VIRTUX INNOVATIONS PTE. LTD. (hereinafter referred to as “we”, “us” or the “Service Provider”) attaches great importance to your personal data and respects your right to privacy. In the course of providing you with access to the FJD Trion Creative website at creative.fjdtrion.com (hereinafter referred to as the “Website”), we will collect and process your personal data strictly in accordance with applicable laws and regulations and only within the scope stated in this Privacy Policy (hereinafter referred to as this “Policy”). Please read and understand this Policy carefully before submitting any personal data to us. Please note that this Policy applies only to the Website. If you use any other products or services provided by us, please refer to the privacy policy applicable to such product or service.
Please note that privacy rights and obligations may vary in certain locations under applicable local data protection laws. We have included supplemental information for certain jurisdictions in this Policy.
Current Website features: this public marketing Website provides product information and links to separate store and support services. It does not provide account registration, checkout or private scan uploads. Optional third-party videos and project viewers require a separate opt-in. Browsing or acknowledging this Policy does not constitute consent to optional cookies, advertising or other processing that requires consent.
1. Who We Are
The Website and related services are provided by VIRTUX INNOVATIONS PTE. LTD. and its applicable affiliates. For the personal data processing described in this Policy, VIRTUX INNOVATIONS PTE. LTD. is the data controller.
For processing activities described in this Policy where we independently determine the purposes and means of processing personal data, we will act as the data controller, personal information handler, or an equivalent responsible party under applicable data protection laws. For the specific responsible entity and contact details, please refer to the “How to Contact Us” section of this Policy and the applicable jurisdiction-specific supplemental terms.
Where we process personal data solely on behalf of, and in accordance with the instructions of, an enterprise customer, partner or other third party, such enterprise customer, partner or third party may be the controller of the relevant personal data, and we will process such data in accordance with our agreement with that party and applicable law.
2. What Personal Data We Collect
When you use the Website and/or services, we may from time to time ask you to provide personal information. The information requested and the reasons for requesting it will be explained to you when we make the request. Certain personal information is necessary to enable the basic functions of the Website; if you refuse to provide it, you may be unable to use the relevant functions. For other personal information collected to improve your user experience, you may decide whether to provide it. Refusal to provide such information will not affect your use of basic functions, and we will not refuse to provide services solely on that basis. Examples of circumstances in which we directly request information from you include:
Contact and enquiry information: for example, name, email address, telephone number, company name, country or region, products of interest and enquiry details.
Product and project information: for example, the products or solutions you are interested in, intended application, project requirements or site details that you choose to provide with an enquiry.
In connection with your enquiries and customer support requests, this may include project or site details, as well as on-site images, videos, audio recordings, logs or other materials that you actively provide when contacting us or seeking support. Such materials may contain the location, image or voice of individuals, or may incidentally capture employees, contractors, visitors, minors or other persons. We do not collect biometric information, health information, financial information or children’s personal data when handling website enquiries. If the foregoing materials constitute sensitive personal data, special-category personal data or other specially protected data in a particular scenario, we will process such data only to the extent necessary to respond to your enquiry or provide the support you request, and will obtain explicit consent, separate consent, provide required notices, or take other necessary measures as required by applicable law. Please avoid submitting such information where it is unrelated to the relevant product or service.
Customer support and after-sales information: information that you provide to us through the Website, our contact form, email, telephone or other customer support channels, such as contact details, enquiry descriptions, products of interest, project requirements, materials you voluntarily provide, communication records and handling results. We use such information only to the extent necessary to provide responding to enquiries, providing product information, arranging demonstrations and handling customer support requests.
Any information you provide in connection with contacting our customer support services.
When you use the Website and/or services, we may also automatically collect various types of information from you. Some information is collected anonymously, while other information may be associated after collection with information you have already provided. If such information is linked to information you provide in an enquiry, or if the information collected can be used to trace a specific individual, we regard it as personal data. The following are examples of information automatically collected while you use the Website and/or services:
Website usage and approximate location data: for example, the pages visited, referral source, access time, country or region, and approximate location inferred from your IP address.
Images and supporting materials: when you voluntarily provide project images, videos or other materials with an enquiry, these materials may contain personal data. Relevant images or videos may incidentally capture individuals or other personal information. Whether we receive or store such data depends on the information you choose to provide when contacting us.
Network and technical information: for example, IP addresses of Website visitors, browser type, operating system and device type, time zone and language settings, connection information, website access logs, performance data, error logs and security-audit records.
Transaction and service data: including enquiries or quotations, products of interest, customer or business contact details, demonstration requests, enquiry records and communications with our teams.
Information generated by Cookies, SDKs and similar technologies: when you use the Website, Cookies, local storage, SDKs, session tokens and similar technologies may generate or record online identifiers, browser and device information, session status, language and feature preferences, pages visited, buttons clicked, access time, errors, crashes, performance and security events, and other information. Based on the actual integrations, we will identify the relevant third parties, processing purposes and information types in our Cookie Policy or another appropriate location, and will provide mechanisms to consent, reject or disable such technologies as required by law. We will handle the information you provide in enquiries in accordance with the purposes and lawful bases described in this Policy.
Information that you do not submit through the Website may remain on your device or under your own control. We receive such data only when you actively submit it through the Website or a contact form, or where receipt is necessary to respond to your request.
Information You Provide and Your Control
You may choose to provide project details, images or other materials when submitting an enquiry. Information you do not submit remains under your own control.
