Privacy Policy

Important: Please read this Privacy Policy in full before using our website or purchasing any products. By using our website or taking any of the actions described below, you acknowledge that you have read and understood this Privacy Policy.

---

1. Who We Are

This website, aftertone.com (the “Website”), is owned and operated by Soltan Enterprises Limited, a company registered in Hong Kong SAR, China, trading under the brand name Aftertone (referred to as “Company”, “we”, “us”, or “our” throughout this policy).

Our registered address is: Office 3906, 39/F, The Center, 99 Queen’s Road Central, Central, Hong Kong.

We use the term “personal information” to refer to any data that can, directly or indirectly, identify you, describe you, relate to you, or be associated with you. The term “you” refers to any visitor, viewer, or user of the Website and/or any purchaser or user of our digital products and services.

Please note that we cannot control the privacy practices of third-party websites and services that we do not own.

---

2. Information We Collect and How We Collect It

2.1 Information You Provide Directly

We collect information you provide to us when you:

• Purchase or access any of our digital products or services (each, a “Product”)
• Create an account or sign in to our platform
• Sign up to receive emails or newsletters
• Fill out any forms on the Website
• Comment on posts or interact with us on social media
• Access public or private membership groups, including those hosted on third-party platforms
• Respond to a survey or provide feedback
• Contact us via email, online form, or any other means

(collectively, “Actions”).

Examples of information we may collect include: your first name, last name, email address, billing address, billing information (such as credit card details processed through our payment providers), account name, and any other information you voluntarily submit to us.

Tax identification information: If you are a client who requires an invoice for tax purposes, we may collect your Tax Identification Number solely for invoicing and accounting compliance. This information is stored securely and used only for that purpose.

2.2 Information Collected Automatically

We automatically collect certain data when you visit or use our Website, open or respond to our emails, or interact with our content. This may include:

• Internet Protocol (IP) address
• Browser type and version
• Operating system
• Device type and unique device identifiers
• Pages visited, date, time, and length of your visit
• How you interact with the Website, Products, and tools
• Referring website information
• Cookie data and other diagnostic data
• Session recordings and heatmap data, including mouse movements, clicks, scroll behaviour, and page interactions (collected via Microsoft Clarity)
• Conversion tracking and advertising interaction data (collected via Meta Pixel)

2.3 Information from Third-Party Sources

We may receive information about you when you connect with us, comment on or like our posts, or otherwise interact with us on social media platforms. Examples include your profile information, social media handle, name, and email address.

2.4 Information from Automated Tools and Segmentation

We use marketing automation tools (including GoHighLevel) to segment our audience, send personalised email sequences, and track engagement with our content. These tools may process your email address, purchase history, engagement data, and browsing behaviour on our Website to deliver relevant communications and improve your experience. You have the right to opt out of automated profiling at any time by contacting us.

---

3. Why We Collect Your Information

We use your personal information for the following business and commercial purposes:

• To deliver, process payment for, and grant you access to our digital Products
• To create and maintain your account and authenticate your identity
• To communicate with you about your purchases, account, and our services
• To send promotional and marketing communications if you have opted in to receive them, including email marketing
• To personalise your experience with the Website and suggest Products you may be interested in
• To segment our audience and send targeted email sequences based on your engagement and purchase history
• To improve the design, functionality, and performance of our Website and Products
• To analyse interactions and conduct research to improve our business processes
• To respond to your enquiries, feedback, and support requests
• To detect, prevent, and address fraud, security incidents, and illegal activity
• To comply with applicable laws, legal obligations, and regulatory requirements
• To respond to legal and regulatory enquiries and assist law enforcement when required

3.1 Lawful Basis for Processing

We process your personal information on the following legal grounds, depending on the context:

• Consent: Where you have given us clear consent to process your personal information for a specific purpose (e.g., signing up for marketing emails).
• Contractual necessity: Where processing is necessary to fulfil a contract with you or to take steps at your request before entering a contract (e.g., delivering a Product you purchased).
• Legal obligation: Where processing is necessary to comply with a legal obligation we are subject to.
• Legitimate interest: Where processing is necessary for the purposes of our legitimate business interests, provided those interests are not overridden by your rights and freedoms (e.g., fraud prevention, improving our services).

---

4. Who We Share Your Information With

We do not sell, rent, or trade your personal information. We may share your information with the following categories of third parties, solely for the purposes described in this policy:

Payment Processors

We share your payment information with our payment processors to process transactions securely.

