1. Introduction and Scope
1.1 This Privacy Policy explains how Interlinkages Limited, a company incorporated in Hong Kong (“Credence”, “we”, “us”, “our”), collects, uses, discloses and protects personal data in connection with the Credence Data portal and related company profile pages, downloads, and report services (together, the “Services”).
1.2 This Policy applies to (a) visitors to our website and company profile pages, (b) users who create an account, download sample materials, purchase reports or credits, or otherwise use the portal, and (c) subject companies and their representatives who provide information to us for inclusion in reports and/or publication (each, a 'User' or 'you').
1.3 This Policy forms part of and is incorporated by reference into our Terms and Conditions. Capitalised terms not defined in this Policy have the meaning given to them in the Terms and Conditions.
1.4 Our Services are intended for adults. We do not knowingly collect Personal Data from children. If you believe a child has provided Personal Data to us, please contact us so we can take appropriate steps.
2. Definitions
2.1 Personal Data means any data (including an opinion) relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable (or equivalent concepts under applicable law).
2.2 Processing means any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, transmission, and deletion.
2.3 Services means the Credence portal, website, company profile pages, sample downloads, and related report and credit services made available by Credence.
2.4 Subject Company means the company that is the primary subject of a report or profile page. Subject-Provided Information means information or documents submitted by a Subject Company (including non-public information).
2.5 Cookie means a small text file or similar technology placed on your device when you visit a website or use an online service.
3. Governing Framework
3.1 Credence is based in Hong Kong and processes Personal Data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) ('PDPO').
3.2 If you are located outside Hong Kong, additional laws may apply to our Processing. See Section 12 (International Users) for additional disclosures and rights that may apply depending on your location and our Processing activities.
4. Personal Data we collect
4.1 Personal Data Information you provide directly: (a) account details (name, business name, role, email, password/credentials metadata); (b) checkout and delivery details (delivery email, billing details, company/entity identifiers you enter, country, address inputs); (c) communications (emails, messages, feedback, dispute or correction requests, support tickets);(d) download unlock details (email address used to unlock sample reports or other downloads);
4.2 If you are a Subject Company (or act on behalf of a Subject Company), we may collect Subject-Provided Information, including documents and non-public information you submit for inclusion in a report and, where applicable, for publication pursuant to a separate Publication Consent.
4.3 Information we obtain from sources to generate profile pages/reports: Profile pages and reports may incorporate information obtained from official public records, licensed providers, and other sources believed reliable. Depending on the country availability, this may include personal data about individuals connected to a business (e.g., directors, officers, beneficial owners where available), where legally available.
4.4 Payments are processed by third-party payment processors (e.g., Stripe). We do not store full payment card details. We may receive limited metadata confirming payment status and transaction references.
4.5 Device and usage data: When you use the Services, we may collect technical and usage data such as IP address, device identifiers, browser type, operating system, referral URLs, pages viewed, timestamps, and security logs
5. Purpose of processing
5.1. We process personal data for the following purposes:
5.1.1 To provide the Services, including account creation, authentication, access to profile pages, report generation and delivery;
5.1.2 To deliver downloads and manage abuse prevention and audit logs for downloads;
5.1.3 To process orders and payments, and provide invoices/receipts and delivery confirmations;
5.1.4 To verify entity selection and reduce errors, including requesting clarifications;
5.1.5 To maintain security, prevent fraud, detect misuse (including scraping/bulk extraction attempts) and protect the integrity of the Services;
5.1.6 To comply with legal obligations, regulatory expectations, law enforcement requests, and to maintain appropriate records and audit trails;
5.1.7 To manage disputes, claims, and enforcement, including investigating suspected breaches of the T&C;
5.1.8 To improve the Services, including troubleshooting, analytics (where permitted), and performance monitoring;
5.2 Where a Subject Company provides Subject-Provided Information, we process such information to produce the requested report and, where separately authorised by Publication Consent, to publish specified fields (which may be labelled as 'Provided by the Subject Company' and may include a description of verification status).
6. Direct marketing and product updates
6.1 We may send transactional or service communications necessary to provide the Services (e.g., confirmations, delivery notices, security notices, reminders for action).
6.2 Where you have provided explicit consent, we may use your contact details to send product updates, announcements, offers and information about new products or features. You may withdraw your consent at any time by using the unsubscribe link provided in our communications or by contacting us.
6.3 We do not permit customers to use Personal Data obtained from the Services for direct marketing, list-building or advertising targeting, and such use is prohibited under our Terms and Conditions.
7. Cookies and Similar Technologies
7.1 We use Cookies and similar technologies (including pixels and local storage) to operate and secure the Services, remember preferences, and (where enabled) measure performance and improve the Services.
7.2 Where required by applicable law, non-essential Cookies will be used only with appropriate consent. You may manage Cookies through any cookie controls we provide (if available) and/or through your browser settings. Disabling certain Cookies may affect functionality.
8. Disclosure of Personal Data
8.1 We may disclose Personal Data to: (a) service providers and processors acting on our behalf (e.g., hosting, email delivery, customer support tools, security monitoring); (b) payment processors to process payments; (c) data/registry providers where necessary to generate reports, subject to lawful access and provider terms; (d) professional advisers (including legal and audit) where necessary; and (e) competent authorities where required by law or necessary to protect rights, safety, or prevent and investigate misuse.
8.2 We do not sell Personal Data for money as a standalone business. If we engage in practices that are treated as 'sale' or 'sharing' under certain laws (for example, sharing with advertising technology partners for targeted advertising), we will provide appropriate notices and opt-out mechanisms as required by applicable law.
9. International Transfers
Because we operate globally and may use service providers in multiple jurisdictions, Personal Data may be transferred to and processed in locations outside Hong Kong. We take reasonable contractual and organisational measures to protect Personal Data in such circumstances.
10. Data Retention
We retain Personal Data only for as long as reasonably necessary for the purposes described in this Policy, including for providing the Services, maintaining audit trails, complying with legal obligations, and resolving disputes. Retention periods vary depending on the type of data and the context in which it is processed.
11. Security
We maintain reasonable administrative, technical and organisational safeguards designed to protect Personal Data against unauthorised access, disclosure, alteration or destruction. However, no system is completely secure and we cannot guarantee absolute security.
12. International Users and Additional Rights
12.1 If you are located outside Hong Kong, you may have additional rights under the laws of your location. Depending on your jurisdiction and our Processing activities, such rights may include the right to request access to, correction of, or deletion of your Personal Data; to object to or restrict certain Processing; and/or to opt out of certain uses such as targeted advertising.
12.2 United States residents. Certain US state privacy laws provide residents with rights such as access, correction, deletion, and the ability to opt out of targeted advertising and certain forms of data 'sale' or 'sharing' (as defined by applicable law). Where such rights apply, you may submit a request as described in Section 13.
13. Your Request (Access, Correction and Other Rights)
Requests. To submit a request relating to your Personal Data, please contact us using the details in Section 14. We may require verification of identity and authority before processing a request. We may refuse or limit requests where permitted by law, including where necessary to protect security, prevent fraud, comply with legal obligations, or protect the rights of others.
14. Contact Details
For privacy questions, requests or complaints, contact us at:
Email: service@credencedata.com
Address: Interlinkages Limited, 9F, Amtel Building, 148 Des Voeux Road Central, Hong Kong
15. Changes to this Policy
We may update this Policy from time to time. The updated Policy will be posted on the website with a revised effective date.