Privacy Policy
This Privacy Policy describes how TWENTY FOUR TWELVE SOCIETY INTERNATIONAL LIMITED ("Twelve", "we", "us", or "our"), a company incorporated in Hong Kong and operating at RM 602, 6/F, Kai Yue Commercial Building, No.2C Argyle Street, Mongkok, Kowloon, HONG KONG, collects, uses, discloses, and safeguards your personal data in connection with our platform and services. By accessing or using our website or services, you agree to the terms of this Privacy Policy.
1. Data Controller Identification
We act as the Data Controller of your personal data, meaning we determine the purposes and means of processing your information. If you have questions or requests about this Policy, you may contact contact@2412society.com
2. Scope of Application
This Privacy Policy applies to all users of our website, clients, vendors, and partners worldwide. It governs the collection, use, and disclosure of personal data regardless of jurisdiction, with full adherence to data protection regulations including but not limited to Hong Kong’s PDPO and the GDPR where applicable.
3. Types of Personal Data Collected We may collect various categories of personal data, including but not limited to your full name, email address, telephone number, billing and shipping addresses, IP address, payment information, browsing data, user account credentials, and any other information that you voluntarily provide to us through forms, emails, or other means of communication. We may also collect data relating to your use of the Website, including cookies, log files, and user behavior data.
4. Legal Basis for Processing Personal Data We process your personal data only where we have a legal basis to do so. Such legal bases include: (i) your consent, where you have provided it voluntarily; (ii) the performance of a contract to which you are a party; (iii) compliance with a legal obligation to which we are subject; and (iv) our legitimate interests, provided that such interests are not overridden by your data protection rights. We will always inform you when we rely on each legal basis and provide clarity as to the nature of the processing involved.
5. User Rights and Access Requests
As a data subject under applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR) where applicable, you may exercise specific rights regarding your personal data. These rights include, without limitation, the right to request access to the data we hold about you, the right to rectify inaccurate or incomplete information, the right to request erasure of your data, the right to restrict processing, and the right to data portability. All such requests must be submitted in writing via the contact details provided at the end of this Privacy Policy. We reserve the right to verify your identity before fulfilling any such request and to retain certain information as permitted or required by applicable law.
6. Lawful Basis for Processing
TWENTY FOUR TWELVE SOCIETY INTERNATIONAL LIMITED processes personal data only when we have a lawful basis to do so. The legal grounds may include your explicit consent, the necessity of processing for the performance of a contract, compliance with a legal obligation, protection of vital interests, or our legitimate interests that are not overridden by your fundamental rights and freedoms. Where consent is the lawful basis, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. All data processing activities are documented in accordance with applicable legal and regulatory standards to ensure transparency and accountability.
7. Data Sharing and Disclosure to Third Parties
We do not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may disclose your information to selected third parties in the following limited circumstances:
Service Providers and Contractors: We may engage third-party vendors and partners to provide services on our behalf, such as payment processing, website hosting, IT support, analytics, and customer service. These partners will have access only to the data necessary to perform their functions and are contractually obligated to maintain the confidentiality and security of such data.
Legal and Regulatory Authorities: We may disclose personal information if required to do so by law or in response to valid legal processes (e.g., court orders, subpoenas, or law enforcement requests), or to enforce our Terms and Conditions, protect our rights or property, prevent fraud, or ensure the safety of users and the public.
All disclosures are made strictly on a "need-to-know" basis, and only to parties bound by obligations of confidentiality and data protection consistent with applicable privacy laws.
8. Cross-Border Data Transfers
Given that our company is incorporated in Hong Kong and may engage with users and service providers across multiple jurisdictions, your personal information may be stored, transferred, or processed outside of your country of residence, including in jurisdictions that may not offer the same level of data protection as your own.
When transferring data internationally, we take appropriate measures to ensure that your personal data remains protected in accordance with applicable data protection laws, including but not limited to:
Implementing contractual safeguards such as Standard Contractual Clauses (SCCs) approved by data protection authorities;
Ensuring that the recipient country has been recognized as providing an adequate level of protection for personal data;
Conducting risk assessments and due diligence on third-party recipients to assess their privacy practices and security standards.
By using our website or services, you acknowledge and agree to the transfer of your personal data as described above.
9. Data Retention and Storage Duration
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, accounting, or regulatory obligations, resolve disputes, and enforce our agreements.
In general, the retention periods are determined based on the following criteria:
The duration of your contractual relationship with us;
Legal obligations under applicable law (e.g., retention for tax, audit, or anti-money laundering regulations);
The sensitivity and nature of the data collected;
Whether there is an ongoing dispute, investigation, or claim that requires us to retain the data.
Once the retention period expires, we ensure that your data is securely deleted, anonymized, or destroyed in accordance with our data destruction policy and applicable legal standards.
10. Your Rights Regarding Personal Data
In accordance with applicable data protection laws, you have certain rights over your personal data. These rights may vary depending on your jurisdiction, but typically include:
Right of Access: You may request confirmation as to whether we process your personal data and obtain a copy of such data along with information on how it is processed.
Right to Rectification: If you believe that your data is inaccurate or incomplete, you have the right to request correction or completion.
Right to Erasure ("Right to be Forgotten"): Under certain conditions, you may request the deletion of your personal data, particularly when it is no longer necessary for the purposes for which it was collected.
Right to Object: You may object to processing of your data for direct marketing or based on legitimate interest, unless we demonstrate compelling legitimate grounds to continue.
Right to Restrict Processing: You can request that we limit the processing of your data under specific circumstances.
Right to Data Portability: Where applicable, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller.
To exercise any of these rights, please contact us at [insert privacy contact email], and we will respond within the legally required timeframe.
