, or US state privacy laws such as the CCPA/CPRA — we handle personal data and rights requests in accordance with those laws.

4. Sharing information

We do not sell personal data. We share information only as needed to run the Services:

• Service providers: hosting, data storage, analytics, email delivery, and customer support tools that process information on our behalf under contract.
• Delivery and measurement partners: partners involved in serving or measuring campaigns you choose to run.
• Fraud and security providers: partners that help filter invalid traffic and protect the platform.
• Legal and regulatory: where required by law, court order, or a valid governmental request.
• Business transfers: in connection with a merger, acquisition, or transfer of assets, subject to this policy.
• With your direction: where you ask us to share information with a third party.

5. Cookies and your choices

We use necessary cookies to keep you signed in and to secure sessions. With your consent, we also use analytics, advertising, and functionality cookies. You can accept, reject, or customise these categories at any time using the Cookie Settings link in the footer, or through your browser settings. We handle cookies and similar technologies in line with applicable law and the guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

6. Data security

We apply technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse. Depending on the service and the data involved, these measures may include:

• encryption of data in transit and at rest where appropriate;
• role-based access controls and least-privilege administration;
• logging of workspace and administrative activity;
• vulnerability management and security testing on a scheduled cadence; and
• security and privacy awareness training for team members.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data retention

We keep personal data for as long as needed to provide the Services and for legitimate business or legal purposes, such as maintaining records, resolving disputes, and meeting legal obligations. When data is no longer needed, we delete or de-identify it.

8. Your rights

Under the PDPO, you may request access to the personal data we hold about you and request correction of data that is inaccurate. You may also object to certain processing, including direct marketing, and, where applicable, request deletion or restriction. To make a data access request or exercise any other right, contact privacy@berefab.com. We may take reasonable steps to verify your identity before acting on a request, and we will respond within the timeframe required by applicable law.

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD). Where other data protection laws apply, you may also contact the relevant supervisory authority in your jurisdiction.

9. International transfers

Information may be transferred to and processed in countries other than Hong Kong, including where our service providers operate. Section 33 of the PDPO has not yet been brought into force; where we transfer personal data outside Hong Kong, we apply contractual and due-diligence measures designed to protect it. Where other laws require additional safeguards, such as the EU Standard Contractual Clauses, we put those in place.

10. Children

The Services are intended for business use and are not directed to children. We do not knowingly collect personal data from children.

11. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be announced through the platform or by email, and the "last updated" date will be revised.