1.1 This Privacy Policy describes how HRP Limited, a Hong Kong company with registered office at Room 701, 7/F Lucky Centre, 165-171 Wanchai Road, Wan Chai, Hong Kong ("HRP," "we," "our," or "us") collects, uses, processes, and protects your personal information when you access our website at https://solopay.pro and our platform located at app.solopay.pro (collectively, the "Services").

1.2 By accessing or using our Services, creating a Platform account, or providing personal information to us, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please discontinue use of our Services immediately.

1.3 We are committed to safeguarding personal information in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and other applicable data protection regulations. This Privacy Policy governs all personal data processing activities conducted by us in our capacity as data controller (as defined under the PDPO) or in similar roles under other applicable data protection frameworks.

1.4 This Privacy Policy does not cover third-party websites, platforms, applications, payment processors, social media services, or other third-party services that may be linked to or integrated with our Services ("Third-Party Services"). When you use Third-Party Services (for example, payment service providers), your personal information may be processed directly by those third parties under their own privacy policies. We recommend reviewing the applicable third-party privacy policies before using such services.

2.1. HRP collects Personal Data only for lawful purposes and through lawful and transparent means.

2.2. We process the following categories of personal information you provide for the following purposes:

To enable you to register on our Platform, create and manage your account, and authenticate your identity (for both business representatives and individual contractors), the personal data used for this may include:

• full name

• business email address

• telephone number

To perform our mutual obligations under the Terms of Use, provide full access to Platform features and, where applicable, verify eligibility and trustworthiness as a subcontractor. Depending on your role and the services you provide, the personal data used for this may include:

• identification and contact details (such as full name and contact information)

• information and documents used to verify your identity and eligibility to perform services (such as identification documents, residency or work eligibility information)

• information, tax registration details or similar data required by applicable law or our contractual obligations

• information related to your cooperation with us (such as period of cooperation, services provided, amounts payable and paid, and related records)

• technical and device information (such as device type, IP address, approximate location at the level of country/region/city, browser type and device identifiers) to help secure access to your account and the Platform

We will only request such information where it is necessary and appropriate for the relevant purpose.

To understand how company representatives and subcontractors use the Platform, improve user experience and ensure stability and maintain security, the data used for this may include:

• the address of the web page, from which you accessed our Platform

• number of visits and pages viewed

• traffic and log data

• the type of browser and device

• time and duration of sessions

other technical usage information generated by your interactions with the Platform

To handle your questions, requests and complaints and provide technical or customer support, the personal data used for this may include your name, contact details and any information you choose to provide in your request.

From time to time, we may offer you the option to subscribe to newsletters or other marketing or informational emails. If you choose to do so or otherwise agree to receive such communications, we will use your name and email address to send them to you and to personalize them where appropriate. You can unsubscribe at any time by using the unsubscribe link included in each email.

You can object to direct marketing at any time, free of charge, and we will stop using your personal data for such purposes as soon as reasonably practicable after receiving your request. You may unsubscribe via the link in our emails or by contacting us using the details below.

To calculate amounts due, process payouts to subcontractors and receive payments from clients, the personal data used for this may include:

• your name

• contact details (such as phone number)

• tax or registration numbers where required

• payment and billing details (such as bank account or other payment information)

For certain payment methods, your data may be processed directly by the relevant payment service provider under its own privacy policy. We recommend reviewing the privacy policy of the chosen payment provider.

If you choose not to provide certain personal data that is necessary for registration, verification or the provision of specific Platform features, we may be unable to create or maintain your account, enable certain functionality (such as receiving payments), allow you to contact us through our certain channels, or provide you with information about our products and services.

HRP may allow advertisers to show their advertisements directly to you on the Platform. While providing such advertisements directly to you, advertisers may place their own cookies on your computer and use their own web beacons and other technologies enabling them to track the effectiveness of advertisements, as well as to collect and track information such as demographic information, likely interests, aggregated information and actions that help them to personalize advertisements delivered to you. HRP shall not provide any information that could enable us to identify you without your consent. However, if you react to advertisements targeted at a particular audience, the advertiser may conclude that you belong to its target audience. This Policy does not cover any actions of such advertisers. Before responding to an advertisement, you should get familiarized with the respective privacy policy of such advertisers.

In some cases, our business customers may provide or enter personal data about certain individuals on the Platform and ask us to invite them to use the Platform or to create user accounts for them.