11. Protection of Minors
Our services are not intended for individuals under the age of 18, and we do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal information from a person under 18 years of age without verified parental or legal guardian consent, we will take immediate steps to delete such data from our systems.
We strongly encourage parents and legal guardians to monitor the online activity of their children and to ensure that no personal data is submitted without proper supervision. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [insert contact address], and we will work diligently to resolve the issue in accordance with applicable data protection regulations.
12. International Data Transfers
Given the international nature of our operations, your personal data may be transferred to and processed in countries other than your country of residence. These countries may not have data protection laws that are equivalent to those in your jurisdiction. In such cases, we take all appropriate and necessary measures to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable legal frameworks.
When we transfer personal data from the European Economic Area (EEA) or the United Kingdom to third countries that are not subject to an adequacy decision by the European Commission or the UK Information Commissioner’s Office, we rely on standard contractual clauses (SCCs), binding corporate rules, or other legally recognized mechanisms to ensure adequate safeguards are in place for the protection of your information.
13. Data Retention and Deletion
We retain your personal data only for as long as it is necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, tax, accounting, or reporting obligations. In certain cases, we may retain your data for a longer period if required by law or if retention is necessary to establish, exercise, or defend legal claims.
Once your personal data is no longer necessary for the purposes for which it was collected, or upon your explicit request (subject to legal exceptions), we will securely delete or anonymize your information. Our data deletion protocols follow strict internal policies and comply with applicable legal requirements, including the General Data Protection Regulation (GDPR) and relevant international privacy standards.
14. Cookies and Similar Technologies
We use cookies, web beacons, tracking pixels, and similar technologies to enhance your user experience, analyze site traffic, customize content, and deliver targeted advertisements. Cookies are small text files that are placed on your device when you visit our website. They allow us to recognize your browser and remember your preferences during and between visits.
You have full control over the use of cookies and can modify your browser settings to refuse all or some cookies or to alert you when websites set or access cookies. However, disabling cookies may affect the functionality and performance of the site and may limit your ability to use certain features. For more detailed information, please refer to our dedicated Cookie Policy, which outlines the categories of cookies we use and how you can manage your preferences.
15. Third-Party Services and Disclosures
In the course of providing our services, we may engage trusted third-party partners who process personal data on our behalf, such as hosting providers, payment processors, analytics services, marketing platforms, and customer support tools. We ensure that all such third parties are contractually bound to comply with strict data protection obligations and do not use your information for any purposes other than those explicitly authorized by us.
We do not sell, rent, or trade your personal data. However, we may disclose your information to third parties:
When required by law, regulation, legal process, or governmental request;
To protect our rights, property, and the safety of our users or the public;
In the context of a business transfer, such as a merger, acquisition, or asset sale.
All disclosures are strictly limited to the minimum necessary to achieve the intended and lawful purpose.
16. Data Transfers Outside the European Economic Area (EEA)
Given the global nature of our operations, your personal data may be transferred to, stored, and processed in countries outside the European Economic Area (EEA), including jurisdictions that may not offer an equivalent level of data protection as your home country. In such cases, we take all necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable laws.
These safeguards may include:
The use of standard contractual clauses approved by the European Commission;
Verification of third parties’ adherence to recognized certification mechanisms (e.g., EU-U.S. Data Privacy Framework, ISO/IEC 27001);
Binding corporate rules where applicable.
We remain fully accountable for the protection of your personal data, regardless of the location of processing.
17. Automated Decision-Making and Profiling
We do not use your personal data to make decisions solely based on automated processing that produce legal effects or significantly affect you, unless such processing is:
Explicitly authorized by law;
Necessary for the performance of a contract;
Conducted with your explicit consent.
Where profiling is carried out (e.g., for fraud prevention, credit risk assessment, or personalized marketing), we ensure that it is based on transparent logic, limited to relevant data, and subject to human oversight. You have the right to object to profiling and to request human intervention in any automated decision-making that may affect you significantly.
We commit to minimizing bias, ensuring transparency, and maintaining the ethical use of any artificial intelligence or algorithmic technologies used in relation to your data.
18. Data Minimization and Retention
We collect and process only the personal data that is strictly necessary for the purposes set out in this Policy. We avoid excessive or irrelevant data collection and ensure that all information is adequate, relevant, and limited in scope and duration.
We retain your personal data:
For as long as it is necessary to fulfil the purpose for which it was collected;
To comply with legal, regulatory, or contractual obligations;
For legitimate business needs such as accounting, audit, or fraud prevention.
Upon expiration of the retention period, we securely delete or anonymize the data, unless legal obligations require us to retain it for a longer duration.
19. Children’s Privacy and Age Restrictions
Our platform is not directed at individuals under the age of 18. We do not knowingly collect or process personal data from minors without the express, verifiable consent of a parent or legal guardian.
In the event we become aware that we have inadvertently collected personal data from a child without such consent, we will take immediate steps to delete such information from our records. If you are a parent or guardian and believe your child has provided us with personal data, please contact us promptly to request deletion.
We reserve the right to verify the age of any user and may restrict access or suspend an account if we suspect that age-related information has been misrepresented.
20. Jurisdiction, Applicable Law, and Dispute Resolution
This Privacy Policy shall be governed and construed in accordance with the laws of Hong Kong SAR, without regard to its conflict of law provisions.
Any dispute, controversy, or claim arising out of or in connection with the interpretation, performance, or breach of this Policy shall be resolved:
Preferably through amicable discussions and negotiations in good faith;
Failing which, through arbitration administered under the Hong Kong International Arbitration Centre (HKIAC) rules, by a single arbitrator appointed in accordance with said rules;
The language of arbitration shall be English, and the seat shall be Hong Kong.
By using our services, you expressly consent to this jurisdictional clause and waive any objection to proceedings being brought in this forum.