Scope of this notice
Please read this privacy notice (“Notice”) carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Notice applies to individuals who interact with Proofn services as consumers (“you”). This Notice explains how your Personal Data is collected, used, and disclosed by Proofn Limited (“Proofn”, “We”, "Us”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data is used.
This Notice covers both our online and offline data collection activities, including Personal Data that we collect through our various channels such as websites, apps, third party social networks, Customer Service, and events. Please note that we might aggregate personal data from different sources (website, offline event) and across different devices. As part of this, we combine Personal Data that were originally collected by different Proofn partners. Please see Section 8 for further information on how to object to this.
If you do not provide necessary Personal Data to us (we will indicate to you when this is the case, for example, by making this information clear in our registration forms), we will not be able to provide you with our services. This Notice can change from time to time (see Section 9).
This Notice provides important information in the following areas:
Section 1-Sources of personal data
Section 2-Personal data that we collect about you and how we collect it
Section 3-Personal data of children
Section 4-Log files
Section 5-Disclosure of your personal data
Section 6-Retention of personal data
Section 7-Storage and/or transfer of your personal data
Section 8-Your rights
Section 9-Changes to our notice
Section 10-Data controllers & contact
1. Sources of personal data
This Notice applies to Personal Data that we collect from or about you, through the methods described below (see Section 2), from the following sources:
Proofn websites. Consumer-directed websites operated by or for Proofn, including sites that we operate under our own domains/URLs and mini-sites that we run on third party social networks such as Facebook (“Websites”).
Proofn mobile sites/apps. Consumer-directed mobile sites or applications operated by or for Proofn, such as smartphone apps.
E-mail, text and other electronic messages. Interactions with electronic communications between you and Proofn.
Proofn Customer Service. Communications with our Customer Service.
Advertising interactions. Interactions with our advertisements (e.g., if you interact with on one of our ads on a third-party website, we will receive information about that interaction).
Data we create. In the course of our interactions with you, we will create Personal Data about you (e.g. records of your purchases or purchase of subscription from our websites).
Data from other sources. Third party social networks (e.g. such as Facebook, Google, Instagram, Pinterest) third party social media (e.g. Twitter, Medium, TikTok), market research (if feedback not provided on an anonymous basis), third party data aggregators, Proofn promotional partners, public sources and data received when we acquire other companies
2. Personal data that we collect about you and how we collect it Depending on how you interact with Proofn (online, offline, over the phone, etc.), we collect
various types of information from you, as described below.
Device Information. We collect information about your device, including the hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), browser type and language, email type, mobile device phone number, and mobile network information. We also collect certain device information that will help us diagnose problems in the (hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we detect a crash or other problematic event, we will collect the list of apps on your device and other information about your device’s performance at the time of the event for troubleshooting purposes.
Device Phonebook and Email Account. Because Proofn is all about communicating with friends, family, and colleagues, in order to access and use the features of the Service, you acknowledge and agree that you will have to provide Proofn with your full name, and email address for a Free Plan and with your credit card payment information for a Silver Plan and Gold Plan Account. You expressly acknowledge and agree that in order to provide the Services,
Proofn will periodically access your contact list and phone and email address book on your mobile device to find and keep track of mobile phone numbers and email addresses of other users of the Service. When providing your mobile phone number or email address, you must provide accurate and complete information. We do not collect physical addresses. You must notify Proofn immediately of any breach of security or unauthorized use of your mobile phone and/or mobile device. Although Proofn will not be liable for your losses caused by any unauthorized use of your account, you will be liable for the losses and damages of Proofn or third parties due to such unauthorized use.
Location Information. With your consent, we collect your device location so that you can use our location-based features including Proofn scheduling, and for any other purpose described in this privacy policy. As with your phonebook, email accounts and photos, you can always revoke your consent by changing the settings or preferences on your device. If you do so, certain features of the Services will no longer function.
Account login information. Any information that is required to give you access to your specific account profile. Examples include your email handle ID/email address from Proofn, password in unrecoverable form, and/or security question and answer.
Demographic information & interests. Any information that describes your demographic or behavioral characteristics to help Proofn improve our services. Examples include your date of birth, age or age range, gender, geographic location (e.g. postcode/zip code), favorite products, hobbies and interests, and household or lifestyle information
Information from computer/mobile device. Any information about the computer system or other technological device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Proofn website or app via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data.
