Resolution of privacy queries and complaint mechanism
Accountability for onward transfers
We are responsible for the processing of Personal Data it receives, and subsequently transfers to a third party acting as an agent on its behalf.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the Hong Kong Government. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
1. MEMBER CONSENT
2. A NOTE ABOUT CHILDREN
We do not intentionally gather Personal Data about visitors who are under the age of 13. If we inadvertently hold or have access to Personal Data about anyone under 13, please let us know so we can delete it.
3. TYPES OF PERSONAL DATA WE COLLECT
Any Expense collects Personal Data from you when you visit our Site, when you send us information or communications in connection with your use of the Any Expense Service, and/or when you download and use the Any Expense app. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, geographic location of your computer or mobile device, telephone number and email address.
Personal Data You Provide To Us
We collect Personal Data from you, such as first and last name, email and mailing addresses, telephone number, company name, and password, when you register for the Any Expense Service. In addition, we will collect Personal Data when you upgrade to a paid account. We also retain information on your behalf, such as the Personal Data described above and any correspondence. If you provide us feedback or contact us via email, we will collect your name and email address, IP address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us, such as a resume. If we conduct a survey in which you participate, we may collect additional profile information. We may also collect Personal Data at other instances in the Site or Application user experience where we state that Personal Data is being collected.
When you provide us with Personal Data about your contacts we will only use this information for the specific reason for which it is provided.
If you believe that one of your contacts has provided us with your Personal Data and you would like to request that it be removed from our database, please contact us at email@example.com
Personal Data Collected by Third Parties
We may receive Personal Data about you from companies that distribute the Any Expense Service by way of a co-branded or private-labelled website, companies that offer their products and/or services via the Any Expense Service, or companies that provide services (such as payment processing services) in connection with the Any Expense Service (collectively, “Partner Companies”). Our Partner Companies may supply us with Personal Data, such as your name and email and mailing address information or your login credentials for such Partner Company’s website or service, in order to help us establish the account or fulfill orders. We may add this information to the information we have already collected from you via our website in order to perform and improve the Any Expense Service. If you provide us Personal Data about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Personal Data Collected via Technology
The Any Expense Service (which may be hosted by a third-party service provider) collects Personal Data from you, such as browser type, your approximate geographic location of your mobile device or computer (from your Internet Protocol (IP) address), operating system and version, Internet Protocol (IP) address, domain name, information about your application, operating environment and hardware profiles and/or a date/time stamp for your visit. We may also use Identifiers (as defined below) and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and/or access to the Any Expense Service and your activity on the Site and the Application. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit the Site, use the Application or access your account on our network.
When you interact with the Site or the Application, we try to make that experience simple and useful. We and our partners use industry standard identifiers, such as cookies or other similar technologies. We also use mobile device identifiers which perform a similar role, like the IDFA used by Apple devices and the UDID used by Android devices. Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application and which store and sometimes track information about your use of the Site or Application (as the case may be). A number of cookies we use last only for the duration of your web or Application session and expire when you close your browser or exit the Application. Other cookies are used to remember you when you return to the Site or Application and will last for longer. We refer to cookies and the mobile device equivalents as “Identifiers”.
We use Identifiers to:
remember that you have visited us before; this means we can identify the number of unique visitors we receive;
customize elements of the promotional layout and/or content of the pages of the Site or Application;
collect statistical information about how you use the Site or App (including how long you spend on the Site or Application) and where you have come to the Site or Application from, so that we can improve the Site and learn which parts of the Site and which functions of the Application are most popular with users
Some of the Identifiers used by the Site are set or accessed (as appropriate) by us, and some a by third parties who are delivering services on our behalf.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note, however, that by blocking or deleting cookies used on the Site or Application, you may not be able to take full advantage of the Site or Application (as the case may be).
When you download and use our Services, we automatically collect information on the type of device you use and operating system version.
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We collect your location based information for the purpose of mileage tracking and providing location specific features. We may share your geo-location data with third parties for the sole purpose of providing these services. If you do not wish to allow us to share your information in this manner please opt out by contacting us at firstname.lastname@example.org
You may opt-out of location based services at any time by editing the setting at the device level.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
3rd Party Tracking Technologies
4. USE OF YOUR PERSONAL DATA
Any Expense uses your Personal Data in the following ways:
to facilitate the creation of and secure your account on our network; identify you as a user in our system;
to provide improved administration of the Any Expense Service;
to improve the quality of experience when you interact with the Any Expense Service;
to send you a welcome email to verify ownership of the email address provided when your account was created;
to send you administrative email notifications, such as security or support and maintenance advisories
to respond to your inquiries related to employment opportunities or other requests;
to send with your consent (or where a friend has referred you to us) promotional communications;
to provide you with hardcopy or electronic newsletters, or surveys;
to send with your consent (or where a friend has referred you to us) upgrades and special offers related to the Any Expense Service and for other marketing purposes of Any Expense or our Partner Companies; and
to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback.
Any information, including Personal Data, which you elect to make publicly available on the Any Expense Service will be available to other Members. If you remove information that you have made public on the Any Expense Service, copies may remain viewable in cached and archived pages of the Any Expense Service, or if other Members have copied or saved that information.
We collect information under the direction of our clients, and have no direct relationship with individuals whose Personal Data we process.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your Personal Data with Partner Companies to provide technical support or to provide specific services, such as hosting of your applications, maintenance services, database management or payment processing for purchases or reimbursements. Partner Companies will have access to your Personal Data only to perform these services on our behalf and are obligated not to disclose or use it for any other purpose. They may be located, or their data processing activities may take place, in the United States of America or elsewhere outside the European Economic Area (EEA). The US and other non-EEA countries do not have similar data protection laws to the European Union, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe.
Any Expense may sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Personal Data may be among the items sold or otherwise transferred in these types of transactions, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your Personal Data. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.
In certain situations, Any Expense may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Regardless of any choices you make regarding your Personal Data (if applicable), Any Expense may disclose Personal Data if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants or lawful requests from government authorities served on Any Expense; or (b) protect or defend the rights, reputation or property of Any Expense or users of the Any Expense Service.
Except as otherwise stated in this policy, we do not sell, trade, share, or rent the Personal Data collected from our services to third parties. You expressly consent to the sharing of your Personal Data as described in this policy.
Service Provider, Sub-Processors/Onward Transfer
Any Expense may transfer Personal Data to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Any Expense offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also access and manage your preferences from your account.
7. PERSONAL DATA CHANGES
You may change aspects of any of your Personal Data in your account by editing your profile within the registration portion of the Site or by sending an email to us at email@example.com. You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Access to Data Controlled by our Corporate Members
Upon request we will provide you with information about whether we hold any of your Personal Data. We also acknowledge that you have the right to access your Personal Data. Where a Member accesses the Application or the Any Expense Service because their employer is a Corporate Member, Any Expense has no direct relationship with that Member. In that situation, a Member who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Any Expense’s Corporate Member (the data controller).
Any Expense will retain data we process on behalf of our Corporate Members for as long as needed to provide services to our Corporate Member. Any Expense will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. CONTACT INFORMATION