For data that we can obtain only after you actively provide it, we will provide corresponding settings or choices where available through the Website.
The scope of data that we can actually access depends on the information you submit, your cookie preferences and the choices you make.
3. How We Use Your Personal Information
This section provides further details on the types of personal information we collect from you and the reasons for collecting it. For users residing in the United Kingdom or the European Economic Area (the “Relevant Jurisdictions”), this section also identifies the legal bases on which we rely to process your data.
Information You Provide to Us (Directly or Through a Third Party)
| Data Category | Purpose of Use | Typical Data | Primary Legal Basis |
|---|---|---|---|
| Contact and Enquiry Data | Responding to enquiries, providing product information and customer service | Name, email address, telephone number, company name, country or region, products of interest, enquiry details | Legitimate interests / consent where required / provision of requested services |
Personal Information Automatically Collected or Generated as Part of the Services
| Data Category | Purpose of Use | Typical Data | Primary Legal Basis |
|---|---|---|---|
| Website Usage and Interaction Data | Website analytics, service improvement and technical troubleshooting | Pages visited, access time, referring pages, approximate location and interaction data | Legitimate interests / consent where required |
| Enquiry and Supporting Materials | Responding to customer enquiries and providing requested information | Enquiry descriptions, products of interest and supporting materials voluntarily provided | Legitimate interests / consent where required / provision of requested services |
| Network, Access and Security Data | Maintaining Website availability, security and incident response | IP address, browser information, website access, performance, error and security logs | Legitimate interests / legal obligations |
4. How We Use Cookies and Similar Technologies
We may use Cookies and other similar technologies (such as web beacons, log files, scripts and eTags) (collectively, “Cookies”) to enhance your experience with our services. Cookies are small files placed on your device that enable us to provide certain features and functions.
On the current Creative Website, necessary local storage remembers your cookie preferences in this browser. Optional YouTube videos and Creative Portal / Model Web project viewers load only after you consent to Functionality and open the feature. On creative.fjdtrion.com, Google Analytics 4 loads only after you consent to Analytics. It sends Google information about visits and website interactions, including page URLs, device and browser information, and online identifiers, to help us understand website use and improve its content and performance. Advertising storage, advertising user data, advertising personalization and Google signals remain disabled in this integration. No targeted advertising, social-network trackers, Flash, email tracking pixels or ETags used as tracking identifiers are installed by this Website. General descriptions below apply only where a corresponding service is actually provided; the Cookie Policy gives the current Website inventory. You may reject optional features or withdraw consent at any time using Cookie Preferences in the footer.
(1) Cookies
We operate the Website at creative.fjdtrion.com to provide information about FJD Trion Creative products and solutions. To ensure that the Website functions properly, make access easier for you, and recommend content that may be of interest to you, we may store Cookies, Flash Cookies or other local storage provided by browsers or associated applications, typically containing identifiers, site names and certain numbers and characters (collectively, “Cookies”), on your computer or mobile device. Cookies enable websites to store data such as your preferences or goods and/or services in your shopping cart.
Where permitted by your mobile device or browser add-on services, you may adjust the level at which you accept Cookies or reject our Cookies. However, doing so may in some circumstances affect your ability to use our products and/or services securely, and may require you to change your user settings each time you use the Website and/or services.
(2) Technologies Similar to Cookies
In addition to Cookies, we may use web beacons, pixel tags, ETags and other similar technologies on our websites. For example, emails we send to you may contain links to content on our website. If you click such a link, we may track the click to help us understand your product or service preferences and proactively improve our customer service experience. A web beacon is typically a transparent image embedded in a website or email. Pixel tags in emails enable us to determine whether an email has been opened. If you do not wish your activities to be tracked in this way, you may unsubscribe from our mailing list at any time.
An ETag (entity tag) is an HTTP protocol header transmitted in the background between an internet browser and an internet server and may be used in place of a Cookie. ETags can help us avoid unnecessary server load, improve service efficiency and conserve resources and energy. We may also use ETags to record your identity so that we can better understand and improve our products or services. Most browsers allow users to clear browser cache data, and you may do so through your browser settings. Please note that disabling ETags may prevent you from enjoying an enhanced product and/or service experience.
5. How We Manage Your Personal Data
The servers supporting the Website are located in Hong Kong. Personal data may also be processed in other countries or regions where our service providers or authorised affiliates operate. We will determine data-storage locations in accordance with applicable law and, where cross-border transfers are involved, take the appropriate measures described in the “Local Storage and Cross-border Access” section of this Policy.
We retain your personal data only for as long as necessary to achieve the processing purposes described in this Policy, except where a longer period is required or permitted by law or regulation.
When determining specific retention periods, we take into account: (1) the period required to provide the relevant products or services; (2) the duration of our business relationship with you; (3) the form, volume and sensitivity of the data; (4) security, fraud-prevention and dispute-resolution needs; and (5) applicable legal, tax, accounting, regulatory and limitation-period requirements.
Where the law requires a specific category of data to be retained for a specified period, we will comply with the applicable legal requirements.
Once we no longer have a legitimate business need to process your personal data and the applicable retention period has expired, we will delete or anonymize your personal data. If deletion or anonymization is not possible, we will pseudonymize and/or securely store your personal data and isolate it from any further processing until deletion or anonymization becomes possible.
