Effective date: Jan 01, 2019
Hexler Limited is open and transparent about how we treat your personal data. We are committed to safeguarding the privacy of all visitors to our website (Guests) and more formal users who have registered an account with us, or voluntarily installed one of our software applications (Users).
Hexler Limited aims to fully comply with Cap 486 of the Personal Data (Privacy) Ordinance of the Laws of the Hong Kong Special Administrative Region (https://www.pcpd.org.hk) alongside the EU General Data Protection Regulation (https://eugdpr.org).
Hexler Limited will ensure compliance by our staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted via our website, its sub-domains, or software applications; and we will not release such information to anyone without the your prior consent, except to the authorised persons specifically listed later in this document.
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Hexler and You
Hexler Limited's registered business address is 20th Floor, Central Tower, 28 Queen's Road, Central, Hong Kong. Our registered Hong Kong company number is 2313690.
Hexler Limited ("us", "we", or "our") (i) operates the https://hexler.net website and (ii) creates a number of software applications (the "Service").
The Service is (i) the https://hexler.net website operated by Hexler Limited and (ii) software applications created by Hexler Limited.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
User Created Data
User Created Data means all data related to files, file contents, file names, file locations, any embedded or linked content, created and/or owned by end users of the application.
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself.
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Types of Data Collected and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
User Created Data
We will not access, transfer or otherwise observe User Created Data in any way. You can verify this by installing an independent network traffic monitoring application.
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as unique device identifiers, software application diagonostic data, website diagnostic data, your devices's Internet Protocol address, web browser type and version, the pages of our Service that you visit, the time and date and duration of using the Service.
Website Tracking and Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
You can read the details of our Cookies Policy here:
You can change your Cookie Preferences here:
Use of Data
Hexler Limited uses the collected data for various purposes:
• To provide and maintain our Service.
• To notify you about changes to our Service.
• To allow you to participate in interactive features of our Service when you choose to do so.
• To provide customer support.
• To gather analysis or valuable information so that we can improve our Service.
• To monitor the usage of our Service.
• To detect, prevent and address technical issues.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Hexler Limited may process your Personal Data because:
• We need to perform a contract with you.
• You have given us permission to do so.
• The processing is in our legitimate interests and it's not overridden by your rights.
• For payment processing purposes.
• To comply with the law.
Retention of Data
Hexler Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your country or other jurisdiction where the data protection laws may differ than those from your jurisdiction.
Disclosure of Data
Under normal circumstances Hexler Limited will never disclose or share your Personal Data with any entity beyond those deemed necessary by us for the provision of Services:
We may share specific personal data of yours with third party service providers, subcontractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions (for example tech support, customer relations).
If you have consented to receive marketing communications, we may use one of the following third-party marketing automation services; Mailchimp, Mailchimp Mandrill, Pipedrive, Zoho CRM and/or SharpSpring. These services enable us to analyse the use of these communications. Information relating to marketing services will be included with any communication we send to you.
Disclosure for Law Enforcement
Under certain circumstances, Hexler Limited may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Hexler Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
• To comply with a legal obligation.
• To protect and defend the rights or property of Hexler Limited.
• To prevent or investigate possible wrongdoing in connection with the Service.
• To protect the personal safety of users of the Service or the public.
• To protect against legal liability.
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Hexler Limited aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Hexler Limited relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests, and complying with certain requests may limit or end your ability to continue to have access to the Service.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service. At the time of writing this document Hexler Limited does not employ the use of third-party Service Providers in our Service.
At the time of writing this document Hexler Limited does not employ the use of Google Analytics in our Service.
Payments and Third-Party Services
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Google (Google Play)
Apple (iTunes / App Store)
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
By email: email@example.com