This Privacy Notice explains how Robotic Online Intelligence Ltd ("ROI", "we", "us", "our") collects, uses, shares and protects personal data when you interact with us — including when you visit our website(s) at www.roboticonline.ai, www.kubro.net, www.kubrosearch.com, www.signallium.com, www.gbaintelligence.com (the "Website(s)"), contact us, subscribe to our communications, or use our products and services (including the Signallium™ China Property Web Application).
This Notice is provided in accordance with:
This Notice covers the personal data we Process as a controller — meaning where we decide why and how your personal data is used. Where we Process personal data on behalf of a business customer (for example, data about users of the Signallium™ China Property Web Application whose employer has contracted with us), we act as a processor and a separate Data Processing Addendum applies between us and that customer. If you are a user of our products and services (including the Signallium™ China Property Web Application), your employer's privacy notice will generally be the primary notice that applies to you.
Data Controller: Robotic Online Intelligence Ltd
Address: Suite 10, 7/F, Houston Centre, 63 Mody Road, Kowloon, Hong Kong SAR
Email for privacy matters: privacy [at] roboticonline.ai
We have not appointed a Data Protection Officer. We are a Hong Kong-established company and have not appointed a UK representative under Article 27 UK GDPR, on the basis that our Processing of UK individuals' personal data is limited in scope and does not constitute the offering of goods or services to, or the monitoring of the behaviour of, UK data subjects in the manner envisaged by Article 3(2) UK GDPR.
We Process personal data about the following categories of individuals, for the purposes and on the legal bases described below.
What we collect: name, job title, business email address, business telephone number, business postal address, company name, and any business information you choose to share with us (for example, in an enquiry).
How we collect it: directly from you when you contact us, complete a form on our Website, exchange business cards, engage with us at conferences or events, or enter into a contract with us; and occasionally from professional networks (such as LinkedIn) or publicly available business directories for the purpose of initiating a business conversation.
Why we Process it:
Legal bases (UK GDPR):
Lawful basis under PDPO: the data is collected for purposes directly related to our business function of providing subscription services and communicating with our customers and prospective customers.
What we collect: name, email address, and any preferences or interests you indicate.
How we collect it: when you subscribe to our newsletter or marketing communications via the Website or otherwise opt in.
Why we Process it: to send you newsletters, research notes, product updates and other marketing communications you have subscribed to; to manage your preferences and unsubscribe requests.
Legal bases (UK GDPR):
What we collect: technical information such as IP address, browser type and version, operating system, referral source, pages visited, time spent, and other usage data.
How we collect it: automatically via standard server logs when you visit the Website, and via cookies and similar technologies where you have consented to their use.
Why we Process it: to operate and secure the Website; to understand how visitors use the Website and improve it; and (where applicable) to support marketing analytics.
Legal bases (UK GDPR): our legitimate interests in operating and improving the Website and in Website security (Article 6(1)(f)); and, for non-essential cookies, your consent (Article 6(1)(a) and PECR).
Please see our Cookie Notice for more details about cookies and how to manage your preferences.
When individuals use our products and services including the Signallium™ China Property Web Application on behalf of a customer organisation, we Process their personal data primarily as a processor on that customer's behalf. That Processing is governed by the Data Processing Addendum between us and the customer and, where applicable, by the customer's own privacy notice.
However, to a limited extent we also Process certain data as controller in connection with operating the Web Application — including aggregated and de-identified usage analytics for product improvement, security monitoring for our own legitimate interests, and compliance with our legal obligations.
Legal bases (UK GDPR): our legitimate interests in operating, securing and improving the Web Application (Article 6(1)(f)); and compliance with legal obligations (Article 6(1)(c)).
Our Website uses cookies and similar technologies (such as local storage and tracking pixels) to operate the Website, to understand how visitors use it, and — where you have consented — for analytics and marketing purposes.
What are cookies? Cookies are small text files that are placed on your device when you visit a website. They allow the website to recognise your device, remember preferences, and collect information about your use of the site.
The categories of cookies we use:
Managing your cookie preferences. When you first visit the Website, you will be presented with a cookie banner allowing you to accept, reject, or manage non-essential cookies. You can change your preferences at any time by clicking the 'Cookie Preferences' link in the Website footer. You can also disable or delete cookies through your browser settings, though this may affect the functionality of the Website.
Third-party cookies. Where third parties (such as analytics providers) set cookies on our Website, those third parties may collect personal data about your visit. Please see the respective third party's privacy policy for more details.
Retention. Different cookies have different expiry periods. Session cookies are deleted when you close your browser. Persistent cookies remain until their expiry date or until you delete them. Details of the cookies we use, their purposes and retention periods are available in our cookie banner settings.
We share personal data with the following categories of recipients, only where necessary for the purposes described above:
We do not sell personal data to third parties.
We are established in Hong Kong SAR and some of our service providers are located outside the UK and the European Economic Area. Where we transfer personal data from the UK to a country that is not covered by UK adequacy regulations, we put in place appropriate safeguards as required by UK Data Protection Laws — typically the UK International Data Transfer Agreement (or the EU Standard Contractual Clauses with the UK Addendum) issued by the UK Information Commissioner — and we rely, where applicable, on the UK Extension to the EU-US Data Privacy Framework for transfers to certified US organisations.
You can request further information about our international transfer safeguards, or a copy of the relevant safeguards, by contacting us using the details in Section 2.
We keep personal data only for as long as we need it for the purposes described above, taking into account legal, accounting, regulatory and contractual requirements. As a general guide:
Depending on the law that applies to our Processing of your personal data, you have the following rights:
Under UK Data Protection Laws, you have the right to:
Under the PDPO, you have the right to:
To exercise any of these rights, please contact us using the details in Section 2. We will respond within the timeframes required by the applicable law (generally one month under UK GDPR, and 40 days under the PDPO). There is normally no fee, but we may charge a reasonable fee or refuse to respond in the limited circumstances permitted by law (for example, where a request is manifestly unfounded or excessive).
We take appropriate technical and organisational measures to protect personal data against unauthorised or unlawful Processing, accidental loss, destruction or damage. These measures include access controls, encryption in transit and at rest, secure cloud infrastructure, personnel training, and vendor due diligence. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security; however, we take reasonable steps to protect your personal data and to notify affected individuals and regulators of any Personal Data Breach where required by law.
We do not use personal data to make decisions about you based solely on automated Processing (including profiling) that produce legal effects concerning you or similarly significantly affect you.
Our services are directed at businesses and business professionals. We do not knowingly collect personal data from children under the age of 18. If you believe we have collected personal data from a child, please contact us so we can take appropriate action.
We may update this Notice from time to time to reflect changes in our Processing activities or legal requirements. The "Last updated" date at the top of this Notice indicates when it was last revised. Where changes are material, we will bring them to your attention by appropriate means (such as an email to our contact list or a prominent notice on the Website).
If you have any questions about this Notice or our Processing of your personal data, please contact us at:
Robotic Online Intelligence Ltd
Suite 10, 7/F, Houston Centre, 63 Mody Road, Kowloon, Hong Kong SAR
Email: privacy [at] roboticonline.ai