We endeavor to protect your personal data against unauthorized access, use, disclosure, alteration, destruction, damage, loss or other unlawful processing by strengthening administrative and technical safeguards, such as access controls, encryption and employee training. The network environment is not absolutely secure. In the event of a personal data security incident, we will comply with our notification obligations, which may include informing you of the basic circumstances of the incident and its potential impact, measures we have taken or intend to take, and recommendations for steps you may take to prevent or mitigate risks. We will endeavor to notify you in a timely manner by telephone, email, push notification or other means; in certain circumstances, we may publish an announcement on our official website. We will also proactively report our handling of personal-information security incidents to competent regulators as required.
If you know or have reason to believe that your personal data has been lost, stolen, misappropriated or otherwise compromised, or if there is any actual or suspected misuse of your personal data, please contact us promptly.
6. How We Share Your Personal Data
We may share personal data with applicable entities within our group to the extent necessary to provide global services, respond to enquiries, provide technical support, maintain information security, conduct internal management, and fulfill other purposes described in this Policy. Where it is genuinely necessary for us to share your personal information with a third party, we will centrally identify, in list form, the recipient’s name and contact details, the types of personal information shared, the purpose of sharing, the method of processing and the security measures taken. You may review such information in the personal-information sharing list within the Application. Such circumstances include:
For the current Website, the relevant third-party services are described in the Cookie Policy; no separate Application or account is needed to view that information or exercise your privacy rights.
(1) Third parties supporting the provision of services, including website hosting, contact form, customer support and analytics service providers that process information identified in this Policy on their servers in order to provide services or support relevant communications. We require such service providers, through contracts, data protection agreements and other appropriate measures, to process personal data in accordance with our instructions, the agreed purposes and applicable law.
(2) Companies within our corporate group that process your personal information in order to operate services worldwide. All relevant group companies may use your personal information only in accordance with this Privacy Policy.
(3) Regulatory authorities, judicial bodies, law-enforcement agencies and other third parties where sharing is necessary for safety, security or legal compliance. For example:
In certain circumstances, we may be legally required to disclose information about you to competent authorities, for example to comply with legal obligations or procedures, enforce our terms, address security- or fraud-related matters, or protect our users. Pursuant to valid legal process, such as a subpoena, court order or search warrant, such disclosures may be made with or without your consent and with or without notice to you. The terms of legal process may prohibit us from notifying you of such disclosures. Where a government agency does not provide the required subpoena, court order or search warrant, we may seek your consent before responding to its request for disclosure. We may also disclose your information for the following purposes:
to enforce our terms and conditions and other agreements, including investigating any potential violation of such terms and conditions or other agreements;
to detect, prevent or otherwise address security, fraud or technical issues; or
as required or permitted by law, to protect the rights, property or safety of us, our users, third parties or the public (including exchanging information with other companies and organizations for fraud prevention and credit-risk reduction).
(4) A third party acquiring all or substantially all of our business. We may disclose your information to a third party where: (a) we sell, transfer, merge, consolidate or reorganize any part of our business, or combine with, acquire or form a joint venture with any other business, in which case we may disclose your data to any prospective purchaser, new owner or other third party involved in the change to our business; or (b) we sell or transfer any of our assets, in which case information we hold about you may be sold as part of those assets and transferred to any prospective purchaser, new owner or other third party involved in such sale or transfer.
(5) Third-party website technologies. Details of cookies and other tracking technologies used on the Website are provided in our Cookie Policy.
We conduct strict security testing of third-party technologies through which authorized partners obtain personal information, and we agree on strict data protection measures with such authorized partners to ensure that they collect and process your personal data in accordance with our agreements and this Privacy Policy.
7. Localized Storage and Cross-Border Access to Your Personal Data
For cross-border transfer arrangements applicable to specific countries or regions, please refer to the “Supplemental Terms for Specific Jurisdictions” section of this Policy.
The servers supporting the Website are located in Hong Kong.
To provide technical support, after-sales services, system maintenance, security safeguards or other necessary services, our affiliates, technical support teams or service providers located in other countries or regions may remotely access relevant data to the extent necessary.
In certain jurisdictions, such remote access from outside the jurisdiction may be regarded as a cross-border transfer or international data processing. We will take the necessary contractual, technical and organizational measures in accordance with applicable law and, where legally required, complete the applicable notice, consent, filing, certification, assessment or other compliance procedures.
Unless otherwise required by law or separately authorized by you, the relevant overseas access party will not, solely as a result of such access, separately store your personal data in its country or region.
8. Your Rights
The laws of certain jurisdictions grant specific rights to users of the services. This section describes those rights.
This section applies to users located in the Relevant Jurisdictions. If you are located outside the Relevant Jurisdictions, please refer to the jurisdiction-specific supplemental terms for information on your rights and how to exercise them.
The sections entitled “Right of Access”, “Right to Rectification” and “Right to Erasure” also apply to users located in Canada.
Right of Access
You have the right to access the personal information we hold about you and to understand how we use it and with whom we share it.
Right to Data Portability
You have the right to receive a copy of certain personal information about you that we process. This includes personal information that we process on the basis of your consent or pursuant to our contract with you (such as customer support), as described in the “How We Use Your Personal Information” section above. You have the right to receive this information in a structured, commonly used and machine-readable format. Subject to certain exceptions, you also have the right to request that we transmit such personal information to another party. If you make such a request, we will provide you with further relevant information.
