Privacy Policy

This is the privacy statement of the company Hong Kong Reverse Technology Limited., hereinafter: FindLocate. This document explains how FindLocate handles the processing of your personal data. In processing your personal data, FindLocate will exercise the utmost care.

Acquisition of Personal Data

If you use the services of FindLocate, you will provide a number of personal data to FindLocate or personal data obtained from you in the context of the agreement. Personal data is defined as all data relating to identified or identifiable natural persons.

Categories of Personal Data

FindLocate processes the following categories of personal data:

  • Contact and name and address information, including location information, phone number, email address

  • IP addresses

  • Company data, including VAT number and Chamber of Commerce number

  • Financial data

  • Account information, including your user name

  • Other personal data provided by you

Purpose of Processing

The personal data processed by FindLocate is intended to:

  • to contact you to inform you about the services you have purchased and their implementation

  • to carry out its services;

  • to improve its services;

  • to be able to make payments;

  • to comply with legal obligations;

  • to be able to make marketing and communication statements, including improving the website by analyzing visitor behavior on the website;

  • to be able to send newsletters;

  • to exchange data with third parties for the performance of services, to the extent necessary.

Basis for Processing

The processing of personal data is only possible on the basis of the following grounds: (i) legal obligation, (ii) performance of an agreement, (iii) obtained (explicit) consent of the data subjects, and (iv) legitimate interest. In providing the services of FindLocate personal data is processed. FindLocate only processes data that FindLocate considers necessary for (the improvement of) the services and will carefully handle the (personal) data that it has collected about you and your use of the services. The basis for processing this data is the agreement that you have entered into with FindLocate. Personal data about you may also be processed by visiting the website if you have given permission.

Need for Processing

The processing of your personal data is necessary to perform the services. The services provided by FindLocate cannot be fully implemented without the processing of your personal data. If for specific purposes relating to the personal data your explicit consent is required, you must provide separate consent for this.

Automated Decision Making

If there is any automated decision-making, such decision-making is done by computer systems and / or computer programs without the intervention of human action. The data subject is personally responsible for the data he or she provides that is used at the time of automated decision-making. If the data turns out to be incorrect or incomplete, the damage resulting from this will be at the expense and risk of the person concerned. This also includes the failure to perform, to perform in a timely manner, or to perform incorrectly.

Retention Period

The personal data processed by FindLocate will be stored in accordance with the relevant laws and regulations. If a longer retention period is necessary on the basis of legislation or regulations, the personal data will be retained for a longer period in accordance with these requirements. All (obtained) personal data will not be kept longer than strictly necessary.

Processing by Third Parties

FindLocate will only share personal data with third parties if this is strictly necessary for the performance of an agreement and to comply with relevant laws and regulations. Personal data will not be sold. FindLocate may be under a legal obligation to share personal data with third parties. If personal data is shared with third parties, processing agreements will be concluded for this purpose. The third parties with whom personal data is shared are:

  • The Payment Provider, for the purpose of executing an agreement. The categories of personal data processed are financial data.

  • The Bookkeeper, for the purpose of executing an agreement. The categories of personal data processed are contact and name and address information and financial data

  • Software suppliers, for the purpose of executing the agreement. The categories of personal data processed are contact and name and address details.

  • Website administrator, for the purpose of executing the agreement. The categories of personal data processed are contact and name and address details.

  • Hired third parties, for the purpose of executing the agreement. The categories of personal data processed are contact and name and address details.

Security of Personal Data

FindLocate takes the protection of your personal data seriously and takes appropriate technical and organizational measures in this respect, taking into account the state of the art, implementation costs, as well as the nature, scope, context and the processing purposes and the different risks for the rights and freedoms of persons in terms of probability and severity, to ensure a risk-appropriate level of security.


By using the website you agree with the disclaimer. FindLocate reserves the right to change the contents of its website and / or this disclaimer at any time without informing its customers and / or users of the website about this change. The contents of the website have been composed with the utmost care, but may nevertheless contain inaccuracies or be incomplete. FindLocate does not accept any liability whatsoever for damage caused by or arising from the use of the website. The use of this website is entirely at the risk and expense of a user of the website. No rights can be derived from the content of the website. All texts on the website are copyrighted and owned by FindLocate to the extent that they do not belong to third parties.

