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Privacy Policy

Last updated 2026-08-30

1. Data Controller Statement

ClearClaim ("the Website", "the Platform") is a proprietary SaaS prototype operated by Base Creative Consultants Co. Ltd, registered in Hong Kong ("we", "us", "our"). We are committed to protecting your personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and applicable international data protection standards.

2. Personal Data We Collect

Under the Data Protection Principles of the PDPO, we collect only personal data that is necessary, adequate, and not excessive for the purpose of demonstrating, testing, and evaluating the ClearClaim prototype. This includes:

  1. Account & Contact Data: Name, business email address, company name, job title, and phone number when you register for prototype access or contact us.
  2. Platform & Service Usage Data: Textile claims data, claim descriptions, supporting images/documents, and feedback submitted during prototype testing.
  3. Technical Data: Basic system metrics, IP address, browser type, and server request logs necessary strictly for hosting and security. (Note: We do not currently use Google Analytics or non-essential tracking cookies on this prototype).

3. Purpose of Data Collection

We collect and process your personal data strictly for the following purposes:

  1. To provide access to, demonstrate, and test the ClearClaim SaaS prototype.
  2. To communicate with you regarding your feedback, inquiries, or support requests.
  3. To refine, develop, and improve the ClearClaim platform features and user interface.
  4. To prepare for the commercial launch and future legal incorporation of ClearClaim.

4. Direct Marketing

We will not use your personal data for direct marketing purposes unless we have received your explicit opt-in consent. If you consent, we may send you updates regarding the full commercial release, features, and incorporation of ClearClaim. You may opt out of receiving direct marketing communications at any time by contacting us or using the unsubscribe link provided in our emails.

5. International Data Transfers & European Union (GDPR) Notice

ClearClaim is operated out of Hong Kong. If you access or test the prototype from outside Hong Kong, including from the European Economic Area (EEA), United Kingdom, or Switzerland, please note that your personal data may be transferred to, stored, and processed in Hong Kong or other locations where our cloud servers are hosted.

For users in the EEA/UK, processing is based on our legitimate interest in demonstrating and developing the prototype or for performance of a contract/pre-contractual steps. Where personal data is transferred internationally, we ensure appropriate safeguards are implemented in compliance with General Data Protection Regulation (GDPR) requirements to protect your privacy rights.

6. Transfer and Disclosure of Data

Your data will be handled confidentially. We will not sell, rent, or trade your personal data. We may share or transfer your personal data only under the following circumstances:

  1. Corporate Restructuring: Upon the formal incorporation of ClearClaim as a separate legal entity, all prototype data (including personal data) will be transferred to the new ClearClaim entity.
  2. Third-Party Service Providers: To cloud hosting and infrastructure service providers acting on our behalf under strict confidentiality agreements.
  3. Legal Requirements: When required by applicable law, court order, or governmental authority in Hong Kong or other applicable jurisdictions.

7. Data Retention, Security, and Your Rights

We implement reasonable security safeguards to prevent unauthorized access, processing, erasure, loss, or use of personal data. Data collected for this prototype will be retained only as long as necessary to fulfill the purposes outlined above, after which it will be securely erased or anonymized.

Under the HK PDPO (and where applicable, GDPR), you have the right to request access to, correction of, or erasure of the personal data we hold about you. To exercise these rights or make a privacy query, contact us at:

  1. Entity: Base Creative Consultants Co. Ltd
  2. Email: info@basecreate.com
  3. Address: 1908 - 1909, 19/F, Dominion Centre, 43-59 Queen's Road East, Wan Chai, Hong Kong