Privacy Policy

Collection of Personal Data
Sensitive or Special Categories of Personal Data
Purpose of Processing Personal Data
Sharing and Disclosure
International Transfers
Storage and Retention of Personal Data
Security of Personal Data
Access and Correction of Personal Data
Third Parties and Integrations
Use of Cookies
Children’s Privacy
Amendment
Contact

Last updated: November 21^st, 2022

TECHDesign platform (TECHDesign.com) and its related functions, features, and services (collectively, “TECHDesign Services”) are operated by Callisto Holding Limited (“Callisto” “we” or “us”) under the TECHDesign® brand name.

We respect the privacy of every individual whose personal data we handle, and this Privacy Policy will help you understand what data we collect, why we collect and how we protect your personal data. For the purpose of applicable data protection laws, Callisto Holding Limited, with registered address at Unit 9-11, 22/F, Millennium City 2, 378 Kwun Tong Road, Kowloon, Hong Kong, is the data controller responsible for your personal data.

This Privacy Policy applies to all websites or digital applications that refer to or link to this Privacy Policy. By using TECHDesign Services, you are consenting to the practices described in this Privacy Policy.

1. Collection of Personal Data

“Personal data” means any personal data which on its own or combined with other information relates to and identifies, whether directly or indirectly, a living individual.

There are three basic categories of personal data that we collect:

1.1. Information You Give to Us
We ask for and collect information, including personal data, about you when you use TECHDesign Services. This information is necessary for us to carry out adequate performance and services to you as a platform service provider.
You may be required to provide personal data such as your name, address, email address, phone number or other contact information by registering a TECHDesign Services account. This information is required to use certain TECHDesign Services’ functions and services, to get access to or locate information on suppliers, relevant members on TECHDesign Services, products, and services. In addition to the personal data set out above, you may be required to provide your street address to purchase products and/or services, or to seek assistance and receive customer services at TECHDesign Services. We may also require you to provide certain financial information (such as your bank account or credit card information), in order to facilitate the processing of payments or refund.
In the case where you choose not to provide certain information, we may not be able to provide you with the requested products, functions, or services.
1.2. Information Collected from Your Use of TECHDesign Services
When you use TECHDesign Services, we may collect information, including personal data, by automated means such as cookies and web beacons. For the use of cookies and similar technologies, please refer to our Cookie Notice.
The personal data that we collect in this manner includes data points such as Internet Protocol (IP) address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on TECHDesign Services, and dates and times of TECHDesign Services visits.
1.3. Information We Collect from Third Parties
We may collect information, including personal data, about you from publicly and/or commercially available sources as permitted by law, which we may combine with other information we collect through TECHDesign Services from or about you. We do not control, supervise, or administer how the third parties providing your information collect, process, or use your personal data. For personal data on how the third parties collect and process personal data about you and information on how to opt out of the third parties’ collection of personal data from you, please refer to the third parties’ own privacy policy.
The third parties from whom we collect information, including personal data, and our purpose for collecting such information from them are:
- Communication services and social media tools such as Freshdesk, LinkedIn, Google and Facebook in order to understand, facilitate, and validate your requests;
- Analytics tools such as Google Analytics and Mixpanel in order to understand and analyze user behaviors, improve TECHDesign Services design and services, and optimize user experience;
- Anti-bot service such as hCaptcha in order to check whether data entered on our website has been entered by a human or by an automated program, which helps enhance the security of our website.

2. Sensitive or Special Categories of Personal Data

Different rules apply to the process of personal data concerning race, ethnic origin, political opinions or beliefs, religious or other beliefs, trade union memberships, physical or mental health, sexual life or orientation and any offences committed. We do not require or collect such sensitive or special categories of personal data.

3. Purpose of Processing Personal Data

We will only use your personal data where we are permitted to do so by applicable law. Under the EU data protection laws, the use of personal data must be justified under one of several legal grounds. The principal legal grounds that justify our use of your personal data are:

Contract Performance: The use of your personal data may be necessary to enter or perform our contract with you for TECHDesign Services, our terms and conditions, and/or other policies under which we provide TECHDesign Services.
Consent: We will rely on your consent to use (i) technical information such as cookie data and geolocation data; and (ii) your personal data for marketing purposes. You may withdraw your consent at any time by contacting us using the information at Section 13 of this Privacy Policy or by clicking an unsubscribe link in any marketing communication you receive from us.
Legitimate Interests: We may use your personal data to achieve a legitimate interest. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms.
Legal Obligations: We may use your personal data if such information is necessary for us to comply with our legal obligations.
Legal Claims: We may use your personal data if such information is necessary for us to defend, prosecute or make a claim against us, you or a third party.

