Privacy Policy

Last updated: 1 June 2026

GDPR compliant HK PDPO compliant Minimal data collection No data selling — ever
Section 1

Who We Are

BrandON ("we", "us", "our") operates the website brandon.promo and the BrandON mobile app. We aggregate promotional offers from Hong Kong retailers and deliver them to users via the website, app, and optional weekly email digest.

This Privacy Policy explains how we collect, use, store, and protect your personal data, and your rights under the EU General Data Protection Regulation (GDPR) and the Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap. 486).

Section 2

What We Collect

We collect the minimum data necessary to provide our services:

  • Email address — collected only when you voluntarily subscribe to BrandON Weekly Digest.
  • Usage data — anonymised page views, device type, and browser via Google Analytics 4, Microsoft Clarity, and PostHog. This data does not identify you individually.
  • Cookie data — session identifiers and preference cookies (see Section 7).

We do not collect your name, phone number, address, payment information, or any other sensitive personal data.

Section 3

Lawful Basis

  • Email newsletter: Collected with your explicit consent (GDPR Art. 6(1)(a); PDPO Section 26 direct marketing consent). You can withdraw consent at any time.
  • Analytics: Legitimate interest in improving our service (GDPR Art. 6(1)(f)), with anonymisation measures to minimise privacy impact.
Section 4

The BrandON Weekly Digest

When you subscribe to BrandON Weekly Digest:

  • Your email is stored by Brevo SAS (formerly Sendinblue, our email service provider, based in France). We have a data processing agreement with Brevo ensuring GDPR-compliant handling.
  • Every email we send includes a one-click unsubscribe link. Clicking it removes you from our list immediately and permanently.
  • We will never sell, rent, or share your email address with third parties for marketing purposes.
  • We send one email per week (Tuesday). We may send occasional service notices (e.g. major changes to this policy).
Section 5

Direct Marketing (PDPO §26)

Under Hong Kong's PDPO, you have the right to opt out of receiving direct marketing communications from us at any time. To exercise this right, click the unsubscribe link in any email or contact us at the address below. We will process your opt-out within 10 business days.

Section 6

Data Retention

  • Email subscribers: Retained until you unsubscribe. Unsubscribed emails are kept on a suppression list to prevent accidental re-subscription.
  • Analytics data: Retained for 14 months in Google Analytics (our standard retention setting), 1 year in PostHog, then automatically deleted.
Section 7

Cookies

  • Functional cookies: Remember your language preference and whether you have dismissed the subscribe bar (session-scoped, expire when you close the browser).
  • Analytics cookies: Google Analytics 4 (_ga, _ga_*), Microsoft Clarity, and PostHog cookies, used to measure aggregate traffic. These do not identify you personally.

You can disable cookies in your browser settings. Disabling analytics cookies will not affect your ability to browse deals on the site.

Section 8

Third-Party Services

Brevo
Email delivery & list management
Privacy policy ↗
Google Analytics 4
Web analytics
Privacy policy ↗
Microsoft Clarity
UX heatmaps & session recording
Privacy policy ↗
Cloudflare
CDN and edge computing
Privacy policy ↗
PostHog
Product analytics & session replay
Privacy policy ↗
Section 9

Your Rights

Under GDPR (and equivalent PDPO rights), you have the right to:

Access Request a copy of your personal data.
Rectification Correct inaccurate data we hold.
Erasure Request deletion of your data.
Restriction Pause processing in certain cases.
Portability Receive data in machine-readable format.
Object Object to legitimate-interest processing.
Withdraw consent Opt out of newsletter at any time.

To exercise any of these rights, contact us below. We will respond within 30 days.

Section 10

International Transfers

Your email address is processed by Brevo SAS, headquartered in France (EU). As an EU-based processor, Brevo is directly subject to GDPR and no additional transfer mechanism is required.

Section 11

Policy Changes

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page will reflect any changes. For material changes, we will notify email subscribers by email.

Questions about your privacy?

We're happy to help with data requests, corrections, or any questions about this policy.

Send us a message

Website: brandon.promo

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