Privacy Policy

Smart Galas Limited

Registered in Hong Kong

Registered Address: Unit 1802, 18/F, Hua Fu Commercial Building, Sheung Wan, Hong Kong

Email: privacy@smartgalas.com

Who We Are

Smart Galas Limited (“Smart Galas”, “we”, or “us”) provides an online fundraising platform and bidding facility to connect sellers, bidders, and client charities or companies hosting auctions.

We are a company registered in Hong Kong. Our fundraising platform is powered by a technology partner based in the United Kingdom, Emma Live Ltd (“Emma Live”), which acts as the primary data processor. Emma Live handles the processing of personal data on our behalf to deliver the platform’s functionality.

This privacy policy explains how, why, and when we process your personal data, your rights regarding your information, and the roles of our technology partner and event organisers.

Data Controllers and Processors

For data protection inquiries relating to the operation of the platform, you may contact our technology partner’s Data Protection Officer:

Jonathan Douglas

Email: jd@emma-live.com

For inquiries relating to Smart Galas or this privacy policy, please contact us at:

Smart Galas Limited – Privacy Office

Email: privacy@smartgalas.com

Information That We Collect

We process your personal information to provide our fundraising and auction services. We will never collect any unnecessary personal data from you, and we do not process your information in any way other than as specified in this policy.

The personal data that we collect includes:

• First and Last Name
• Email Address
• Phone Number
• Billing and Shipping Address
• Organisation Name (where applicable)
• Payment Information (processed securely by our payment processor)

We collect information through online forms on the Smart Galas platform, which is operated by our technology partner, Emma Live.

How We Use Your Personal Data

We take your privacy very seriously. Other than to provide our services and as described in this policy, we will never disclose or share your data without your consent unless required to do so by law.

We only retain your data for as long as is necessary and for the purposes specified in this policy. Where you have consented to receiving promotional offers and marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data are detailed below:

• To provide auction and fundraising services and to ensure that any funds given to our charity or corporate clients are collected;
• To facilitate the delivery of items you have purchased to your preferred address by our sellers;
• To keep you updated on the progress of the event, auction, or campaign in which you are participating (via email and SMS, processed by our technology partner);
• To maintain business accounting and tax records as required by applicable law;
• Very occasionally, to send you service-related information without your prior consent, but only where we have assessed that it is beneficial to you as a user and in our legitimate interests. Such information will be non-intrusive.

Your Rights

You have the right to access any personal information that we process about you and to request information about:

• What personal data we hold about you and the purposes of the processing;
• The categories of personal data concerned;
• The recipients to whom the personal data has been or will be disclosed;
• How long we intend to store your personal data;
• If we did not collect the data directly from you, information about the source.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information. We will strive to correct it as quickly as possible.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with applicable data protection laws, to exercise your data portability rights, and to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we will ask you to verify your identity before acting on the request. This is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this policy or where there is a legal requirement.

In addition to sharing your data with the event organiser (client) for each auction, we use third-party processors to provide the services and business functions below. All processors acting on our behalf process your data in accordance with our instructions and comply fully with this privacy policy and applicable data protection laws.

Our Technology Partner (Primary Processor)

Payment Processing

Fulfilment and Voucher Services

Marketing and Communications

Where you have consented to us using your data for marketing purposes, we may share it with:

Lot Suppliers (Sellers)

Where you have successfully bid for an item, we will share your details with the relevant lot supplier (seller) so that they may provide you with the item. Lot suppliers change on a regular basis and process your data independently as data controllers.

Safeguarding Measures

We take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction. Security measures in place include:

• Encryption to protect against physical theft or loss;
• Encryption when sending data over public networks to prevent interception or tampering;
• Up-to-date security software to prevent malware and external threats;
• Strict permission controls to ensure access only by authorised persons.

Our technology partner, Emma Live, maintains security measures aligned with UK and EU standards.

Transfers Outside Hong Kong

As a Hong Kong-based company, we utilise technology and service providers located in the United Kingdom, the European Union, and the United States. This means that your personal data may be transferred to and processed in jurisdictions outside Hong Kong.

Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Data processing agreements incorporating standard contractual clauses;
• Compliance with applicable data protection laws in the jurisdictions where our processors operate;
• Ensuring that our UK-based technology partner adheres to UK GDPR standards.

The following processors host or store data outside Hong Kong:

• HubSpot (servers located in the United States)
• Stripe (operates globally with data transfers in accordance with their compliance frameworks)

How Long We Keep Your Data

We only retain personal information for as long as is necessary, and we have strict review and retention policies in place to meet these obligations.