In accordance with the legal grounds stipulated above, we may use your personal data in the following ways:

3.1. To Provide, Improve, and Develop TECHDesign Services
- Enable you to access and use TECHDesign Services;
- Enable you to interact and communicate with Callisto, suppliers, members on TECHDesign Services, and other ecosystem members on or through TECHDesign Services;
- Inform you with services or support messages, updates, security alerts, or account notifications;
- Operate, protect, improve, optimize, or customize TECHDesign Services and user experience, by performing analytics and research;
- Provide customer service, respond to your enquiries, facilitate payment, refund, and logistics, deliver the products or services you requested, and provide after-sales services; and
- Maintain and continuously upgrade the quality of TECHDesign Services and affiliated services.
- Relevant Legal Ground: Contract Performance, Legitimate Interests and Consent
3.2. To Provide, Personalize, Measure and Optimize our Advertising and Marketing
- Provide marketing or advertising for related products or services that may be of your interest based on your activity and purchases on our platform and/or the products that you leave in your cart when you do not finish a transaction;
- Personalize, measure, and improve our advertising; and
- Administer referral programs, rewards, discounts, surveys, coupons, or other promotional activities or events sponsored or managed by Callisto or third parties.
- Relevant Legal Ground: Legitimate Interests and Consent
3.3. Create and Foster a Trusted and Safer Platform Environment for Users, and Safeguard TECHDesign Services and Your Information
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activities;
- Verify or authenticate information or identifications provided by you;
- Conduct checks against databases and other due diligence sources, in order to maintain reasonable qualities of project leads and supplier fulfillment, or to ensure security and risk management;
- Comply with and fulfill our legal obligations to TECHDesign Services users;
- Stop unauthorized access to TECHDesign Services and distribution of malicious virus, malware, or software program; and
- Prevent denial of service attacks and damage to TECHDesign Services.
- Relevant Legal Ground: Legitimate Interests, Legal Obligation and Consent (collectively, the “Purposes”).

4. Sharing and Disclosure

To offer our products and services, identify your preference, improve our services, and manage TECHDesign Services, we may share your personal data with the following entities:

4.1. Suppliers and Other Members on TECHDesign Services
In order to help facilitate your product or service requests and fulfillment, including but not limited to providing reference design and solutions, delivering goods, verifying payment, matching you with suitable suppliers, and connecting you with other members on TECHDesign Services, certain information, including your personal data, may be shared as necessary for the adequate performance of TECHDesign Services.
4.2. Third Party Service Providers
Callisto uses a variety of third party service providers to help us provide services related to TECHDesign Services. For example, service providers may help us: (i) facilitate the communications between Callisto and our users, (ii) verify or authenticate your information and requests, (iii) check information against public databases, (iv) conduct fraud prevention and risk assessment, (v) perform product and service development, maintenance, delivery, and optimization, (vi) allow the provision of TECHDesign Services through third party platforms and software tools (e.g. through the integration with our APIs), or (vii) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf.

The third parties we use for the above-mentioned purposes to provide services related to TECHDesign Services are:
- Communication services and social media tools such as Freshdesk, LinkedIn, Google and Facebook in order to understand, facilitate, and validate your requests;
- Analytics tools such as Google Analytics and Mixpanel in order to understand and analyze user behaviors, improve TECHDesign Services design and services, and optimize user experience;
- Anti-bot service such as hCaptcha in order to check whether data entered on our website has been entered by a human or by an automated program, which helps enhance the security of our website.
- Carriers and logistics companies such as DHL, FedEx and SF Express in order to fulfill your order and product delivery.
4.3. Affiliates
Your personal data may be shared among Callisto’s affiliates that are related by common ownership, are controlled by Callisto or are controlling Callisto, for the Purposes described in Section 3 of this Privacy Policy.
4.4. Third Parties Permitted By Law
Callisto may also share your information in the circumstances where disclosure is legally permissible and necessary, and this includes, but is not limited to (1) preventing, investigating, or taking action against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our agreements, or as otherwise required by law; and (2) defending our legal rights, responding to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).
4.5. Business Transfers
If Callisto undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, insolvency, or other similar transactions or proceeding, we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you accordingly and before you become subject to a different privacy policy.

5. International Transfers

In order to effectively carry out our product delivery and service offering across our global network of suppliers and other member on TECHDesign Services, we may transfer personal data we collect from you or about you to countries other than the country in which the personal data originally was collected. Such other countries may not have the same data protection laws as the country in which you initially provided the personal data. Regardless of where the personal data is transferred to, when we transfer your personal data to other countries, we will impose the same data protection safeguards as described in this Privacy Policy to offer an adequate level of data protection.

