Privacy Policy

BRUSHO COMPANY LIMITED (hereinafter referred to as “we” or “the Company”) respects your privacy and is committed to protecting your personal information. This Privacy Policy details how we safeguard your personal information, including its collection and processing when you access our platform, regardless of your location.

We collect, compile, and disclose users' personal information solely under the terms and conditions of this Privacy Policy. By clicking “Agree,” you consent to access and use the [https://brusho.com] under the terms of this Privacy Policy.

Contact Information

Our contact details are as follows:

Legal Entity Name: BRUSHO COMPANY LIMITED

Registered Address: RM 1427, 14/F RADIO CITY 505, HENNESSY RD CAUSEWAY BAY, HONG KONG

Dedicated Email Address: customerservice@brusho.com

Personal Information Collected from You

Personal information refers to any information that can specifically identify an individual's personal identity. Personal information also includes user information that can be identified through organizations, institutions, or other collectives, whether or not this information alone can identify the user's personal identity.

We collect, use, store, and transfer your email address to provide necessary services. The personal information you provide to us is either legally required, necessary to provide the requested services, or related to certain specific purposes, which will be further described below.

We do not collect any special categories of personal information (including data about your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, etc.). We also do not collect any information regarding criminal convictions and offenses.

If we are required by law or under our agreement with you to collect personal information, such as your email address, and you fail to provide the information as required, we may be unable to perform the contract we have or are trying to enter into with you (for example, to provide goods or services to you). In such cases, we may have to cancel your contract for products or services with us, but we will notify you immediately.

Purposes of Collecting Personal Information

We collect and process user personal information for the following purposes, and only the personal information necessary for our business operations is collected:

Creating, managing, and maintaining our contractual relationship with users: When users engage in transactions or use services, we use your personal information to receive and process orders, handle payments, and enhance security.

Ensuring compliance with laws and regulations: Many of our services are subject to strict and specific legal regulations. Local laws and regulations require us to collect, use, and store certain personal data and process personal identification information to comply with applicable laws and regulations.

User communication and recommendations: We communicate with users by sending promotional emails, updating transaction information, and recommending features and services that may be of interest. Without such communication, you may miss important updates relevant to your use of our services. We collect and process your personal information to provide services, process your orders, facilitate transactions, support user requests, and resolve disputes or complaints.

Enhancing the security, reliability, and integrity of the [https://brusho.com] and its services: We collect and process your personal information to enhance service security, combat malware or security risks, and comply with applicable security laws and regulations.

Improving our services and conducting research and innovation: We collect and process personal information to improve our services and provide a better user experience. We also use your information to support technological development and drive innovation in our services and products.

Use of Cookies and similar technologies: Where required by applicable law, we will use Cookies and similar technologies based on your consent to process personal information from Cookies in our services. You can withdraw your consent at any time, and we will cease processing your personal information for that purpose.

Changes to the Purposes of Collecting Personal Information

We will only use your personal information for the purposes outlined above, unless we reasonably believe that there is a need to use it for another purpose consistent with the original intent.

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

In situations where it is required or permitted by law, or mandated by government policies, we may process your personal information without your knowledge or consent.

Transfer and Disclosure of Personal Information

Personal information may be transferred and disclosed under the following circumstances, but not limited to:

As a principle, personal information collected and generated globally based on users' use of products or services is stored within [Singapore]. You hereby understand and agree that due to the global nature of the [https://brusho.com] and the cross-border design of certain products or services, we may need to provide personal information to jurisdictions outside of the user's country/region or such information may be accessed by those jurisdictions. We will comply with applicable laws and regulations and ensure your personal information is secure, maintaining standards consistent with relevant laws and this Privacy Policy. If you disagree with the cross-border transfer of your data, some [https://brusho.com] products or services based on cross-border design may not be available.

We may also transfer and disclose your personal information actively or passively in the following circumstances, among others: compliance with laws, regulations, legal processes, litigation, or mandatory government requests; to restrict services or transactions in response to fraud, abnormal operations, cheating, or security risks; to address public health emergencies or emergencies necessary to protect natural persons' life, health, and property safety; to conduct news reporting, public opinion monitoring, etc., within reasonable bounds. We assume no responsibility for any disclosures resulting from the above reasons.

Data Security

We collect, use, store, and transfer user information under the principle of “minimization” and notify you of the purpose and scope of information use through corresponding user agreements and privacy policies for each product and service.

We are committed to building a professional data security management team, advised by legal professionals, including a data compliance officer and other staff members.

We regularly engage legal professionals with expertise and longstanding cooperation with us to conduct data compliance training for all employees, ensuring all staff understand and strictly implement privacy protection measures.

However, please understand that due to technical limitations, the rapid development of the internet industry, and the potential for various malicious attacks, we cannot guarantee 100% security of information at all times. Please be aware that the systems and communication networks you use while accessing [https://brusho.com] products or services may experience security issues beyond our control.

Personal information leakage, alteration, destruction, or loss is classified as a security incident. Should such an incident occur, we will promptly assemble a response team to investigate the cause and minimize losses as quickly as possible.

