We recognise the importance of protecting personal data. This Privacy Policy explains how personal data is handled in connection with Card Manager (the App), testing programmes, support communications, external services, and our legal information website.
Card Manager is provided by its developer (the Developer, we, us, or our). Our Personal Information Collection Statement (PICS) gives additional information when we collect personal data directly from you.
1. Scope#
This Policy applies to personal data handled by us when you use the App, participate in a testing programme, communicate with us, or visit our legal information website. It does not govern information processed independently by a platform, external service, or website under that provider's own terms and privacy notice.
2. Information kept on your device#
The App processes information you choose to record, including financial and organisational records, imports, preferences, notes, reminders, and related information. It may create calculations, histories, notification schedules, backups, and exports from that information.
App content is ordinarily kept on your device. We do not operate an app account, cloud-synchronisation service, or remote database that receives that content. Information leaves the App only when you choose an external feature, export, back up, share, or deliberately include it in feedback or another communication.
You should not enter full payment-card numbers, security codes, banking credentials, one-time passwords, Hong Kong identity card information, or other secrets that the App does not require.
3. Information we may receive#
Depending on how you interact with us, we may receive:
- contact, invitation, and participation information used to administer a testing programme;
- app, build, device, operating-system, language, session, usage, crash, diagnostic, and feedback information made available through a platform or distribution provider;
- contact details, messages, attachments, and technical information that you submit when requesting support or making another enquiry;
- limited request and technical information processed when you choose an App feature supplied through an external service; and
- ordinary request, device, usage, and security information processed by providers that host, deliver, or protect our legal information website.
Please provide only information reasonably necessary for the relevant purpose and remove financial details, credentials, identity documents, or other sensitive material that is not required.
4. How we use information#
We may use personal data to:
- administer testing participation and communicate with testers;
- provide support and respond to enquiries or requests;
- investigate faults, security concerns, misuse, and service performance;
- operate, protect, maintain, and improve the App and related documentation;
- maintain appropriate operational, security, dispute, and legal records; and
- comply with applicable law, lawful requests, or the establishment, exercise, or defence of legal rights.
We do not sell personal data or use or provide it for direct marketing. Before introducing direct marketing, we would provide the information and obtain the consent required by Hong Kong law.
5. Disclosure and service providers#
Where reasonably necessary for the purposes above, personal data may be disclosed to:
- platform and distribution providers involved in making the App or a testing programme available;
- hosting, infrastructure, communications, technical, support, security, and external-information service providers involved in operating or protecting the App and related services;
- professional advisers and persons assisting with a support, diagnostic, security, technical, or legal matter under appropriate duties or confidentiality arrangements;
- a person who lawfully succeeds to responsibility for the App and uses the information for compatible purposes; and
- courts, regulators, law-enforcement bodies, public authorities, or other persons where disclosure is required or permitted by law.
A provider may process information on our behalf or independently under its own terms. We do not authorise a provider acting on our behalf to use that information for unrelated advertising or marketing.
6. Processing outside Hong Kong#
Personal data may be processed or stored outside Hong Kong by external providers. Laws and protections differ between jurisdictions. Where we arrange processing on our behalf, we will take reasonably practicable steps appropriate to the circumstances to protect the information consistently with this Policy and applicable Hong Kong law.
7. Retention#
Information kept in the App remains under your control until you edit or delete it, reset or remove the App, or manage any separate device backup. Exports and backups you place elsewhere remain under your control.
We retain personal data received through testing, support, or other communications only for as long as reasonably necessary for the relevant purpose, security, dispute management, or legal obligations. We then delete or de-identify it where reasonably practicable. Independent providers apply their own retention practices to information they control.
8. Security#
The App uses device and platform protections and provides controls intended to help protect local information. We apply reasonable administrative and technical safeguards to personal data we receive. No device, storage method, transmission, or service is completely secure. You remain responsible for device access controls and for protecting exports and backups.
9. Your rights and choices#
Subject to the Personal Data (Privacy) Ordinance (Cap. 486) (PDPO), you may request access to personal data we hold about you, ask us to correct inaccurate data, and request information about our personal-data policies and the kinds of data we hold. We may verify your identity and charge a fee where permitted by law. We will respond within the legally required period, ordinarily no later than 40 calendar days after receiving a valid request, subject to lawful exceptions.
Most App content is available only on your device. You may manage it in the App, perform a local reset, or remove the App, but must separately manage exports and backups. You may decline optional feedback or support information and stop participating in a testing programme through the relevant provider.
10. Children and young people#
The App is not intended for children under 13. A user under 18 should use it only with the agreement and involvement of a parent or legal guardian. If we learn that a child has provided personal data in circumstances that do not meet applicable requirements, we will take reasonable steps to address it.
11. External services and policy changes#
External services and websites are governed by their own privacy practices. We are not responsible for information they process independently.
We may update this Policy to reflect changes to the App, our practices, or legal requirements. We will identify the current version, effective date, and a concise change summary. Where renewed notice is required, the App will identify the changed document before normal use continues. Changes will not apply retroactively unless required by law.
12. Contact#
For data access, correction, privacy, or support requests, contact the Developer at cardmanager@fishneko.com.