Privacy Policy
The data controller for information collected through the website is : E-SMART GROUP LIMITED
Rm 701, Unit 108, 7/F, Tower B, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui, Hong Kong
Business Registration Certificate Number: 79681439-000-01-26-1
Contact : contact@mbsecosysteme.com
We collect the following categories of data :
2.1. Data provided directly by the User
When you use the contact form or contact us through the information displayed on the website (email, WhatsApp), we may collect :
• Your full name ;
• Your email address ;
• Your phone number (if applicable) ;
• The name of your company or project (if applicable) ;
• The content of the message you send us and any information you choose to include.
2.2. Data collected automatically
While browsing the website, certain data may be collected automatically :
• IP address, browser type and version, operating system, language ;
• Pages visited, date and time of consultation, visit duration, traffic source ;
• Cookie identifiers and advertising trackers (see section 6).
3.1. Responding to contact requests
Purpose : processing your requests for information, quotes, or business inquiries, and ensuring follow-up of the pre-contractual relationship.
Legal basis : performance of pre-contractual measures taken at your request, and/or the legitimate interest of the publisher in responding to inquiries addressed to it.
3.2. Audience measurement and website improvement
Purpose : understanding website usage, improving ergonomics, and enhancing the relevance of content.
Legal basis : User consent (collected through the cookie banner) or the legitimate interest of the publisher when the tools used are anonymized and non-intrusive.
3.3. Marketing, retargeting, and advertising performance measurement
Purpose : complying with any applicable legal or regulatory obligation, and defending our rights in the event of a dispute.
Legal basis : prior consent of the User, collected through the cookie banner.
3.4. Compliance with legal and regulatory obligations
Legal basis : User consent (collected through the cookie banner) or the legitimate interest of the publisher when the tools used are anonymized and non-intrusive.
Legal basis : legal obligation and legitimate interest of the publisher.
Your data may be shared with :
• Authorized teams within E-SMART GROUP LIMITED ;
• Technical subcontractors acting on our behalf, including the website host (Framer B.V.) and our communication tools (messaging services, CRM) ;
• Advertising platforms such as Meta Platforms Ireland Ltd., TikTok Technology Ltd., and Snap Inc., exclusively in relation to the advertising cookies and pixels described in section 6 ;
• Any competent public authority, in the context of a legal obligation or judicial procedure.
We never sell or rent your personal data to third parties for commercial purposes.
The Website is accessible free of charge to any person with Internet access, 24 hours a day, 7 days a week, except in cases of force majeure, maintenance operations, or potential communication network failures.
The publisher reserves the right, without notice or compensation, to temporarily or permanently close all or part of the Website, particularly for updates, modifications, or in the event of service discontinuation. The publisher cannot be held responsible for the potential impact of such unavailability on the User’s activities.
All costs related to accessing the Website (computer equipment, software, Internet connection, etc.) remain the sole responsibility of the User.
The website uses cookies and trackers to ensure proper functionality, measure audience traffic, and deliver targeted advertising.
6.1. Categories of cookies used
Strictly necessary cookies
Essential for the proper functioning of the website (security, remembering your cookie preferences). Their use does not require your consent.
Audience measurement cookies
Used to measure website traffic and performance. Subject to your prior consent when not exempted.
Advertising cookies and tracking pixels
• Meta Pixel (Facebook / Instagram) — provided by Meta Platforms Ireland Ltd. Privacy Policy: https://www.facebook.com/policy.php
• TikTok Pixel — provided by TikTok Technology Limited. Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/fr
• Snap Pixel — provided by Snap Inc. Privacy Policy : https://snap.com/fr-FR/privacy/privacy-policy
These pixels allow these platforms to collect your IP address, advertising identifier, and information related to your browsing activity, and associate it with accounts you may hold on their services. They are only placed after obtaining your prior consent.
6.2. Managing your consent
During your first visit, an information banner allows you to accept, refuse, or configure non-essential cookies. You can modify your choices at any time through the website’s cookie management module or by deleting cookies from your browser settings.
You may also opt out of advertising tracking directly through the privacy settings of your Meta, TikTok, or Snapchat account.
Your data is retained for periods proportionate to the purposes pursued :
• Contact form data and business communications: retained for the time necessary to process your request, then archived for three (3) years from the last contact for commercial prospecting purposes ;
• Audience measurement data : retained for a maximum of twenty-five (25) months ;
• Advertising cookies and pixels : maximum lifespan of thirteen (13) months ;
• Data retained to comply with a legal obligation : kept for the period required by applicable law.
In accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) and the Data Protection Principles (DPP), you have the following rights regarding your personal data :
• Right of access (Data Access Request — DPP6 / Section 18) : obtain confirmation that personal data concerning you is held by the publisher, and receive a copy of it ;
• Right of correction (Data Correction Request — Section 22) : request the correction of inaccurate or incomplete data ;
• Right to object to direct marketing (Sections 35A to 35M) : request to stop receiving direct marketing communications, free of charge ;
• Right to withdraw your consent at any time when processing is based on consent.
To exercise these rights, you may contact us at : contact@mbsecosysteme.com , specifying your request and, if necessary, providing proof of identity.
If you believe that the processing of your data does not comply with applicable regulations, you may file a complaint with the Privacy Commissioner for Personal Data (PCPD — www.pcpd.org.hk ), the competent authority in Hong Kong for personal data protection.
We implement reasonable technical and organizational measures, in line with industry standards, to protect your personal data against loss, alteration, unauthorized access, or disclosure: secure HTTPS connection, access control to internal tools, employee training and awareness, and rigorous selection of subcontractors.
However, no Internet data transmission or electronic storage method is completely secure; therefore, we cannot guarantee absolute security.
The MBS ECOSYSTEME website is not intended for minors under eighteen (18) years old. We do not knowingly collect personal data relating to minors. If you are a minor, please do not provide us with any personal data. If you believe that a minor has provided us with personal data, you may contact us so that we can proceed with its deletion.
This Privacy Policy may be modified at any time to reflect regulatory, technical, or organizational developments. The date of the latest update is indicated at the top of the document. We invite you to review it regularly.
This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region.
Any dispute relating to this policy shall be subject to the exclusive jurisdiction of the competent courts of Hong Kong.
For any questions regarding this Privacy Policy or the processing of your data, you may contact us at : contact@mbsecosysteme.com