Depending on how the customer uses the Platform and the services requested, the personal data provided for this purpose may include:

• basic identification and contact details (such as name and phone number), which we may use to send an invitation (for example, by SMS)

• information used to verify the individual's identity and eligibility to perform services (such as nationality or citizenship, identification or passport details, tax identification or registration numbers, residency or work eligibility information and similar data required under applicable law or our contractual obligations with the customer)

• other information that is reasonably necessary to set up, link and administer the relevant accounts and project settings on the Platform

Our business customers are responsible for ensuring that they have an appropriate legal basis to collect and disclose such personal data to us and to enter it into the Platform, and that data subjects have been provided with any notices or obtained any consents required under the laws that apply to them.

We use this information to send invitations, create and manage user accounts and operate the Platform. If an invited person does not complete registration or does not start using the Platform, we will retain their personal data only for as long as reasonably necessary to manage the invitation process, avoid duplicate records, maintain our logs and ensure security, after which we will delete or anonymize this data where practicable.

Once an account has been created for such an individual and the individual starts using the Platform (for example, by accepting our terms or logging in), we process the personal data associated with that account as described in this Privacy Policy for our own purposes, including operating, securing and improving the Platform, managing relationships with subcontractors, performing our obligations as a general contractor and complying with applicable legal requirements. We will only request and use identity, tax or similar documentation where it is necessary and appropriate for these purposes or required by applicable law or our contractual obligations.

We use cookies and similar technologies (such as pixels, tags, and local storage) to operate and secure our Services, enable certain functionalities, remember user preferences, analyze Platform usage, and, where applicable, support advertising and marketing activities. These technologies help us improve our Services and provide a more reliable and efficient user experience.

Where required by applicable law (for example, in the European Economic Area or the United Kingdom), we will request your consent before placing non-essential cookies (such as analytics or advertising cookies) on your device. You can withdraw your consent or modify your cookie preferences at any time through your browser settings or, where available, through our cookie management tools.

Some cookies may be set by third-party analytics or advertising providers operating under their own privacy policies, and we do not control their practices.

Where required by applicable law, we will seek your consent before deploying non-essential cookies on your device. You may withdraw or update your cookie preferences at any time through cookie settings tools or your browser settings.

3.3 By continuing to use our Services after being provided with this Privacy Policy, you acknowledge that you have read and understood how we use cookies and manage your information as described in this Policy. This acknowledgment does not replace any express consents we are required to obtain from you under applicable law.

4.1 The PDPO does not require us to categorize our processing activities by specific "legal bases." We primarily process personal information based on Hong Kong law requirements and principles when collecting, holding, and using personal data. However, where applicable laws (for example, in the European Economic Area or the United Kingdom) require such categorization, the processing of personal information for the purposes described in this Policy is generally based on one or more of the following legal grounds:

-Performance of a Contract: To create and manage your account, authenticate your access, provide Platform functionality, process payments, and fulfill our obligations under applicable agreements with you - Compliance with Legal Obligations: For example, in relation to accounting, tax, anti-fraud, anti-money laundering regulations (where applicable), or other mandatory regulatory requirements

-Legitimate Interests: To operate, secure, and improve the Platform, manage relationships, conduct business analytics, and ensure data protection and information security, provided that such interests are not overridden by your rights and freedoms

-Your Consent: Where required by applicable law (for example, for newsletters, certain types of online tracking, or other non-essential cookies)

4.2 Where laws of a particular jurisdiction require separate or explicit consent for certain types of processing, we will request such consent in an appropriate form before carrying out that processing. These legal bases and consent requirements apply only where and to the extent required by the laws of the relevant jurisdiction.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and processed, as described in this Policy, or for as long as required by applicable laws and regulations. For example, in accounting and tax contexts, certain transaction data may need to be retained for several years and, in some cases, up to ten (10) years or such other period as the law may require. In some jurisdictions, applicable law may also require that certain records be retained in a particular form or location; where this is the case, we will comply with those requirements.

After the relevant retention period has expired, we will take reasonably practicable steps to delete or anonymize personal information so that it can no longer be associated with an identified or identifiable individual.

-If you close your account, we will deactivate it and schedule your personal information for deletion or anonymization, unless a longer retention period is required or permitted by law (for example, for compliance, accounting, fraud prevention, or dispute resolution purposes)

-For individuals whose accounts remain active or who engage with the Platform, we will retain personal information associated with their account for operational purposes unless a longer retention period is mandated by applicable law

We take reasonably practicable steps to protect personal information against unauthorized or accidental access, processing, erasure, loss, or use, in accordance with the PDPO and, where applicable, other data protection laws. Measures we apply include, among others:

-Access controls and the "need-to-know" principle for staff and contractors handling personal information

-Authentication and password requirements for user accounts

-Technical and organizational safeguards to protect our IT systems and infrastructure, including, whereappropriate, encryption or pseudonymization

-Use of reputable hosting and service providers bound by contractual confidentiality and data protectionobligations

-Internal policies, procedures, and staff training on data protection and information security

-Periodic reviews of our data processing practices and security measures

While we strive to protect personal information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we aim to maintain protection appropriate to the risks associated with our handling of personal information. You are responsible for keeping your account credentials confidential and should not share them with third parties. If you believe that your account or personal information may have been compromised, please contact us using the details in the "Contact Information" section.