If you would like us to transmit such personal information to a third party, please include details of that party in your request. Please note that we can transmit information to a third party only where technically feasible. We may be unable to provide certain personal information where doing so would adversely affect the rights of others (for example, where providing personal information we hold about you would disclose another person’s information or our trade secrets or intellectual property rights).
Right to Rectification
If you believe that personal information we hold about you is inaccurate or incomplete and needs to be changed, please notify us using the methods set out in the “How to Contact Us” section below.
Right to Erasure
You have the right to request that we delete personal data we store about you. You may also contact us to request deletion of your personal data. We will process your request within the period prescribed by applicable law. We may retain certain information to satisfy legal requirements or for security purposes. Certain information may also be retained in anonymized form.
Where relevant data protection law provides a lawful reason for us to retain personal information (for example, to defend legal claims or protect freedom of expression), we may be required to retain such information, in which case we will inform you. If you request deletion of personal information that has been made public through the services and there are grounds for erasure, we will take reasonable steps to attempt to inform other parties displaying such personal information or providing links to it that the personal information should also be deleted.
Right to Restrict Processing to Storage Only
In certain circumstances, you have the right to request that we stop processing personal information we hold about you and store it only. Please note, however, that if we stop processing personal information and subsequently have a lawful basis under applicable data protection law to process it (for example, to defend legal claims or protect others), we may use that personal information again. As stated above, where we agree to stop processing relevant personal information, we will attempt to inform any third party to whom such personal information has been disclosed and request that they also cease processing.
Right to Withdraw Consent
Certain processing activities may be based on your consent. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal or any other existing lawful basis for the relevant processing.
Where consent is required to process your personal information, if you do not consent or withdraw your consent, we may be unable to provide the expected services.
Right to Object
Where the relevant processing is based on our legitimate interests (rather than a legal obligation), you have the right to object at any time to our processing of your personal data on grounds relating to your particular situation. If you object, we will cease processing your personal data unless there are compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defense of legal claims. If you do not wish us to process your personal data for marketing activities, you may change your preference at any time by emailing infosec@fjdynamics.com.
Right to Lodge a Complaint and Take Legal Action
If you wish to complain about the way we process your personal information, please contact us in the first instance and we will endeavor to address your request as soon as possible. If you believe we have violated applicable data protection law, you may lodge a complaint with the data protection authority in the country or region where you reside or work.
You also have the right to take legal action in respect of any infringement of your rights in connection with our processing of your personal data.
Service Announcements
Where we consider it necessary (for example, where access to the services is temporarily suspended for maintenance, security or privacy reasons), we may send you announcements or other administrative notices from time to time. You may not opt out of these service-related announcements because they are not promotional in nature.
Advertising
If we use automated decision-making to push information or conduct commercial marketing to you, or to make a decision that has a significant impact on your personal rights and interests, we will safeguard the transparency of such decision-making and the fairness and impartiality of its outcome, and provide you with an option not based on personal characteristics or a means to opt out. You have the right to request an explanation of the relevant processing rules and to refuse decisions made solely by automated means. You may manage non-essential cookies through Cookie Preferences on the Website or contact us using the methods set out in the “How to Contact Us” section below.
How to Exercise Your Rights
You may exercise your rights using the methods set out in the “How to Contact Us” section below. We will process your request within the period prescribed by applicable law. We reserve the right to refuse to act on a request where it would affect the rights and privacy of others. Where your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to act on the request.
Please note that we may need you to provide information to confirm your identity and determine that you are entitled to exercise the relevant rights.
9. How We Protect Children’s Personal Data
Our products and services are primarily intended for adults and business users and are not specifically directed at children. We do not knowingly collect children’s personal data in violation of applicable law. Where a relevant product or service genuinely requires the processing of children’s personal data, we will obtain valid authorization from a parent or guardian or take other necessary protective measures in accordance with the law applicable in the child’s country or region. If we become aware that children’s personal data has been collected without appropriate authorization, we will take legally required steps to delete the data or otherwise address the matter.
10. How This Policy Is Updated
We may update this Privacy Policy from time to time. If this Privacy Policy is revised, we will promptly make the new version available in a prominent location on this webpage. If there are material changes to this Policy, we will notify you in a more prominent manner, for example by email, SMS or website pop-up.
11. How to Contact Us
If you have any comments, suggestions or questions about this Policy, or any requests or enquiries concerning your personal data, you may contact us using the following details. As a general rule, we will respond within 30 days.
Contact: Data Protection Enquiries
Email: infosec@fjdynamics.com
Company: VIRTUX INNOVATIONS PTE. LTD.
Address: 101 Thomson Road, #28-03A United Square, Singapore 307591
Telephone: +65 8004922588
12. Supplemental Terms for Specific Jurisdictions
The laws of certain jurisdictions provide additional terms applicable to users of the services. This section describes those terms.
If you are a user located in one of the jurisdictions listed below, the terms set out under the name of your jurisdiction will apply to you in addition to the terms of our Privacy Policy above. In the event of any conflict, the supplemental terms under the name of your jurisdiction will prevail.