Websites/communication usage information. We collect information about your activity and the email you send and receive through our Services. This includes information such as the time, date, sender, recipient of a email, the number of email you exchange with your friends, which friends you exchange email with the most, how often you edit what you sent to recipients on Proofn, and your interactions with email (such as when you open an email or capture a screenshot). As you navigate through and interact with our Websites, we use automatic data collection technologies to collect certain information
about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected
through the use of third-party tracking for analytics and advertising purposes.
Market research & consumer feedback. Any information that you voluntarily share with Us about your experience of using our products and services.
Consumer-generated content. Any content that you create and then share with Us on third party social networks or by uploading it to one of our Websites or apps, including the use of third-party social network apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, we collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third-party social networking.
Third party social network information. Any information that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Facebook) and that you allow the third-party social network to share with Us. Examples include your basic account information (e.g. name, email address, birthday, current city, profile picture, email handle, list of friends, etc.) and any other additional information or activities that you permit the third-party social network to share. We receive your third party social network profile information (or parts of it) every time you download or interact with a Proofn web application on a third party social network such as Facebook, every time you use a social networking feature that is integrated within a Proofn site (such as Facebook Connect) or every time you interact with Us through a third party social network. To learn more about how your information from a third-party social network is obtained by Proofn, or to opt-out of sharing such social network information, please visit the website of the relevant third-party social network.
Payment and Financial information. Any information that we need in order to fulfill an order, or that you use to make a purchase or purchase a subscription, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). In any case, we or our payment processing provider(s) handle payment and financial information in a manner compliant with applicable laws, regulations and security standards such as PCI DSS.
Calls to Customer Services. Communications with a Customer Services can be recorded or listened into, in accordance with applicable laws, for local operational needs (e.g. for quality or training purposes). Payment card details are not recorded. Where required by law, you will be informed about such recording at the beginning of your call.
Sensitive Personal Data. We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on your prior express consent for any processing which is voluntary (e.g. for marketing purposes). If we process your sensitive personal data for other
purposes, we rely on the following legal bases: (i) detection and prevention of crime (including the prevention of fraud); and (ii) compliance with applicable law (e.g. to comply with our diversity reporting).
3. Personal data of children
We do not knowingly solicit or collect personal data from children below the age of 17. If we discover that we have unintentionally collected personal data from a child below 17, we will remove that child’s personal data from our records promptly. However, Proofn will collect personal data about children below the age of 17 years of age from the parent or guardian directly, and with that person’s explicit consent.
4. Log files
We collect information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help Us to troubleshoot errors, improve performance and maintain the security of our Websites.
5. Disclosure of your personal data
We share your Personal Data with the following types of third-party organizations:
•Other recipients on Proofn. When you send an email to other email addresses on Proofn (yourname@proofn.com), your recipients will see your name and, of course, whatever your email says or shows (whether that’s a photo, video, text or document attachment.)
•When you view other emails from Proofn email addresses the sender, can edit, delete or remove content and attachments at any time without providing notification to you of the changes the sender made.
•When you send a non-Proofn email, your recipients will see your name and Of course, whatever your email says or shows (whether that’s a photo, video, text or document attachment.)
•When your recipients view your email, the sender, cannot edit, delete or remove content and attachments. We will let the sender know whether the recipient(s) opened your email or not, and if we detect that you captured a screenshot of the email, we will try to let the sender know that. If you ever want to change your payment information, you may do so in the “Settings” tab.
•When you let us access your mobile phone device, we will share information about you with other users who have your phone number in their device phonebook.
•When you let us access your mobile device’s email account, we will share information about you with other users who have your email in their email account.
•When other users view your profile, they will be able to view profile information, including your full name, profile photos. When you send email along with attachments and make retroactive changes to your original email and any attachments before your recipient to other email addresses on Proofn (yourname@proofn.com), it is important for you to understand that users who see your email can always save them, either by taking a screenshot or by using some other image-capture technology (whether that be software or even something as old-fashioned as a camera to take a photo of your device’s screen). If we’re able to detect that a recipient took a screenshot of an email you sent, we’ll try to notify you. But the same common sense that applies to the Internet at large applies to Proofn as well: Don’t send email that you wouldn’t want someone to share with others. Do not write something that you will later regret writing. Always assume an unknown third party will read your email without your knowledge or permission.