6.1 We treat personal information as confidential and will not disclose it to third parties except as described in this Policy or where disclosure is required or permitted by applicable law.

We may share personal information with trusted third-party service providers who assist us in operating the Platform, conducting our business, or servicing users. These service providers may include:

-Payment processors and financial institutions

-Cloud hosting and infrastructure providers

-IT support and software development contractors

-Analytics and marketing service providers

-Legal, accounting, and professional advisors

These third parties are authorized to use personal information only as necessary to provide their services to us and are contractually obligated to maintain appropriate confidentiality and data protection measures.

We may disclose personal information when required or permitted by law, including:

-In response to lawful requests by public authorities (for example, law enforcement or regulatory agencies)

-To comply with legal obligations, court orders, or legal processes

-To protect our rights, property, or safety, or the rights, property, or safety of our users or the public

In the event of a merger, acquisition, reorganization, sale of assets, or similar business transfer, personal information may be transferred to the acquiring or successor entity, provided that appropriate safeguards are in place to protect your personal information in accordance with this Policy and applicable law.

We may share personal information with third parties when you have provided your consent to do so, for example, when you authorize us to share information with a partner or third-party service provider.

Personal information may be stored and processed on infrastructure operated by our verified hosting providers, which may be located outside Hong Kong, in countries or regions where we or our service providers operate. In some jurisdictions, applicable law may require that certain personal information be stored on servers located within that jurisdiction; where this is the case, we comply with such requirements.

Where personal information is transferred to a location outside Hong Kong, we will take reasonably practicable steps to ensure that the recipient provides a level of protection comparable to the requirements of the PDPO or that appropriate safeguards are in place.

If you are located in the European Economic Area or the United Kingdom, personal information may be transferred to countries that do not provide the same level of data protection as the EEA/UK. In such cases, we implement appropriate safeguards, such as standard contractual clauses or equivalent measures, to ensure that your personal information remains protected.

If you would like more information about the safeguards used for international transfers, you may contact us using the details provided in the "Contact Information" section.

Under the PDPO, you have the right to:

-Request confirmation as to whether we hold personal information about you and to access such information

-Request the correction of personal information that is inaccurate, incomplete, or outdated

If you are located in a jurisdiction with additional data protection rights (for example, the European Economic Area or the United Kingdom), you may also have the right to:

-Request erasure of your personal information (the "right to be forgotten")

-Request restriction of processing

-Object to processing based on legitimate interests

-Request data portability

-Withdraw consent (where processing is based on consent)

-Lodge a complaint with a supervisory authority

To exercise any of your rights, please contact us using the details provided in the "Contact Information" section. We may request additional information to verify your identity before responding to a request, particularly where sensitive data or a large volume of data is involved. We may decline requests where permitted or required by law, including where a request is manifestly unfounded or excessive, where it would adversely affect the rights and freedoms of others, or where we are required to retain certain data for legal, regulatory, accounting, or fraud-prevention purposes.

9.1 The Platform is not intended for children under the age of 14, and we do not knowingly collect personal information from children under this age. If we become aware that personal information has been collected from a child under 14 without appropriate consent or authorization (where required by law), we will take reasonably practicable steps to delete such information.

If you are a parent or guardian and believe that a child has provided personal information to us, please contact us using the details listed in the "Contact Information" section.

10.1 If you have questions about this Policy, wish to exercise your rights, or would like to submit a request or complaint, you may contact our Data Privacy Officer:

Michael Chan Address:

Room 701, 7/F Lucky Centre, 165-171 Wanchai Road, Wan Chai, Hong Kong

10.3 We will use reasonable efforts to respond to your request within a reasonable time and in accordance with applicable laws.

11.1 We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. The version of this Policy that applies to our processing of personal information is the one currently published on the Platform and on our website (https://solopay.pro/policy).

11.2 When we update this Policy, we will publish the revised version at the top of the document. We may, at our discretion or where required by applicable law, provide additional notice of material changes (for example, by displaying a notice on the Platform or sending an email), but we are not obligated to do so in all cases.

11.3 We encourage you to review this Policy periodically to stay informed about how we collect, use, and protect personal information. By continuing to use the Services after an updated version of this Policy has been published, you are deemed to have read and understood the updated Policy. If you do not agree with the updated Policy, you should stop using the Services and may request deletion of your account.