Privacy Policy Statement (PPS)

We are ReCube Limited (“ReCube”, “The Company”, “we”, “us” or “our”), but usually we just use the name ReCube or Re³. ReCube is a limited company incorporated and operated in Hong Kong, under Hong Kong regulation.

This Data Privacy Policy (“Policy”) explains how ReCube (“we”, “our”, “us”) collects, uses, stores, and protects personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) of Hong Kong.

We are committed to protecting the privacy of all visitors to our website and all visitors who access the website or services through any mobile application (including any social media channels) (together, “Sites”), and/or otherwise engage with us. Please read the following carefully to understand our policy and practices regarding how your Personal Information will be collected, treated and processed.

By visiting and/or using our services on the Sites or otherwise engaging with us, you agree (and, where required, you consent) to this privacy policy. This privacy policy applies to all personal data obtained by us through your use of our service. It does not apply to any websites controlled by third parties not affiliated with us that may be linked to our service(“Third Party Services”). The relevant privacy policies set out in the respective Third Party Services shall apply in those cases. If you are under the age of 18, you must have a legal representative such as a parent or guardian accepting this Policy on your behalf before providing any Personal Information to us.

For any clarification required on the definition of the terms, please refer to the Terms of Use (“Terms”) of the Company.

If there is any inconsistency between the English and Chinese version of this PPS, the English version shall prevail.

1. Contact Us

If you have any queries or requests about this privacy policy or how we handle your information more generally, you can get in touch by contacting:

Email: info@recube.hk

2. Right of modification

We reserve the right to change this privacy notice to ensure compliance with relevant legal and statutory provisions. Any changes to our Privacy Policy will be posted to the Sites and, where appropriate, through email notification.

Last update: August 2026

3. Information That We Collect From You

We collect two basic types of information, personal information and non-personal information. Personal information is information that you supply to us, as described more fully below, i.e., when you use our Services, obtain a subscription, complete a survey, register for the service, upload content, or provide your email address. Personal information is any information that can individually identify you and includes, among other things, your name, gender, email address, telephone number, postal address, Credit Card and Payment Platform Credentials, billing and contact information. Non-personal information includes information that does not personally identify you, but it may include tracking and usage information about your location, demographics, interests, use of the App and the Internet. This PPS does not restrict or limit our collection, use and provision of non-personal information.

3.1 Personal Information

As a general matter, you can browse our website or App without submitting your personal information to us. However, there are a number of circumstances in which you may supply us or our Third Party Services with your personal information. The following lists the most common ways in which we may collect your personal information.

Registration for an account for our services and Reward program on the website App and ReCube App
Use of the account through the website or App, including rental of Reusable Tableware and access of the Reward program
Payment information submitted to ReCube when renting a Reusable Tableware
Registration for an event sponsored by us and any particular (not limited to redeem, register, transfer, receive Reward Point(s) ‘ReCoin’) related to the Reward Program
Profile information that you provide for your user profile
Social media information that you authorize
Certain location data, as described below
Uploading Content to our website or App
Submitting an application to work at ReCube
Participation in surveys, contests, or sweepstakes
Sign up to receive alerts or other information via email, text or instant message from ReCube
Request for customer service, support requests or other assistance
Service related communications, e.g. account verification; technical notification
Submission of content or other data and information on any part of the ReCube website or the App for access to your personal information.

3.2 Non-Personal Information

When you use our websites and/or mobile applications, we may keep an activity log that does not identify you individually and cannot be used to identify the identity of any particular user. Generally, we collect and store the following categories of Non-Personal Information:

Information about your device that you use to access our websites and/or mobile applications. This information may include the device name, IP address, operating system and version, the type of network and mobile Internet browser you use, the browser’s type and configuration, the geo-location information and other unique device identifiers of the device, browsing preferences such as language settings and font size etc.; and
Information about your use of the website and/or mobile application including without limitation the domain names you visit and the specific actions you take on the website and/or mobile application, the number of new or returning visits, statistics on the pages visited and referred, a reading history of the pages and sites you have visited and viewed, search terms used and search results, error and crash statistics, traffic data (such as time, duration and date of access), interaction with other retail technology such as use of NFC Tags, QR Codes or use of mobile vouchers.

The above Non-Personal Information are collected and used to measure traffic, gauge the popularity of various parts of our websites and/or mobile applications, to gain general knowledge about our audience and market our websites and/or mobile applications to advertisers with whom we may share summarized traffic data. We may also share to third parties this Non-Personal Information for customizing, enhancing, optimizing, maintaining and/or improving the quality of our websites and/or mobile applications, such as for determining the optimal screen resolution, language and font settings, etc. This Policy in no way restricts or limits our collection, use, handling and provision of Non-Personal Information.