Management and Maintenance of Personal Information

We ensure that personal information is accurate and retained for a duration that complies with applicable laws and regulations within each jurisdiction and does not exceed the time necessary to fulfill required purposes. Email addresses used for contact and marketing purposes will be retained until you fully terminate your use of our services. Information collected through cookies, web beacons, and other analytical tools will be retained for up to one year from the date of collection.

When personal information is no longer needed for operational purposes, we will take all feasible steps to delete it promptly, unless prohibited by law or if deletion is contrary to the public interest.

Simultaneously, we adopt technical and organizational measures to continually implement necessary precautions to protect personal information from unauthorized access, loss, destruction, alteration, or disclosure. We endeavor to provide regular training for employees on controlling and maintaining personal information. Additionally, we strictly adhere to all laws, regulations, rules, industry ethics, and public morals regarding personal information protection.

Rights to Access, Modify, Delete, and Other Personal Information Rights

You have several rights concerning privacy and personal information protection, as described below:

Right to Access: Users have the right to access and query their personal information on the  [https://brusho.com].

Right to Modify: After successfully using [https://brusho.com] (Pending Entity Name) services, users have the right to modify personal information in the corresponding functional areas, such as their email address.

Right to Delete: In certain circumstances, you may terminate our services, transactions, and delete personal information entirely. However, we may still retain your personal information to fulfill legal obligations, with the retention period determined by applicable law or as necessary to exercise our rights in future disputes or claims. After the mandatory retention period required by applicable law expires, your personal information will be deleted. Please note that terminating our services does not exempt you from any actions or responsibilities related to your account before the termination.

Right to Object: Users have the right to object to our processing of their personal data. You have the right to temporarily restrict the processing of your data when you have legitimate reasons. In cases of legal claims or exceptions required by law, we may continue processing your personal data.

Right to Restrict Processing: In certain situations, you have the right to temporarily restrict the processing of your personal data, provided there is a legitimate reason. Exceptions may apply for defending legal claims or as permitted by applicable law.

Right to Challenge Automated Decisions: You have the right to challenge decisions made solely through automated processing without human intervention. We use automated tools to ensure you are eligible to be our customer while considering our interests and legal obligations. If these tools indicate you do not meet our standards, we will not accept you as a customer.

Right to Data Portability: In some circumstances, you can request to receive your personal data, provided to us, in a structured, commonly used, and machine-readable format, or, where feasible, we will transfer your data directly to another data controller on your behalf.

Right to Withdraw Consent: For processing that requires your consent, you have the right to withdraw your consent at any time. Exercising this right will not affect the legality of the processing based on consent before its withdrawal.

Right to Lodge a Complaint with Relevant Data Protection Authorities: While we aim to address any concerns you may have regarding how we process your personal data, you have the right to lodge a complaint with the data protection authority in your place of residence, workplace, or the location where you believe a data protection violation has occurred.

These rights may be subject to limitations in certain cases, such as when we can demonstrate that we have a legal obligation or must comply with government authority requests to process your personal information.

Force Majeure and Other Uncontrollable Circumstances

Please understand and agree that [https://brusho.com] products and services involve internet and mobile communications, which may be affected by unstable factors at various stages. Therefore, we are not liable for any losses arising from unauthorized access, unavailability, modification, loss, destruction, alteration, or leakage of user data due to force majeure (such as earthquakes, typhoons, floods, fires, government actions, wars, pandemics, etc.), computer viruses, hacking, system instability, user location, user shutdown, GSM networks, internet networks, communication lines, or other reasons beyond our control. We will promptly notify users through email or other means and take reasonable and proactive technical measures to minimize any negative impact on users.

Cookies

We use cookies to recognize your identity when you visit the [https://brusho.com] and to create demographic profiles. Cookies are small pieces of information sent by web servers to web browsers, enabling the server to collect information from the browser.

You can set your browser to refuse all or some cookies or to alert you when cookies are being installed or accessed. If you disable or refuse cookies, certain parts of the [https://brusho.com] may be inaccessible or not function properly.

Language

This Privacy Policy may be published in multiple languages. In case of any discrepancies, the English version shall prevail.

Children's Privacy

We do not permit individuals under the age of 18 to use [https://brusho.com] services, nor do we knowingly collect information from individuals under 18.

If a user suspected to be under 18 submits personal information, we will require the user to terminate their use of our services and take measures to delete their information promptly.

Unsubscribing from Services

You may request us to stop sending promotional emails, transaction updates, and recommendations of features and services that may interest you at any time by emailing us at customerservice@brusho.com. If you choose not to receive these communications, unsubscribing will not fall within the scope of personal information provided to us due to purchasing products/services or other transactions.

Notices and Amendments to the Privacy Policy

If you have any concerns regarding our Privacy Policy, please email us at customerservice@brusho.com to contact our data compliance officer and data security management team, and we will do our best to address your concerns.

We periodically review and revise this Privacy Policy to enhance its content. Whenever we amend this Policy, [https://brusho.com] will notify users via their registered email addresses, ensuring that anyone can access and understand the latest Privacy Policy text. The top of the document will display the update date of each version. The revised Privacy Policy will automatically take effect 24 hours after the update date. If users continue to use the products or services of [https://brusho.com], it signifies your agreement to be bound by the revised Privacy Policy.