Cookie Statement

FindLocate uses technical and functional cookies to optimize the website. Cookies are small text files that are sent by visiting a website to make the user experience of visitors more efficient. FindLocate may, by law, store cookies on your device if these cookies are strictly necessary to use the website. For other types of cookies, your consent is required. FindLocate recommends that you accept the cookies in connection with the user-friendliness of the website. Visitors to the website have a check-in option.

The cookies used by FindLocate are functional cookies: these cookies ensure that the website works properly. These cookies have no effect on privacy, so no permission needs to be requested and granted. For example, these cookies store your browser settings so that our website can be viewed best, or that the website remains accessible (load-balancing) but also cookies that ensure that no other cookies may be placed (no-follow).

With your permission, FindLocate places ''tracking cookies'' on your computer. FindLocate uses these cookies to keep track of the pages you visit in order to build up a profile of your online behaviour. This profile is not linked to your name, address, email address, etc., but only to tailor advertisements to your profile so that they are as relevant to you as possible.

On the website of FindLocate cookies are also placed by Google for the purpose of Google Analytics. This means that FindLocate cannot link any information to a natural person. FindLocate does not keep information about what you do on the Internet. Google Analytics may be obliged under applicable laws and regulations to provide access to this data.

Email Newsletter and Other Marketing Mails

You can register via the website for a newsletter and / or for other commercial offers. When you register, FindLocate will ask you for permission to process your email address for the purpose of sending you marketing emails containing the latest information on products and services, special offers and marketing campaigns. You will only receive marketing emails when you have given your consent.

Your consent also includes your approval of the fact that FindLocate may personalize the content of marketing emails in accordance with your needs and interests based on any user profile created for you.

Your consent to the sending of marketing emails may be withdrawn by you at any time by clicking on "Unsubscribe" at the end of the marketing email. Withdrawal of consent does not affect the lawfulness of the processing performed prior to withdrawal of consent.

Browser Settings

If you do not want websites to place cookies on your device used to view the website, you can adjust your browser settings. Before a cookie is placed, you will receive a warning and will have to give your permission for the cookie to be placed. Failure to do so may result in, for example, the website working less well. You can adjust the settings of your browser so that your browser refuses all cookies and also the cookies of third parties. You can also remove installed cookies. To do this you must change the settings of your browser via preferences and then you can change the privacy settings.

This privacy statement does not apply to third-party websites that are connected to this website through links. FindLocate cannot guarantee that these third parties will treat your personal data in a reliable or secure manner. FindLocate advises you to read the privacy statement of these websites before using them.

Permission to Use Device Phone Book

Used for accessing contacts and phone numbers stored on the User's device.

Right of Data Subjects

As a data subject, you have the following rights:

  • Right of access; As a data subject, you have the right to be informed as to whether or not your personal data are being processed and, if so, to obtain access in relation to the processing thereof.

  • Right to rectification; You have the right to obtain rectification and completion of inaccurate data.

  • Right to erasure of data; Without unreasonable delay, a data subject should obtain erasure of personal data concerning him.

  • Right to restriction of processing; As a data subject, you have the right to restrict the processing of your personal data. To do so, please contact FindLocate.

  • Right to transferability of data; A data subject has the right to obtain the personal data relating to him that he has provided to FindLocate in a structured, common and machine-readable form in order to transfer this personal data to a third party if necessary. A data subject may also instruct FindLocate to transfer this data directly to a third party.

  • Right to object; The data subject shall have the right to object at any time, on grounds relating to his/her particular situation, to processing of personal data concerning him/her, including profiling based on those provisions. FindLocate shall cease processing the personal data unless there are compelling legitimate grounds for the processing which override the interests, freedoms and rights of the data subject related to the exercise of, establishment or support of legal claims.


If you have a complaint about the way in which FindLocate handles your personal data, or wish to exercise one of the aforementioned rights, please feel free to contact us via our email

Modifications of the Privacy Statement

FindLocate may amend the Privacy Statement at any time. The most recent version is published on the website. Therefore, always keep an eye on the website for the most recent version. If the new Privacy Statement affects the way in which FindLocate already processes data collected about you, FindLocate will notify you by email.

Last updated on September 13, 2022.