Please contact us as directed under Section 13 below if you would like to see a copy of the specific safeguards applied to the export of your personal data.

6. Storage and Retention of Personal Data

All data collected is subject to our strict data security policies. Our computerized information is stored in secured facilities and access is restricted to authorized personnel.

We will not keep your personal data for longer than is necessary and we will only retain the personal data that is necessary to fulfill the purpose for which the data was collected any other permitted linked purpose. We are also required to retain certain information by law or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions. If your personal data is used for two purposes, we will retain it until the purpose with the longer period expires, but we will stop using it for the purpose with the shorter period once that shorter period expires.

7. Security of Personal Data

We are continuously implementing and updating appropriate technical and administrative measures to help protect your personal data against unauthorized access, loss, misuse, destruction, or alteration. Only authorized persons of Callisto are provided access to the personal data we collect from you, and such individuals have agreed and are obliged to keep such information confidential.

If you know or have a reason to believe that your TECHDesign Services account information has been lost, stolen, misappropriated, otherwise compromised, or in any actual or suspected unauthorized use, please contact us following the instructions in Section 13. We will then assess the likely impact of the incident and take the necessary actions to bring the incident under control. Where necessary, we will also report to the appropriate authority, notify you of the incident and provide relevant information.

8. Access and Correction of Personal Data

In relation to the personal data that we collect, use and process about you, you may exercise the following rights under applicable laws:

Access: You have the right to request a copy of the personal data we are processing about you.
Rectification: You have the right to rectify incomplete or inaccurate personal data about you.
Deletion: You have the right to request that we delete personal data that we do not have a legal basis to hold.
Restriction: You have the right to restrict us from processing your personal data if you think the data is inaccurate (until such data is corrected or confirmed to be correct) if the processing is unlawful, or if it is no longer necessary for us to process the data, subject to any legal or other obligation that we have that overrides your rights herein.
Data Portability: You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, provided that it is personal data that you provided to us and the processing is carried out by automated means or is based on your consent or for contract performance.
Right to Object: You have the right to object to our processing of your personal data where we are relying on a legitimate interest or to send you direct marketing materials.
Withdraw Consent: You have the right to withdraw your consent for us to process your personal data at any time.

However, we reserve the right not to take any of the above actions upon your request if the applicable law stipulates that we are entitled not to do so. Any exercise of your rights as listed above may result in your not being able to purchase or obtain products or services from Callisto. If you have any questions or wish to exercise the rights, please contact us following the instructions in Section 13 below.

If you are an individual located within the European Economic Area (“EAA”), you also have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the EEA.

Callisto reserves the right to charge a reasonable fee for processing any data access request.

9. Third Parties and Integrations

TECHDesign Services may integrate tools and services provided by a third party service providers, or contain links to third party websites or services (including suppliers, other members on TECHDesign Services and other third party service providers mentioned in Section 4.1 and 4.2), such as third party integrations, co-branded services, or third party-branded services (together “Third Parties”).

Callisto doesn’t own or control these Third Parties and when you interact with them, you may be providing information directly to the Third Parties, Callisto, or both. These Third Parties will have their own rules about the collection, use and disclosures of the information. We encourage you to review the privacy policies of these other websites you visit.

10. Use of Cookies

This website may send a cookie (a small text file) to your computer in order to facilitate your use of this website. If you do not wish to receive cookies, you may reset your Internet browser to block all cookies. You may also configure your Internet browser so that you receive a warning before a cookie is stored. For more information about how we implement cookies, please refer to our Cookie Notice.

The TECHDesign Services server automatically records information incidental to your use of this website, including but not limited to the name of the domain and host from which you access the Internet, the IP address of the computer you are using, the date and time you access this website, and the Internet address of the website from which you linked directly to this website. Callisto uses the aforementioned information to track aggregate traffic patterns throughout this website.

11. Children's Privacy

Callisto does not direct its services to individuals under the age of 18, nor do we knowingly collect any personal data from individuals under the age of 18. Individuals under the age of 18 are requested to NOT provide any personal data through TECHDesign Services. If you become aware that an individual under the age of 18 has provided us with personal data without parental consent, please contact us using the information at Section 13 of this Privacy Policy. If we become aware that an individual under 18 has provided us with personal data, we take commercially reasonable steps to remove such information from our systems.

12. Amendment

In order to reflect the updates on regulations or security technologies, we reserve the right to revise this Privacy Policy from time to time. We recommend you to check this page from time to time to inform yourself of any changes in this Privacy Policy or of any other policies.

13. Contact

If you have any questions or concerns regarding this Privacy Policy, please click here to contact us