Legal · draft
Privacy policy
Operational draft for SplitzFPS (Personal Information Collection Statement + Privacy Policy Statement). Not legal advice, not a solicitor opinion, and not a substitute for Hong Kong counsel. Last updated 16 September 2026.
Who the data user is
SplitzFPS is a Hong Kong bill-splitting PWA operated by Kendrick Ching (sole proprietor). Contact for access, correction, erasure, and marketing opt-out: ascendbeyond@proton.me.
Why we collect (PICS)
We collect personal data only to run SplitzFPS: create and secure your account, do split maths on receipts you upload, generate an FPS/PayMe link or QR from an identifier you already own, charge our own software subscription via Stripe, and send service messages (OTP, password reset, billing receipts for our fee). Direct marketing is a separate, optional purpose.
- Email — obligatory for an account. Without it we cannot log you in, confirm the address, or send security and Stripe receipts for our SaaS fee.
- Name — voluntary.
- HK mobile — voluntary unless you want it as an FPS alias. Not required to create an account.
- FPS / PayMe identifier — only if you use settle. We encode what you type; we do not open a wallet or take the dinner money.
- Receipt images and split history — only if you scan or save a split. Images may include other diners; do not upload others’ data without a basis to do so.
- We do not collect HKID, full bank account numbers, or card PAN. Card details stay with Stripe.
What we hold
- Account: name, email, optional HK mobile, language.
- Auth: password hashes via Supabase (we do not store raw passwords).
- Billing: Stripe customer and subscription IDs for SplitzFPS plan fees in HKD. Stripe is our software-subscription processor, not a path for dinner money.
- Splits: receipts you upload, dish lines, amounts in HKD, FPS / PayMe identifiers you type, group names.
- Device / logs: short operational auth and security logs.
- Marketing flags: only if you tick a separate box for email and/or SMS.
Classes of persons we may transfer data to
Named classes, not “partners”: hosting (Vercel), auth and database (Supabase), payments (Stripe), email delivery (Supabase). Those processors may store data outside Hong Kong. We do not sell lists. We do not provide your data to a third party for their direct marketing.
SMS marketing is not active. If it is ever enabled, it would use a licensed sender, still require a separate SMS opt-in, and would need a Do-not-call Short Messages Register process. We are not starting SMS marketing with this draft.
FPS is information-only
SplitzFPS generates a link or QR for an FPS/PayMe identifier you already registered with your bank. Payers pay each other in their own banking apps. SplitzFPS does not take, hold, pool, or pay out dinner money, does not run a wallet or stored-value balance, and does not collect into the app. Stripe HKD charges are SplitzFPS SaaS fees (Free / Standard / Pro / Founding), not settlement of the bill.
Direct marketing (PDPO Part VIA) and unsubscribe (UEMO)
We intend to use personal data for direct marketing only if you consent. We may not so use it unless we have received that consent. Silence is not consent. Marketing is not a condition of creating an account or buying a plan.
- Kinds of data: name, email, and (only if you also opt in to SMS) phone number.
- Classes of marketing subjects: SplitzFPS plans, features, and HK$ promotions — not other companies’ offers.
- Response channel: untick the box at signup, or email ascendbeyond@proton.me with “stop marketing”.
You can require us to stop, without charge. We will honour an unsubscribe or PDPO cease request. For commercial electronic messages we aim to stop within 10 working days. First marketing email (if you opted in) will repeat that you can stop for free. Transactional mail (OTP, “your split”, Stripe receipt for our fee) will not carry upgrade ads.
Access, correction, retention
You may request access to or correction of your personal data by emailing ascendbeyond@proton.me. If we hold the data, PCPD guidance is to supply an intelligible copy within 40 calendar days of a data access request (or say in writing that we hold none). We keep account and split data while the account is open, then delete or anonymise when no longer needed for that purpose. Stripe billing records follow Stripe and tax-record needs. Marketing opt-out logs are kept longer than marketing lists. Auth logs are rotated on a short operational window.
Cookies and tracking
Hong Kong has no GDPR-style cookie statute in the materials we used. We use first-party session / auth cookies so you can stay signed in. They are needed for login. We do not currently run advertising pixels. If we add analytics or ads later, this page will name them.
Security and children
We use access controls (including database RLS) so users cannot self-upgrade a plan row, and we do not store card PAN. SplitzFPS is intended for adults. Do not create an account for a child.
Complaints
Write to us first at the email above. You may also contact the Office of the Privacy Commissioner for Personal Data (PCPD): pcpd.org.hk.
粵語摘要
我哋收集電郵係為咗開戶、保安同我哋自己嘅 Stripe 月費／創始費收據，唔係收齊枱數。手機同市場推廣都係可選，唔剔都可以開戶。我哋唔收香港身份證。FPS／PayMe 連結只係資料；錢喺你同朋友嘅銀行 App 過。想查閱或者改正資料、或者停推廣，電郵 ascendbeyond@proton.me，唔使錢。