United Kingdom (UK GDPR and Data (Use and Access) Act 2025)
This section applies to users in the United Kingdom. Pursuant to the Data (Use and Access) Act 2025 (“DUAA”), our processing of personal data of UK users is subject to the following arrangements under the UK GDPR and DUAA: for automated decisions that have a significant effect on you, we will provide meaningful human intervention and rights to be informed and to object; except for necessary and low-risk Cookies (such as those used for statistical analysis, storage of user preferences, and security and fraud prevention), we will obtain your consent before use; certain processing may be based on recognized legitimate interests; and, for data subject access requests, we will respond in relation to information within a reasonable and proportionate scope.
This Website applies the same prior opt-in requirement to all optional services for UK visitors as for other visitors, including any optional statistical or preference technologies if introduced.
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
Collection and Disclosure of Personal Information
During the preceding 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
Identifiers, such as your name, IP address, online identifiers, email address and mobile phone number.
Internet or other electronic network activity information, such as information about your use of the Website and/or services, including pages visited and other website usage information described in the main body of this Privacy Policy. This information is collected directly from you and your device.
Commercial information concerning enquiries and interactions with the Website, such as products of interest. This information is collected directly from you and your device.
Other information described in Section 1798.80(e). This information is collected directly from you in your capacity as our consumer.
We collect your personal information for the following purposes:
to provide services to you and respond to your enquiries;
to improve our services, including their functionality;
for security and verification purposes, including preventing and detecting fraudulent activity; and
to identify and remedy technical issues and vulnerabilities.
For additional information about how we use each type of personal information, please refer to the “What Personal Data We Collect” and “How We Use Your Personal Data” sections in the main body of this Privacy Policy.
We disclose personal information to the following types of entities:
other companies within our corporate group that process your personal information for the purpose of operating the services;
other companies that provide services on our behalf and support the services, which are contractually prohibited from retaining, using or disclosing personal information for any purpose other than providing services to us;
regulatory authorities, judicial bodies and law-enforcement agencies; and
entities that acquire all or substantially all of our business.
During the preceding 12 months, we have not sold California residents’ personal information for money or other valuable consideration, nor have we shared such personal information for cross-context behavioral advertising.
Rights under the CCPA:
If you are a California resident, you have the right to:
request that we disclose to you, free of charge, the following information collected during the 12 months preceding your request:
the categories of personal information we collected about you;
the categories of sources from which the personal information was collected;
the purposes for collecting your personal information;
the categories of third parties to whom we disclosed your personal information, the categories of personal information disclosed (if applicable), and the purposes for disclosing your personal information; and
the specific pieces of personal information we collected about you;
request that we delete personal information collected from you, subject to the exceptions provided by the CCPA; and
request correction of your personal information; opt out of the sale or sharing of personal information (for cross-context behavioral advertising); limit our use and disclosure of sensitive personal information (such as precise geolocation, government identification numbers, financial accounts, race or religious beliefs, biometric information and health information); and, where technically feasible, receive or transfer your personal information in a portable format; and
not be unlawfully discriminated against for exercising your rights under the CCPA, including by being provided a different level or quality of service or being denied goods or services.
We aim to respond to all verified requests under the CCPA within 45 days. Where necessary, this period may be extended by an additional 45 days, in which case we will explain the reason for the extension.
How to Exercise Your Rights
First, you may log into your account and manage your data. If you are a California resident to whom the CCPA applies, you may also contact us through our website or email us at infosec@fjdynamics.com to exercise any rights you may have in relation to other data.
Nevada
Under Nevada law, Nevada residents who purchase goods or services from us for personal, family or household purposes may opt out of the “sale” (as defined under Nevada law) of “covered information” to another person where that person will license or sell such information to additional persons. “Covered information” includes a name, address, email address and telephone number, or an identifier that permits a specific individual to be contacted either online or offline. As described above, we may share your information with certain third parties that we believe may provide offers and promotions for products and services in which you may be interested through the methods described above. We do not believe that our sharing of information in this manner constitutes a sale under Nevada law. However, if you are a Nevada resident who has purchased goods or services from us, you may submit a request by emailing infosec@fjdynamics.com so that we can record your opt-out preference. Please note that we may take reasonable steps to verify your identity and the authenticity of your request.
Mainland China
Consent
We will not collect or use your personal information without your consent, and you may withdraw your consent at any time. Please note that after you withdraw your consent, we will cease collecting and using your personal information on the basis of that consent; the processing of personal information carried out on the basis of your consent before withdrawal will remain valid.
Parental and Guardian Consent
If you are under 14 years of age, please do not use the services for any purpose unless your parent or guardian has consented to this Privacy Policy on their own behalf and on your behalf. We do not knowingly collect personal information from children under 14 without such consent.
Your Rights
We protect your personal-information rights in accordance with applicable Chinese privacy laws, including the rights to access, copy, correct and delete personal information; where statutory conditions are met, request transfer of personal information to a designated processor; request that we explain our personal-information processing rules; withdraw consent; request account cancellation; refuse decisions made solely by automated means; and lodge complaints or reports concerning our personal-information processing activities with the authority responsible for personal information protection. For more information, please refer to the “How to Exercise Your Rights” subsection above.
Hong Kong SAR, China
As a data subject in Hong Kong SAR, China, you have statutory rights in relation to the personal data we hold about you, to the extent permitted by applicable laws and regulations.
You have the right to make a data access request (to receive a copy of data about you that we process) and a data correction request, and the right to object to the use of your personal data for direct marketing. We may charge a fee for complying with a data access request.
