Privacy Policy

Last updated: September 2026

1. Who we are

This Privacy Policy is issued by Lever Data Solutions Limited, a company incorporated in Hong Kong trading as "Checkafy" ("Checkafy", "we", "our" or "us"), with its registered office at Unit 231, 2/F, Building 16W, Hong Kong Science Park, Pak Shek Kok, Hong Kong. For the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO"), Lever Data Solutions Limited is the data user of the personal data described in this Policy.

This Policy explains how we collect, use, disclose, transfer and protect personal data when you use our website (www.checkafy.com), any mobile applications we publish, and our commercial solutions, including CheckReport, CheckDashboard, CheckAPI and CheckOps (together, the "Services"). It also sets out the statement required under the PDPO regarding the use of personal data in direct marketing.

By using the Services you acknowledge that you have read this Policy. Where our processing relies on your consent, you may withdraw that consent at any time as described in section 9.

2. Personal data we collect

2.1 Data you provide to us

  • Contact and account details: name, work email address, company name, job title or role, telephone number and password
  • Enquiries, demo requests and access requests submitted through our website forms, by email, or through third-party form providers we use to receive them
  • Commercial and billing details for subscriptions and managed services (company name, billing address, purchase order and payment references)
  • Instructions, scope documents and materials you provide to us for the delivery of CheckOps or other managed services
  • Job applications and CVs sent to info@checkafy.com

2.2 Data collected automatically

  • Device and browser information (device type, operating system, browser type, screen size, unique device identifiers)
  • Usage data (pages visited, features used, dashboards viewed, API calls made, time and duration of access)
  • Log data (IP address, access times, referring pages, errors)
  • Location data, only where you have enabled it, to provide localised market information

2.3 Retail and market data

The Services collect, aggregate and analyse product, pricing, listing, promotion and availability information from publicly accessible retailer websites, marketplaces and other public sources ("Market Data"). Market Data is business information about products and sellers. It is not intended to, and we do not knowingly use it to, identify or profile individual consumers. Where a public listing includes the name or contact details of an individual seller, we process that information only to the extent necessary to provide the Services (for example, brand protection and unauthorised-seller monitoring for our customers) and in accordance with the PDPO. If you are a seller and believe we hold your personal data, you may exercise your rights under section 9.

3. How we use personal data

  • To provide, operate, secure and maintain the Services
  • To deliver reports, dashboards, API access and managed-service deliverables you have subscribed to
  • To set up and administer your account and subscription, and to invoice and collect payment
  • To respond to enquiries, demo and access requests, and support tickets
  • To send service communications (onboarding, changes to the Services, security notices, billing)
  • To carry out direct marketing, subject to section 4 and your consent
  • To analyse usage, improve and develop the Services, and train and evaluate our matching and analytics models using aggregated or de-identified data
  • To detect, investigate and prevent fraud, abuse, security incidents and breaches of our Terms of Service
  • To comply with legal and regulatory obligations and to establish, exercise or defend legal claims
  • To assess job applications

Providing personal data to us is voluntary. However, if you do not provide the data we request, we may be unable to provide the Services, respond to you, or process your application.

4. Direct marketing

We may use your name, email address, telephone number, company name and job role to send you information about Checkafy products and services, including market intelligence reports, dashboards, data APIs, managed execution services, events, webinars and industry insights (the "Marketing Classes").

We will not use your personal data for direct marketing unless you have given your consent or indicated no objection. We do not provide your personal data to any third party for that third party's own direct marketing.

You may ask us to stop using your personal data for direct marketing at any time, free of charge, by clicking the unsubscribe link in any marketing email or by writing to info@checkafy.com. We will action your request without charge and within a reasonable time.