• Stripe: Privacy policy: https://stripe.com/privacy
• GoHighLevel: Privacy policy: https://www.gohighlevel.com/privacy-policy
• PayPal (future integration): Privacy policy: https://www.paypal.com/webapps/mpp/ua/privacy-full

Marketing and Automation Platform

We use GoHighLevel as our all-in-one marketing, CRM, email marketing, funnel building, and automation platform. GoHighLevel processes your name, email address, purchase history, engagement data, and other information necessary to deliver our Products and marketing communications.

Analytics and Behaviour Tracking Providers

We use the following analytics tools to understand how visitors interact with our Website:

Google Analytics uses cookies to collect aggregated data about website usage, including pages visited, time on site, and traffic sources. You can learn about Google Analytics’ privacy practices at https://policies.google.com/privacy and opt out by downloading the Google Analytics opt-out browser add-on.

Microsoft Clarity is a user behaviour analytics tool that captures session recordings (including mouse movements, clicks, and scroll behaviour) and generates heatmaps to help us understand how visitors interact with our Website. Clarity may collect and process browsing behaviour data tied to your session. Microsoft Clarity’s data is processed by Microsoft. You can learn about Microsoft’s privacy practices at https://privacy.microsoft.com/privacystatement.

Advertising and Conversion Tracking

Meta Pixel (Facebook Pixel) is a tracking tool provided by Meta Platforms, Inc. that allows us to measure the effectiveness of our advertising, understand user actions on our Website, and deliver targeted advertisements to you on Facebook, Instagram, and other Meta platforms. The Meta Pixel collects data about your browsing activity on our Website, including pages visited, Products viewed or purchased, and other actions you take. This data is shared with Meta and may be used by Meta for its own advertising purposes. You can learn about Meta’s privacy practices at https://www.facebook.com/privacy/policy/ and manage your ad preferences at https://www.facebook.com/adpreferences.

Important: Because the Meta Pixel shares browsing and conversion data with Meta for advertising purposes, this may constitute “sharing” of personal information under the CCPA/CPRA. You can opt out of this tracking by adjusting your cookie preferences when you visit our Website, enabling Global Privacy Control (GPC) in your browser, or contacting us directly.

Tag Management

Google Tag Manager is a tag management system that allows us to deploy and manage tracking scripts (including Google Analytics, Microsoft Clarity, and Meta Pixel) on our Website. Google Tag Manager itself does not collect personal information, but it facilitates the operation of the tracking tools described above. You can learn about Google’s privacy practices at https://policies.google.com/privacy.

Cloud Service and Technology Providers

We may share your information with cloud hosting, storage, and technology service providers who help us operate the Website and deliver our Products.

Customer Service Providers

We may share your information with providers who assist us in responding to your enquiries and support requests.

Professional Advisors

We may share your information with auditors, consultants, legal professionals, and other advisors who provide professional services to us.

Government Agencies and Law Enforcement

We may disclose your information to government agencies, courts, regulators, and law enforcement where we are required to comply with applicable laws, regulations, or legally binding processes, or in response to lawful requests such as subpoenas or court orders. We may also disclose your information to establish, exercise, or defend our legal rights, or to protect you, us, or third parties from harm, fraud, or illegal activity.

Business Transfers

If Soltan Enterprises Limited is acquired, merged with another entity, or undergoes any form of corporate restructuring, your personal information may be transferred as part of that transaction. We may also share information with prospective purchasers during due diligence.

Public Forums

If our Website allows you to leave a post, comment, or review in a public area, that information will be visible to the public. We may also share your publicly posted content outside the Website.

---

5. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies on our Website. These technologies help us understand how you use the Website, personalise your experience, analyse trends, and administer the site.

5.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Website to function properly (e.g., session management, security, payment processing). These cannot be disabled.
• Analytics and Performance Cookies: Help us understand how visitors interact with the Website. These include cookies set by Google Analytics (traffic and usage data) and Microsoft Clarity (session recordings, heatmaps, and click tracking). These cookies collect data about your browsing behaviour to help us improve the Website.
• Marketing and Targeting Cookies: Used to deliver relevant advertisements and track campaign performance. These include the Meta Pixel (Facebook Pixel), which tracks your activity on our Website and shares data with Meta to enable targeted advertising on Facebook, Instagram, and other Meta platforms. These cookies may be set by us or by third-party advertising partners.
• Functionality Cookies: Remember your preferences and settings to improve your experience.

