This Privacy Policy explains how THINKING FROG LIMITED ("Company", "we", "us" or "our"), a company incorporated in Hong Kong, collects, uses, discloses and protects personal data in connection with the BrightThink AI website at brightthink.net and related services (the "Services"). We are committed to handling personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and other applicable data protection laws.
1. Who we are
BrightThink AI is a brand and product operated by THINKING FROG LIMITED. THINKING FROG LIMITED is the data user (as defined in the PDPO) responsible for the personal data described in this Policy. You can contact us at [email protected].
2. Personal data we collect
- Information you provide: name, company name, work email address, phone number, job title, and the contents of any message or enquiry you send us through the contact form or by email.
- Account and billing information: if you sign up for a paid plan, we collect billing contact details and transaction records. Payment card details are processed by our payment service providers and are not stored on our systems.
- Usage and technical data: IP address, browser type and version, device identifiers, pages visited, referring URLs, language preference, and similar data collected automatically when you use the website.
- Content you submit to the Services: data, documents and knowledge-base material you upload to build or operate agents. We process this content only to provide the Services to you.
3. How we use personal data
- To provide, operate, maintain and improve the Services;
- To respond to enquiries, demo requests and support tickets;
- To create and administer accounts, process payments and issue invoices;
- To send service communications, and (where you have consented or where permitted by law) marketing communications, which you may opt out of at any time;
- To monitor security, prevent fraud and abuse, and enforce our Terms of Use;
- To comply with legal obligations, including anti-money-laundering, tax and record-keeping requirements.
4. Legal basis and consent
We collect personal data on a voluntary basis. Where the PDPO or other applicable law requires consent for a particular use (for example, direct marketing), we will obtain your consent before doing so. Failure to provide certain personal data may mean we are unable to provide the Services to you.
5. Disclosure of personal data
We do not sell personal data. We may share personal data with:
- Service providers who host our infrastructure, process payments, provide analytics, or deliver email on our behalf, under contractual obligations of confidentiality and data protection;
- Cloud and AI infrastructure partners (including Amazon Web Services and large-language-model providers) to the extent necessary to operate the Services;
- Professional advisers such as auditors, lawyers and bankers, on a need-to-know basis;
- Regulators, courts and law-enforcement agencies where required by law or to protect our rights;
- A successor entity in connection with a merger, acquisition or sale of assets, subject to this Policy.
6. International transfers
Our Services are operated from Hong Kong and use infrastructure located in other jurisdictions, including Singapore, the United States and Japan. Where personal data is transferred outside Hong Kong, we take reasonable steps to ensure it receives a level of protection comparable to that required under the PDPO.
7. Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to provide the Services, and to comply with legal, accounting and regulatory requirements. Usage logs are typically retained for no longer than 12 months. Content you upload to the Services is deleted or anonymised within 30 days after your account is closed, unless a longer period is required by law.
8. Security
We use administrative, technical and physical safeguards appropriate to the sensitivity of the data, including encryption in transit and at rest, access controls, and logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Cookies and similar technologies
The website uses strictly necessary cookies and local storage (for example, to remember your language preference). We do not currently use third-party advertising cookies. You can control cookies through your browser settings; disabling them may affect some features of the website.
10. Your rights
Under the PDPO you have the right to request access to, and correction of, personal data we hold about you. You may also ask us to stop using your personal data for direct marketing. To exercise these rights, contact us at [email protected]. We may charge a reasonable fee for processing a data access request as permitted by the PDPO. Depending on your location, you may have additional rights under other laws, such as the right to erasure, restriction or portability, which we will honour where applicable.
11. Children
The Services are intended for business users and are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors.
12. Changes to this Policy
We may update this Policy from time to time. The "Effective date" above indicates when it was last revised. Material changes will be notified on the website or by email where appropriate.
13. Contact
THINKING FROG LIMITED
Hong Kong
Email: [email protected]