Japan
The business operator handling your personal information may jointly use the following personal information:
(1) Items of Personal Information Jointly Used
The personal information described in the “What Personal Data We Collect” section above.
(2) Scope of Joint Users of Personal Information
Companies within the corporate group to which the operator belongs (including companies that join our corporate group after this Privacy Policy is established).
(3) Purposes of Use by Joint Users of Personal Information
The purposes of use described in the “How We Use Your Personal Data” section above.
(4) The operator responsible for managing personal information will take necessary and appropriate measures to prevent leakage, loss or damage of personal information and to ensure its secure management. If you have any questions about the security management measures taken, please feel free to email us at infosec@fjdynamics.com.
Canada
If you are located in Canada and wish to obtain written information about our policies and practices regarding service providers located outside Canada, you may contact us through our website or email us at infosec@fjdynamics.com.
Where service providers we use may have access to your personal information, we require them to implement privacy and security standards comparable to ours. We maintain the confidentiality and security of your personal information and prevent it from being used for purposes other than those set out in this Privacy Policy through contracts with service providers and other measures.
Russia
If you use the Website and/or services in Russia, by doing so you agree that:
you confirm that you are at least 18 years of age;
for the purposes of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (as amended), or any replacement legislation, your information may be processed in accordance with this Privacy Policy; where the processing relates to legitimate interests, optimization of the services or performance of a contract, you agree that, for purposes of Russian law, your consent may be treated as the basis for such processing (that is, the processing is carried out with your consent); and such consent also covers the processing of any Cookies to the extent those Cookies constitute personal data under Russian law;
your information may be transferred across borders to any country or region in which we maintain a database or branch office;
where applicable law requires local storage of personal information relating to Russian users, we will comply with those requirements; before transferring such information abroad, we will complete the notification procedure with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) as required by law and comply with its rules governing cross-border transfers;
for purposes of federal laws relating to marketing/advertising, we may provide advertising/marketing information to you unless you opt out of receiving it.
The subsections entitled “Right of Access”, “Right to Rectification”, “Right to Erasure”, “Right to Restrict Processing to Storage Only”, “Right to Object” and “Advertising” in the “Your Rights” section above apply to users in the Russian Federation.
We will notify you of any material changes and may require you to accept such changes. Unless we require your acceptance, if you continue to use the services after notification, we will obtain your separate consent to the changes again.
You may contact us by email at infosec@fjdynamics.com. Please include the word “Russia” in the subject line.
South Africa
1. Personal Information of Juristic Persons
In addition to the personal data collected under this Policy, we also process data relating to South African juristic persons, which may constitute personal information under South Africa’s Protection of Personal Information Act. Personal information relating to South African juristic persons that we process includes:
Examples: the name, address, telephone number, email address and company registration number of a company or other juristic person, and the name of its company contact person.
2. Purposes and Legal Bases for Processing Personal Information of Juristic Persons
The purposes of processing the personal information described above include:
identifying customers and prospective customers;
marketing or selling products to customers;
negotiating and entering into contracts with customers;
Generally, we process the personal information described above for the following purposes: to perform contracts with customers; to obtain the consent of the relevant customer or juristic person; or on the basis of our legitimate interests or the interests of a third party to whom the information is provided, including marketing and selling our products and services, supporting customers in accessing and using our products, providing training to users of our products, responding to customer or user enquiries, improving products and services, and recommending product features, new versions or maintenance to users.
Personal information of juristic persons may be shared with third parties and transferred to countries/regions outside South Africa. Please refer to the relevant provisions of this Policy in this respect.
3. Laws Authorizing or Requiring the Collection of Personal Information
Legislation that may require the processing of personal information relating to individuals or juristic persons includes:
Financial Intelligence Centre Act, 2001;
Income Tax Act, 1962; and
Companies Act, 2008.
4. Sensitive Personal Information:
Where applicable, information relating to an individual’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political beliefs, health or sex life, biometric information or criminal conduct, including any photographic or video record, may be regarded as sensitive/special personal information under applicable South African laws and regulations.
Before processing personal data of a child under 18, we will obtain the consent of the child’s guardian. Children’s personal data is treated as special personal information and afforded enhanced protection. We will use an individual’s special personal information for the purposes described in this Privacy Policy or for other purposes notified to you from time to time.
5. Contact Us. If you have any questions or concerns, you may contact us using the contact details below or the information provided in the “How to Contact Us” section of this Policy. We will respond to your request within a reasonable period, and in any event no later than 30 days. We may require verification of your identity.
Mexico
Age Restrictions
You may not use the services unless you are at least 18 years of age or have obtained the consent of your parent/guardian to this Privacy Policy on their own behalf and on your behalf.
Types of Personal Information We Use
For the avoidance of doubt, Sections 2 “What Personal Data We Collect” and 3 “How We Use Your Personal Data” provide full details of the personal data we use. Accordingly, for purposes of the Federal Law for the Protection of Personal Data Held by Private Parties (the Federal Law for the Protection of Personal Data Held by Private Subjects (“FLPPDHPP”), effective March 21, 2025, which replaced the former LFPDPPP) and other applicable provisions, we provide you with complete information regarding the personal data we use.
Purposes of Processing
Certain of the processing purposes described above are voluntary purposes, including displaying personalized recommendations and advertisements to you. We may also use your personal data for voluntary purposes to send information to your email address that we believe may be relevant to you. You may object to the processing of your personal data for voluntary purposes as described in the “Your Rights” section below.