4. How Do We Use Your Information?

We use the information we learn from you to help us personalise and continually improve your experience on the App. We may use your Personal and Non-Personal Information in the following ways:

4.1 General Uses

To access and provide the ReCube Service and Reward Program to you as you request
To track the usage of Reusable Tableware and Reward Program, including but not limited to verifying the order record, payment transaction, etc.
To upload your content to our Website and/or App as you request
To permit you to update, edit, and manage your content on our Website and/or App
To communicate with you about your account or transactions with us (including service related announcements) and send you information about features and enhancements on our App
To communicate with you about changes to our policies
To personalize content and experiences on our App, including providing you reports, recommendations and feedback based on your preferences
To disclose anonymized Personal Information statistics and analytics and other details regarding the use of our Website and/or App.
To optimize or improve our products, services and operations
To automatically update the Website and/or App on your device
To detect, investigate, and prevent activities that may violate our policies or be illegal
To perform statistical, demographic, and marketing analyses of users of the Website and/or App

4.2 Use of Your Location Information

Specifically, we use your location information to:

Track the use of the ReCube Reusable tableware
Personalize content on our App, including providing you reports, recommendations and feedback based on your preferences
Optimize or improve our products, services and operations
Detect, investigate, and prevent activities that may violate our policies or be illegal
Perform statistical, demographic, and marketing analyses of users of the App and their purchasing patterns

4.3 Combination of Your Personal Information

We use the information from one portion of the App on other portions of the App or elsewhere in our network of Apps, apps, and other interactive features, or in reports and analysis, all of which are owned and operated by ReCube, and we may combine information gathered from multiple portions of the App into a single customer record or analysis or report. We also use and/or combine information that we collect off-line or we collect or receive from third party sources to enhance, expand, and =check the accuracy of your customer records.

4.4 Direct marketing
We intend to use your information (name, contact details, use of our services) for direct marketing on offers and promotions and we may contact you to do so by post, telephone, mobile or in-app messaging (e.g. in-app, push notifications, SMS, MMS etc.) as well as by email. We may also, for gain, provide your information to our partners for direct marketing. However, we may not do so unless we have received your consent. We obtain explicit confirmation from you to agree on the collection and usage of your information for direct marketing purposes. Where you have chosen at a device level to begin or continue receiving push notifications from us, we may send you push notifications relating to the services that you have requested from us and information about our services and offers. You can choose to stop receiving push notifications from us and the agreement on direct marketing at any time by changing your preferences on your mobile device or by getting in touch (see Contact Us).

If you do not want us to use your information described above or change your mind about being contacted in the future, please let us know by using the contact details set out above and/or amending your profile accordingly.

5. Disclosure and Transfer Of Your Information

Third party Services process information such as credit card payments and reward programme information and provide support services related to payments and our services for us. In addition, we may need to provide your information to any partners that you have placed your order with or otherwise deal with. By submitting your information, you agree to this transfer, storing or processing of the information. ReCube will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy.

You agree that we may allow selected third party marketing and advertising companies, our affiliated entities in the food, drink, groceries, leisure, transportation, payment services and advertising sectors, to contact you occasionally about services that may be of interest to you, including direct marketing. They may contact you by in-app notifications, push notifications, telephone, SMS as well as by email. If you change your mind about being contacted by these companies in the future, please let us know by using the contact details set out above and/or by amending your profile accordingly. We may also share your information with marketing companies who help us analyse the information we collect so that we can administer, support, improve and develop our business and services to you.

If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

We may use the information that you provide to us if we are under a duty to disclose or share your information to third parties in or outside Hong Kong in order to comply with (and/or where we believe we are under a duty to comply with) any legal or regulatory obligation that arise in or outside Hong Kong; or in order to enforce the Terms of Use of the Sites and any other agreement; or to protect the rights of ReCube, partners or others. This includes exchanging your information with other companies and other organisations for the purposes of fraud protection and prevention.

Any reward programme information/number you provide to us will be provided to the relevant partner that operates the programme (together with any other relevant information as required by the partner). You will earn points and/or rewards under the terms and conditions that you have entered into with a partner.

6. Security And Data Retention

We take all practicable steps to protect the personal data the users hold against unauthorised or accidental access, processing, erasure, loss or use.. We will keep your information for a reasonable period for as long as necessary for the purposes set out above, or as long as the law requires.

Where you have chosen a password which allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

We take all practicable steps to ensure that personal data is accurate and is not kept longer than is necessary for the fulfillment of the purpose for which the data is used. We take all practicable steps to erase personal data that is no longer required for the purpose for which the data is used, unless erasure is prohibited by law or is not in the public interest.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7. Your Legal Rights

7.1 Right to access

You have the right to be informed which data we store about you and how we process this data.

We will respond to your access request as soon as practicable, in any case within forty (40) days upon receiving your access request. We will also inform you within the timeframe if we are unable to adhere to your request (with reasons) or require additional time to effect the request.

7.2 Right to rectification

If you notice that stored data is incorrect, you can always ask us to correct it.

We will respond to your correction request as soon as practicable, in any case not later than forty (40) days upon receiving your correction request. We will also inform you within the timeframe if we are unable to adhere to your request (with reasons) or require additional time to effect the request.

7.3 Right to withdraw your consent to the processing of your personal data

You can withdraw your consent to our collection, use and disclosure of your personal data at any time for any or all of the Purposes, with written notice. Upon receiving your withdrawal request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request.

We will endeavour to process your request within forty (40) business days upon receipt, and will notify you accordingly if we require additional time.

To exercise your rights, you may make your request via email to info@recube.hk at any time and we will process such requests in accordance with this Privacy Policy and our obligations under applicable laws.

Following termination or deactivation of your account, ReCube, its Clients, Affiliates, or its

service providers may retain information (including your profile information) and user Content

for a commercially reasonable time for backup, archival, and/or audit purposes. If you have

any questions about termination or deactivation of your account, please contact us directly at

info@recube.hk

In accordance with Section 28 of the PDPO, ReCube may charge a reasonable fee to cover the direct costs of handling and complying with a Data Access Request. We will inform you of the estimated fee in advance. No fee will be charged for processing Data Correction Requests or Direct Marketing Opt-Out Requests.