A few final words on editing, deletion and removals on emails sent to anyone with an email address on Proofn. We can’t guarantee that email will be deleted, or attachments removed within a specific timeframe. And even after we’ve deleted email data or attachments from our servers, that same data or attachment will remain in backup for a limited period of time. We also sometimes receive requests from law enforcement requiring us by law to suspend our ordinary
server-deletion practices for specific information. Finally, of course, as with any digital information, there will be ways to access email while still in temporary storage on recipients’ devices or, forensically, even after they are deleted.
Service providers. These are external companies that we use to help Us run our business (e.g. order fulfillment, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, website development, data analysis, CRC, etc.). Service providers, and their selected staff, are only allowed to access and use your Personal Data on Our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure. Where required by applicable law, you can obtain a list of the providers processing your Personal Data (see Section 10 to About Us). Among the third parties we use for analytics is Google Analytics, which provides mobile analytics in connection with our app. Additionally, some companies will use the information they collect on our blog and other websites to deliver targeted advertisements on behalf of us or other companies, including on third-party websites and apps. Proofn does not currently respond to do-not-track signals that will be sent from your device. If we do so in the future, we will provide information about that practice in an updated version of this privacy policy.
Third party recipients using Personal Data for legal reasons or due to merger/acquisition.
We will disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger.
6. Retention of personal data
Proofn takes every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the retention period for your Personal Data is:
(a) Proofn will retain copies of your Personal Data in a form that allows for identification only for as long as:
(i) We maintain an ongoing relationship with you (e.g. where you have a Free Plan, Silver Plan or Gold Plan );
(ii) Your Personal Data is necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis, Plus
(b) The duration of: (i) any applicable limitation period (i.e. any period during which a person could bring a legal claim against us), and (ii) an additional 2 months following the end of the applicable limitation period (so we are able to identify any personal data of a person who will bring a claim at the end of the applicable period),
And
(c) In addition, if any relevant legal claims are brought, we will continue to process your Personal Data for such additional time necessary in connection with that claim.
During the periods noted in paragraphs b(i) and b(ii) above, we will restrict our processing of your Personal Data to storage or, and maintaining the security of, those data, except to the extent the data need to be reviewed in connection with any claim, or any obligation under applicable law.
Once the periods in paragraphs (a), (b) and (c) above, each to the extent applicable, have concluded, we will either (i) permanently delete or destroy the relevant Personal Data or (ii) anonymize the relevant Personal Data.
7. Storage and/or transfer of your personal data
We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.
People who can access your Personal Data. Your Personal Data will be processed by our authorized staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected (e.g. our staff in charge of consumer care matters will have access to your consumer record).
Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorized access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although we will do our best to protect your Personal Data, we cannot guarantee the security of the data during transmission through our Websites/apps.
Measures we expect you to take. It is important that you also play a role in keeping your Personal Data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls we provide you in our Website/app.
Transfer of your Personal Data.
The Services are hosted in the Hong Kong Special Administrative Region. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from Hong Kong Special Administrative Region laws, please be advised that through your continued use of the Services, which are governed by Hong Kong Special Administrative Region law, you are transferring your personal information to the Hong Kong Special Administrative Region and you consent to that transfer.
8. Your rights
Under the GDPR, if you are an EU citizen you have the right:
•to access your personal data
•to be provided with information about how your personal data is processed
•to have your personal data corrected
•to have your personal data erased in certain circumstances
•to object to or restrict how your personal data is processed
•to receive a copy of your data in a machine-readable format
•to take any complaints about how we process your data to the Data Protection Authority in your country.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
9. Changes to our notice
If we change the way we handle your Personal Data, we will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.
10. Data controllers & contact
To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please write to us at
Proofn Limited
Rm. 2101, Hong Kong Trade Centre,
161-7 Des Voeux Road Central, Hong Kong or via email at
joel@proofn.com.
We will acknowledge and investigate any complaint about the way we manage Personal Data (including a complaint that we have breached your rights under applicable privacy laws).