Please note that we may also use your personal data for the following purposes: complying with legal obligations or requests of competent authorities; asserting or defending our rights before competent authorities/courts; responding to requests you make to us concerning your personal data; and carrying out transfers of personal data as detailed in Section 5 “How We Manage Your Personal Data”, Section 6 “How We Share Your Personal Data” and Section 7 “How Your Personal Data Is Transferred Across Borders”.
Consent to Data Transfers
As a general rule, we do not require your consent for the transfers described in Section 5 “How We Manage Your Personal Data”, Section 6 “How We Share Your Personal Data” and Section 7 “How Your Personal Data Is Transferred Across Borders”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of our business.
By using the Website and/or services and providing your personal data to us, you consent to the data transfers described above for which your consent is required. You may exercise the rights relating to your personal data described in the “Your Rights” section below.
Your Rights
The subsections entitled “Right of Access”, “Right to Rectification”, “Right to Erasure”, “Right to Object” and “Right to Restrict Processing to Storage Only” in the “Your Rights” section above, including restrictions on the use and disclosure of your personal data, as well as the “Advertising” subsection, also apply to users located in Mexico.
You also have the right to withdraw any consent you have provided to us for processing your personal data.
To exercise any of your rights, please contact us through our website or email us at infosec@fjdynamics.com.
For more information about your rights and the applicable methods, procedures and requirements for exercising them, please contact us by email at infosec@fjdynamics.com.
Cookies
We collect certain information relating to your browsing and device through Cookies, some of which may be regarded as personal data (see the relevant sections above for details). You may adjust your browser settings to reject or disable Cookies. Because browsers differ, please consult the instructions provided by your browser. If you reject, disable or delete Cookies, you may be unable to continue using certain functions of the services. For more information about our use of Cookies and how to disable them, please refer to the “How We Use Cookies and Similar Technologies” section above.
France
Your Rights
Instructions Regarding the Processing of Your Personal Data After Your Death
You have the right to provide us with general or specific instructions concerning the retention, deletion and communication of your personal data after your death.
Specific instructions are valid only for the processing activities referred to in those instructions, and their implementation requires your explicit consent.
You may amend or withdraw your instructions at any time.
You may designate a person to be responsible for carrying out your instructions. Upon your death, that person will be informed of your instructions and will have the right to request that we implement them. If no person is designated, or unless otherwise provided, if the designated person dies, that person’s heirs will have the right to be informed of your instructions and request that we implement them.
If you wish to provide such instructions, please contact us through our website or by emailing infosec@fjdynamics.com.
Brazil
This section applies to users located in Brazil:
Withdrawal of Consent
Where we use your personal information on the basis of your consent, you may withdraw the consent you previously gave to the collection, use and disclosure of your personal information, subject to contractual or legal restrictions. To withdraw consent, you may contact us by emailing infosec@fjdynamics.com to exercise your rights. This may affect our ability to provide services to you.
Parental and Guardian Consent
If you are under 18 years of age, please do not use the services for any purpose unless your parent/guardian has consented to this Privacy Policy on their own behalf and on your behalf. We do not knowingly collect personal information from children under 18 without such consent. If you believe we have obtained any personal information from a child under 18 without parental/guardian consent, please contact us promptly and we will immediately investigate (and delete) such personal information.
For processing based on your consent, before collection we will specifically and clearly inform you of the particular processing purposes and obtain your freely given, informed and unambiguous consent. You may withdraw consent at any time, and withdrawal will not affect the validity of processing carried out before withdrawal.
Colombia
This section applies to users located in Colombia:
Data Subject Rights
Under applicable law, you have the right to:
freely access your personal data;
know, update and rectify your personal data where the data is inaccurate, incomplete, fragmented, misleading, or has been processed without authorization or in a prohibited manner;
request evidence of authorization for the processing of your personal data, unless exempted under applicable law;
lodge a complaint with the Colombian Superintendence of Industry and Commerce;
withdraw authorization and/or request deletion of your personal data where there is no legal or contractual basis for retaining it; and
refuse to authorize the processing of sensitive personal data. As a general rule, we do not process personal data of minors (persons under 18); such data will be processed only where it is public in nature, authorization has been obtained from the legal representative, and the best interests of the child have been taken into account. Providing sensitive personal data is not mandatory.
Australia
This section applies to users located in Australia:
Overseas Recipients
We take reasonable steps to ensure that third parties located outside Australia process your personal information, when received, in a manner consistent with Australian privacy law. However, you acknowledge that we do not control the acts or omissions of such third-party recipients and are not responsible for them.
Right of Access
You have the right to access the personal information we hold about you, information about how we use it and information about the parties with whom we share it. You may log into your account to access the personal information you provided for your account. If you believe we hold any other personal information about you, please contact us at infosec@fjdynamics.com.
Right to Correction
You have the right to correct any inaccurate personal information we hold about you. You may log into your account in the Application to access the personal information we hold about you. If you believe we hold any other personal information about you that is inaccurate, please contact us at infosec@fjdynamics.com.
Children
For minors under 18 years of age, we will determine whether they have the capacity to consent based on their maturity and level of understanding. Where a minor does not have sufficient capacity to consent, we will obtain the consent of the minor’s parent or legal guardian for use of the Website.
Your Rights
If you are dissatisfied with our response to your request to access or correct your personal information, or to a privacy complaint concerning your personal information, you may contact us at infosec@fjdynamics.com.