• Auction Participation: Where you have taken part in an auction, we will keep your data for a period of 3 years for accounting purposes and to reference the event for you, the event organiser, or ourselves.
• Purchases: Where you have purchased an item, we retain your basic personal data (name, address, contact details) for a minimum of 6 years in compliance with applicable tax and accounting laws, after which time it will be securely destroyed.
• Marketing: Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Marketing

Consent

Occasionally, we would like to contact you about new services that we believe will be of genuine interest to you. If you consent to us using your contact details for these purposes, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting us directly at privacy@smartgalas.com.

Legitimate Interest

We process your personal information to enable us to provide our products and services in a workable, proper, and professional manner.

We may very occasionally send you product or service updates by email where we have identified that such information is beneficial to our customers and in your interests. Such information will be relevant to you as a user, non-intrusive, and you will always have the option to opt out or unsubscribe at any time.

Lodging a Complaint

We only process your personal information in compliance with this privacy policy and in accordance with applicable data protection laws.

If you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please contact us first at:

Smart Galas Limited – Privacy Office

Email: privacy@smartgalas.com

If you are located in Hong Kong, you may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) :

Office of the Privacy Commissioner for Personal Data

12/F, 248 Queen’s Road East, Wan Chai, Hong Kong

Email: enquiry@pcpd.org.hk

Website: www.pcpd.org.hk

If you are located in the United Kingdom or the European Union and your data is processed by our UK-based technology partner, you may also lodge a complaint with the UK Information Commissioner’s Office (ICO) :

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, SK9 5AF, United Kingdom

Website: https://ico.org.uk/concerns/

Cookie Policy

Information About Our Use of Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small information file that is sent to your computer, mobile, or other device when you visit a website and it will recognise your device on future visits. These types of files perform a number of different functions, such as remembering your preferences and chosen items, assisting you to improve your site experience, and ensuring that advertisements or offers you see online are more relevant to you.

Types of Cookies We Use

Please note that third parties (including advertising networks and providers of external services such as web traffic analysis) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

Acceptable Use Policy

This acceptable use policy sets out the terms between you and Smart Galas Limited (“we” or “us”) under which you may access our fundraising platform and website. This acceptable use policy applies to all users of, and visitors to, our site and platform.

Your use of our site means that you accept, and agree to abide by, all the policies in this acceptable use policy, which supplement our terms and conditions.

Prohibited Uses

You may use our site and platform only for lawful purposes. You may not use our site or platform:

• In any way that breaches any applicable law or regulation, or is fraudulent;
• For the purpose of harming or attempting to harm minors in any way;
• To transmit, or effect the sending of, any unsolicited or unauthorised advertising or promotional material or similar (spam);
• To knowingly transmit any data, send, or upload any material that contains viruses, Trojan horses, worms, time bombs, keystroke loggers, spyware, adware, or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• Not to reproduce, duplicate, copy, or re-sell any part of our site or platform in contravention of the provisions of our terms and conditions;
• Not to access without authority, interfere with, damage, or disrupt:
  • any part of our site or platform;
  • any equipment or network on which our site or platform is stored;
  • any software used in the provision of our site or platform; or
  • any equipment, network, or software owned or used by any third party.

Suspension and Termination

We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our site or platform. When a breach of this policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this acceptable use policy constitutes a material breach of the terms upon which you are permitted to use our site and platform, and may result in our taking any or all of the following actions:

• Immediate, temporary, or permanent withdrawal of your right to use our site and platform;
• Issue of a warning to you;
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach;
• Further legal action against you;
• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

We exclude liability for actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

Changes to the Acceptable Use Policy

We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our site.

Changes to This Privacy Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

Acceptance of Privacy Policies

By using our event, auctions, and fundraising platform, you agree to:

1. These terms and conditions;
2. The Privacy Policy of the platform technology provider, Emma Live Ltd, available at:
   https://www.emma-live.com/privacy.html;
3. The privacy policy of the event organiser (client) hosting the auction in which you participate.

If you have any questions about these privacy policies, please send an email before using the platform and/or signing up to:

privacy@smartgalas.com

Last Updated: 25th March 2026

Smart Galas Limited

Registered Business Address:

Unit 1802, 18/F, Hua Fu Commercial Building, Sheung Wan, Hong Kong

Office Number: +852 2877 6278

Email: info@smartgalas.com

Privacy Inquiries: privacy@smartgalas.com