5.2 Tag Management

We use Google Tag Manager to deploy and manage the tracking scripts described above. Google Tag Manager operates as a container that controls when and how tracking tools load on our Website. While Google Tag Manager itself does not collect personal data, it enables the analytics, performance, and marketing cookies described in this section.

5.3 Your Cookie Choices

When you first visit our Website, we will ask for your consent before placing any non-essential cookies on your device. You can manage your cookie preferences at any time through our cookie consent banner or through your browser settings.

Most browsers allow you to block or delete cookies. Please note that disabling cookies may affect the functionality of the Website, including your ability to make purchases or access certain features.

5.4 Global Privacy Control (GPC)

We recognise and honour Global Privacy Control (GPC) signals where required by applicable law. If your browser sends a GPC signal, we will treat it as a valid opt-out request for the sale or sharing of your personal information.

5.5 Third-Party Tracking

Our business partners and third-party service providers may also use cookies and tracking technologies on our Website. We do not control these third parties or their privacy practices and encourage you to review their privacy policies directly.

---

6. How We Protect Your Personal Information

We take the security of your personal information seriously. We maintain reasonable and appropriate physical, technical, and procedural safeguards designed to protect your data from unauthorised access, alteration, disclosure, or destruction.

However, no method of data transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. By using our Website, you acknowledge and accept this inherent risk.

---

7. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Specifically:

• Transaction and purchase records: Retained for a minimum of 7 years to comply with Hong Kong tax and accounting obligations.
• Marketing and email data: Retained until you unsubscribe or request deletion, whichever comes first.
• Account data: Retained for as long as your account is active. If you request account deletion, we will delete or anonymise your data within 30 days, except where retention is required by law.
• Support and communication records: Retained for up to 3 years after the last interaction for quality assurance and dispute resolution purposes.

When your data is no longer needed, we will securely delete or anonymise it. Please note that we cannot control the data retention policies of third-party service providers.

---

8. Data Breach Notification

In the event of a data breach that compromises the security, confidentiality, or integrity of your personal information, we will:

• Investigate the breach promptly and take reasonable steps to mitigate any harm
• Notify affected individuals without undue delay where the breach is likely to result in a high risk to your rights and freedoms
• Where required by applicable law (including GDPR notification within 72 hours), notify the relevant supervisory authority
• Follow the recommended breach notification guidelines under Hong Kong’s PDPO

We maintain internal breach response procedures and will provide you with information about the nature of the breach, the data affected, and the steps we are taking to address it.

---

9. Your Rights

Regardless of where you are located, we believe you should have meaningful control over your personal information. You may exercise the following rights by contacting us at [email protected]:

• Right to Access: Request a copy of the personal information we hold about you.
• Right to Correction: Request correction of any inaccurate or incomplete personal information.
• Right to Deletion: Request deletion of your personal information, subject to legal retention requirements.
• Right to Restrict Processing: Request that we limit how we process your personal information in certain circumstances.
• Right to Data Portability: Request your personal information in a structured, commonly used, machine-readable format.
• Right to Object: Object to the processing of your personal information, including for direct marketing or automated profiling.
• Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

We will respond to your request within 30 days (or within 40 days as permitted under Hong Kong’s PDPO). We may need to verify your identity before processing your request.

9.1 Account Deletion Process

If you request deletion of your account, we will permanently delete your account and associated personal information within 30 days. Please note that once your account is deleted, you will lose access to any digital Products associated with that account. Data that we are legally required to retain (such as transaction records) will be retained in accordance with Section 7 above.

9.2 Unsubscribing from Email Marketing

You can opt out of marketing emails at any time by clicking the “unsubscribe” link in any marketing email we send. Unsubscribing from marketing emails does not affect transactional emails related to your purchases (such as order confirmations and access instructions).

9.3 Opting Out of Phone Communications

If we contact you by telephone, you can opt out at any time by contacting us at [email protected] or by informing us during the call.

---

10. International Data Transfers and Processing

Our Website is intended for individuals located worldwide. Our servers and service providers may be located outside of your country or region, including in the United States and other jurisdictions.