Philippines
Minimum Age Requirement
Children under 13 must obtain verifiable parental or guardian consent to use the Website; minors aged 13 to 15 are subject to the applicable rules governing consent for information-society services; and all persons under 18 receive special protection.
Your Rights
You have the following rights:
Right to be informed. In certain circumstances, you have the right to be informed whether your personal data is being or has been processed, including whether automated decision-making and profiling are involved.
Right to object. In certain circumstances, you have the right to object to our processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right of access. In certain circumstances, you have the right to obtain reasonable access to your personal information upon request.
Right to rectification. In certain circumstances, you have the right to identify errors in your personal information and request that we correct them, unless the request is frivolous or unreasonable.
Right to erasure or blocking. In certain circumstances, you have the right to suspend, withdraw, or request the blocking, deletion or destruction of your personal information.
Consent
By consenting to this Privacy Policy, you consent to our:
collecting and processing your personal information in accordance with the “How We Use Your Personal Data” section of this Privacy Policy;
sharing your personal information, in accordance with this Privacy Policy and for the purposes described herein, with third parties, companies within our corporate group, and third parties that acquire all or part of us or our business; and
transferring or storing your personal information at destinations outside the Philippines as described in the “How We Manage Your Personal Data”, “How We Share Your Personal Data” and “How Your Personal Data Is Transferred Across Borders” sections of this Privacy Policy.
Türkiye
For compliance with the Turkish Personal Data Protection Law (“DPL”) and its secondary legislation, you may contact us at infosec@fjdynamics.com. Please include the word “Türkiye” in the subject line of your email.
Pursuant to Article 11 of the DPL, you have statutory rights in relation to the personal information we hold about you. As a data subject in Türkiye, you have the right, to the extent permitted by applicable laws and regulations, to apply to the data controller to:
learn whether your personal data has been processed;
where your personal information is transferred abroad, we will rely on an adequacy decision, standard contract or binding corporate rules and make any legally required filing with the Turkish Personal Data Protection Authority, or rely on an applicable statutory exception;
request information regarding the processing if your personal data has been processed;
learn the purpose for which your personal data is processed;
learn the domestic or foreign third parties to whom personal data is disclosed;
request correction of incomplete or inaccurate personal data;
request deletion or destruction of personal data under the conditions set out in Article 7 of the Turkish Personal Data Protection Law; and
object to automated processing of data and seek certain remedies under the Turkish Personal Data Protection Law.
United Arab Emirates
You consent to the collection, use, disclosure, export and storage of your personal information in accordance with this Privacy Policy, including, without limitation, for the purpose of displaying personalized advertisements to you while you use the services.
We may voluntarily report cybersecurity incidents that constitute offences under UAE law (for example, under the UAE Cybercrime Law). We may report such incidents to the relevant authorities for investigation. Please also note that we may voluntarily report cybersecurity incidents to the UAE Computer Emergency Response Team (“CERT”). CERT is a security-awareness organization that provides a process for recording incidents and guidance regarding known cybersecurity threats in the UAE.
Children
For users located in the United Arab Emirates, in relation to data processing we comply with the UAE Federal Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and the Child Digital Safety Law effective January 1, 2026. Before processing personal information of a child under 18 years of age, we will obtain the consent of the child’s guardian (calculated according to the Hijri calendar). However, minors between 18 and 21 years of age may obtain a court order permitting them to engage in specific commercial transactions. In addition, minors over the age of 7 may engage in commercial transactions with the approval of their guardian.
South Korea
Children under 14 years of age may use the Website (regardless of the purpose of use) only after a parent/guardian has consented to this Privacy Policy on their own behalf and on behalf of the child. Without such consent, we will not knowingly collect any personal information from a child under 14. If you believe we hold personal information of a child under 14 without parental/guardian consent, please contact us and we will promptly investigate (and delete) such personal information.
Where personal information relating to South Korean users is transferred internationally in connection with the Website, we will provide any information and choices required under applicable law.
Mandatory Retention Periods for Personal Information under South Korean Law:
| Item | Applicable Law/Regulation | Retention Period |
|---|---|---|
| Records concerning execution and termination of contracts | Act on the Consumer Protection in Electronic Commerce | 5 years |
| Records concerning payment and other supply of funds | Act on the Consumer Protection in Electronic Commerce | 5 years |
| Records concerning consumer complaints and dispute resolution | Act on the Consumer Protection in Electronic Commerce | 3 years |
| Records concerning labeling/advertising | Act on the Consumer Protection in Electronic Commerce | 6 months |
| Service access logs | Protection of Communications Secrets Act | 3 months |
| Telecommunications logs | Protection of Communications Secrets Act | 12 months |
Destruction of Personal Information
We destroy personal information when the need for it ceases to exist (for example, when the retention period expires and the purpose of processing has been achieved), except where laws or regulations require us to retain such personal information.
The procedures for destroying personal information are as follows:
Destruction procedure: We destroy personal information that is required to be destroyed in accordance with our data deletion and retention protocols and other applicable procedures.
Destruction method: We destroy personal information recorded and stored electronically using methods such as low-level formatting to ensure that it cannot be reproduced; and we destroy personal information recorded and stored in hard copy by shredding or incineration.
You may contact us at infosec@fjdynamics.com. Please include the word “South Korea” in the subject line of your email.