5. Disclosure of personal data

We do not sell personal data. We may disclose personal data to:

  • Service providers acting on our instructions, such as cloud hosting and storage, email delivery, form and survey tools, analytics, customer-relationship, payment and accounting providers, under contractual confidentiality and security obligations
  • Professional advisers (legal, accounting, insurance) where reasonably necessary
  • Our group companies, if any, for the purposes set out in this Policy
  • Business partners, only with your consent, where we deliver a jointly provided service
  • A purchaser or successor in connection with a merger, acquisition, financing or sale of all or part of our business, subject to this Policy
  • Courts, regulators and law-enforcement bodies where required by law, court order or a lawful request, or where necessary to protect our rights, property or safety, or those of our customers or the public

6. Transfer of personal data outside Hong Kong

Our Services are delivered using cloud infrastructure and service providers that may store or process personal data outside Hong Kong, including in Singapore, Japan, the United States and the European Union. Where we transfer personal data outside Hong Kong we take reasonable steps to ensure it receives a level of protection comparable to that under the PDPO, including contractual data-protection obligations with the recipient. By providing personal data to us you consent to such transfers for the purposes described in this Policy.

7. Data security

We apply technical and organisational measures appropriate to the nature of the data, including encryption in transit, access controls, logging, and staff confidentiality obligations. No method of transmission or storage is completely secure. To the extent permitted by law, we are not liable for unauthorised access that occurs despite reasonable security measures. If we become aware of a data breach that is likely to cause serious harm to you, we will notify you and the relevant authorities where required.

8. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, and thereafter as required for legal, regulatory, accounting, audit or dispute-resolution purposes. As a guide: account and subscription data is kept for the duration of the customer relationship and up to seven (7) years after it ends; enquiry and marketing data is kept until you unsubscribe or for up to three (3) years after the last contact; unsuccessful job applications are kept for up to twelve (12) months. When data is no longer required we delete or anonymise it.

9. Your rights

Under the PDPO you have the right to:

  • Request access to the personal data we hold about you (a "data access request")
  • Request correction of personal data that is inaccurate (a "data correction request")
  • Ask us to stop using your personal data for direct marketing, at any time and free of charge
  • Withdraw any consent you have given, without affecting processing carried out before withdrawal
  • Ask us to erase personal data that is no longer required for the purpose for which it was collected, subject to our legal retention obligations
  • Be informed of the kinds of personal data we hold and the purposes for which they are used

To exercise these rights, write to info@checkafy.com with sufficient information for us to verify your identity. We will respond within forty (40) days as required by the PDPO. We may charge a reasonable fee for complying with a data access request, as permitted by the PDPO, and will tell you the fee before proceeding. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong.

10. Cookies and similar technologies

We use cookies and similar technologies that are necessary for the website and dashboards to function, and analytics technologies to understand how the Services are used and to improve them. You can control cookies through your browser settings. Disabling cookies may affect the functionality of the Services.

11. Third-party websites and services

The Services may link to, embed, or rely on third-party websites and services (for example, form providers, calendar and scheduling tools, and app stores). Their privacy practices are governed by their own policies, and we are not responsible for them. Data you submit through a third-party form is also received by that provider under its own terms.

12. Customer data processed on behalf of customers

Where a customer provides us with personal data (for example, an authorised-seller list or contacts) so that we can deliver managed services, we process that data on the customer's instructions and under our agreement with that customer. The customer is responsible for having a lawful basis to share that data with us. Requests relating to such data should be directed to the relevant customer in the first instance.

13. Children

The Services are intended for business users and are not directed at individuals under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

14. Changes to this Policy

We may update this Policy from time to time. The current version is always available on this page with the "Last updated" date. Material changes affecting how we use your personal data will be notified by email or through the Services where practicable. Continued use of the Services after a change takes effect constitutes acceptance of the updated Policy.

15. Contact us

Questions, requests and complaints about this Policy or our handling of personal data should be sent to our Data Protection contact:

  • Lever Data Solutions Limited (trading as Checkafy)
  • Email: info@checkafy.com
  • Address: Unit 231, 2/F, Building 16W, Hong Kong Science Park, Pak Shek Kok, Hong Kong