As a result, your personal information may be transferred to, stored in, and processed in countries other than your own. When we transfer your data internationally, we take steps to ensure appropriate safeguards are in place, including:

• Relying on the Standard Contractual Clauses (SCCs) approved by the European Commission for transfers from the EEA
• Ensuring our service providers maintain appropriate data protection standards through contractual obligations
• Complying with applicable data transfer requirements under Hong Kong’s PDPO

By using our Website, you acknowledge and agree that your personal information may be processed in jurisdictions with different data protection laws than your own. The governing law for this Privacy Policy is the law of Hong Kong SAR, China.

---

11. Notice Under Hong Kong’s Personal Data (Privacy) Ordinance (PDPO)

As a company registered in Hong Kong, we are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Under the PDPO, we adhere to the six Data Protection Principles:

• DPP1 — Purpose and Manner of Collection: We collect personal data only for lawful purposes directly related to our business functions, and by means that are fair and not unreasonably intrusive.
• DPP2 — Accuracy and Retention: We take reasonable steps to ensure your personal data is accurate, up-to-date, and not kept longer than necessary.
• DPP3 — Use of Data: We use your personal data only for the purposes for which it was collected, or for directly related purposes, unless we have your consent.
• DPP4 — Data Security: We take reasonable steps to protect your personal data against unauthorised or accidental access, processing, erasure, loss, or use.
• DPP5 — Openness: We make information about our data practices publicly available through this Privacy Policy.
• DPP6 — Access and Correction: You have the right to request access to and correction of your personal data held by us.

To exercise your rights under the PDPO, including data access and correction requests, please contact us at [email protected]. We will respond within 40 days as required by the Ordinance.

If you are unsatisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong at https://www.pcpd.org.hk.

---

12. Notice for Individuals in the European Economic Area (GDPR)

This section applies to individuals covered by the General Data Protection Regulation (“GDPR”). If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the following additional rights and protections apply to you.

12.1 Legal Basis for Processing

We process your personal information under the legal bases described in Section 3.1 of this policy. We are happy to provide specific details about which legal basis applies to any particular processing activity upon request.

12.2 Your GDPR Rights

In addition to the rights described in Section 9, you have the following rights under the GDPR:

• Right to Lodge a Complaint: You may lodge a complaint with the supervisory authority in your country of residence. A list of supervisory authorities is available at https://edpb.europa.eu.
• Right to Be Informed About International Transfers: You have the right to know about the international transfer of your personal data and the safeguards in place. Please see Section 10 of this policy.
• Right to Object to Automated Decision-Making: We use automated tools for audience segmentation and personalised email sequences. You have the right not to be subject to decisions based solely on automated processing that produce legal effects or similarly significantly affect you. To exercise this right, contact us at [email protected].

---

13. Notice for California Residents (CCPA/CPRA)

This section applies to residents of California. The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), provides you with specific privacy rights regarding your personal information.

13.1 Your Rights Under CCPA/CPRA

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected, the sources of that information, the purposes for collection, and the categories of third parties we have shared it with over the past 12 months. You may make this request free of charge, up to twice per year.
• Right to Delete: You have the right to request that we delete the personal information we have collected about you, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We do not sell your personal information. However, our use of the Meta Pixel may constitute “sharing” of personal information for cross-context behavioural advertising under CCPA/CPRA. You can opt out of this sharing by adjusting your cookie preferences on our Website, enabling Global Privacy Control (GPC) in your browser, or contacting us directly.
• Right to Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA/CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights, including by denying services, charging different prices, or providing lesser quality.

To exercise any of these rights, contact us at [email protected]. We will verify your identity before processing your request and respond within 45 days.

13.2 California’s “Shine the Light” Law

We do not share your personal information with third parties for their direct marketing purposes.

---

14. Notice for Nevada Residents

We do not exchange your personal information for monetary consideration with anyone who would license or sell your personal information to third parties.

---

15. Children’s Privacy

Our Website and Products are not directed toward or designed for use by children under the age of 18. We do not knowingly collect, use, store, or share personal information from children under 18. If you believe we have inadvertently collected information from a child under 18, please contact us immediately at [email protected] and we will promptly delete the information.

---

16. Third-Party Links

Our Website may contain links to third-party websites and services for your convenience. We do not control and are not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

---

17. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make changes, we will update the “Last Updated” date at the top of this page. For material changes that significantly affect how we handle your personal information, we will make reasonable efforts to notify you (such as by email or a prominent notice on our Website).

Your continued use of the Website after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

---

18. How to Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise any of your rights, please contact us: