Privacy policy
Effective 29 July 2026
NoON (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by NoON.
This Privacy Policy applies to our app, and its associated subdomains (collectively, our “Service”) alongside our application, NoON. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.
This Privacy Policy is written to comply with Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and, for users in the European Economic Area (“EEA”) and the United Kingdom, the EU General Data Protection Regulation (“GDPR”) and UK GDPR. Where you use NoON on behalf of an organisation, that organisation is the data controller of the relationship data it manages through the Service, and NoON Technology Ltd acts as its data processor under a Data Processing Agreement (see “International Transfers” below).
Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly defined as:
- Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, remember information about you such as your language preference or login information.
- Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to NoON Technology Ltd, (1101-02, Wayson Commercial Building, 28 Connaught Rd W, Sheung Wan), that is responsible for your information under this Privacy Policy.
- Country: where NoON or the owners/founders of NoON are based, in this case is Hong Kong.
- Customer: refers to the company, organization or person that signs up to use the NoON Service to manage the relationships with your consumers or service users.
- Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit NoON and use the services.
- IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
- Personnel: refers to those individuals who are employed by NoON or are under contract to perform a service on behalf of one of the parties.
- Personal Data: any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
- Service: refers to the service provided by NoON as described in the relative terms (if available) and on this platform.
- Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you.
- App/Application: NoON app, refers to the SOFTWARE PRODUCT identified above.
- You: a person or entity that is registered with NoON to use the Services.
- Data Controller: the person or organisation that decides why and how personal data is processed (under the PDPO, the “data user”).
- Data Processor: a person or organisation that processes personal data on behalf of a Data Controller.
- Standard Contractual Clauses (“SCCs”): the data-transfer contract clauses approved by the European Commission (Decision (EU) 2021/914) that allow personal data to be transferred outside the EEA with appropriate safeguards.
- Data Processing Agreement (“DPA”): the agreement NoON signs with Customer organisations that governs how NoON processes personal data on their behalf, incorporating the SCCs where required.
What information do we collect?
We collect information from you when you visit our app, register on our site, place an order, subscribe to our newsletter, respond to a survey or fill out a form.
- Name / Username
- Phone Numbers
- Email Addresses
- Mailing Addresses
- Job Titles
- Billing Addresses
- Debit/credit card numbers
- Age
- Password
We do not collect GPS or location data of any kind. We also collect information from mobile devices for a better user experience, although this feature is completely optional:
- Phonebook (Contacts list): Your contacts list allows the platform to be much more easy to use by the user, since accessing your contacts from the app makes you save tons of time. The app accesses your contacts only with your permission, and only to provide the Service to you.
Lawful bases (EEA/UK users). We process your personal data on the following legal bases under Article 6 GDPR: (a) performance of a contract — to create your account, sync your ring and app, store the relationship information you enter, and process payments; (b) your consent — for optional features such as sharing your profile when you tap your ring, and for marketing emails, which you may withdraw at any time; (c) our legitimate interests — to secure and improve the Service using aggregated information; and (d) legal obligation — where applicable law requires us to retain or disclose records.
When does NoON use end user information from third parties?
NoON will collect End User Data necessary to provide the NoON services to our customers. End users may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
When does NoON use customer information from third parties?
We receive some information from the third parties when you contact us. For example, when you submit your email address to us to show interest in becoming a NoON customer, we receive information from a third party that provides automated fraud detection services to NoON. We also occasionally collect information that is made publicly available on social media websites. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
Do we share the information we collect with third parties?
We do not share the personal information we collect with advertisers, contest sponsors, promotional or marketing partners, ad networks, or anyone who would use it for their own purposes. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.
The only third parties who receive personal information are the service providers who help us run NoOn — such as hosting our servers and app, database storage, and payment processing. These service providers act only as our data processors under contracts that limit their use of personal data strictly to providing those services on our behalf — never for their own purposes, and never for advertising. A current list of sub-processors is available on request at tap@noonring.ai.
We may also disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations. Where the GDPR applies, any such disclosure is made only where legally required and consistent with Chapter V GDPR.
Where and when is information collected from customers and end users?
NoON will collect personal information that you submit to us. We may also receive personal information about you from third parties as described above.
How do we use the information we collect?
Any of the information we collect from you may be used in one of the following ways:
- To personalize your experience (your information helps us to better respond to your individual needs)
- To improve our app (we continually strive to improve our app offerings based on the information and feedback we receive from you)
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
- To process transactions
- To administer a contest, promotion, survey or other site feature
- To send periodic emails
How do we use your email address?
By submitting your email address on this app, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do. We do not use your email address for advertising or custom-audience targeting on Facebook or any other platform. Email addresses submitted only through the order processing page will be used for the sole purpose of sending you information and updates pertaining to your order. If, however, you have provided the same email to us through another method, we may use it for any of the purposes stated in this Policy. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How Long Do We Keep Your Information?
We keep your information only so long as we need it to provide NoON to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can’t identify you. When you delete your account in the app, it is deactivated and blocked from login immediately, and you can restore it yourself within 30 days. If you do not restore it within that period, we permanently delete your personal data, with no exceptions kept for our own purposes. Infrastructure backups are taken daily and kept on a rolling 7-day window, after which older backups expire automatically — so by the time the 30-day period ends, any backup that ever held your data has already cycled out, leaving no copy anywhere in our systems.
How do we protect your Information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to NoON or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.
Personal data breach notification. If a personal data breach affects your personal data, we will notify the competent supervisory authority without undue delay and, where the GDPR applies, within 72 hours of becoming aware of it (Article 33 GDPR), and we will inform affected users where the breach is likely to result in a high risk to their rights (Article 34 GDPR). In Hong Kong, we will notify the Privacy Commissioner for Personal Data in accordance with PCPD guidance.
Could my information be transferred to other countries?
NoON is incorporated in Hong Kong, and our hosting infrastructure is located outside the European Economic Area (EEA) and the UK. If you are in the EEA or the UK, this means your personal data is transferred outside your region for us to provide the Service — see “International Transfers from the EEA and UK” immediately below for the safeguards that apply. NoOn does not otherwise sell, license, or move your data to third parties in other countries beyond the service providers described in this Policy.
International Transfers from the EEA and UK (SCCs)
Where personal data of EEA or UK users is transferred outside those regions (including to Hong Kong, where NoON is based, and to our cloud hosting sub-processors), we protect it with appropriate safeguards under Article 46 GDPR: the European Commission’s Standard Contractual Clauses (2021) and, for UK data, the UK International Data Transfer Addendum, supported by a transfer impact assessment and supplementary technical measures such as encryption in transit and at rest. Customer organisations may request our Data Processing Agreement, which incorporates the SCCs, together with our sub-processor list, by emailing tap@noonring.ai.
Is the information collected through the NoON Service secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. Nothing in this Policy limits any non-disclaimable duty we owe to protect your personal information under the GDPR, UK GDPR, or Hong Kong’s PDPO.
Can I update or correct my information?
The rights you have to request updates or corrections to the information NoON collects depend on your relationship with NoON. Personnel may update or correct their information as detailed in our internal company employment policies.
Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. You can delete your account yourself at any time, directly in the app, without contacting us — this blocks login immediately. You have 30 days to change your mind and restore your account yourself; after that, your personal data is permanently deleted, with no exceptions. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.
If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization of which you are a customer.
Your Rights under the GDPR (EEA and UK users)
If you are in the EEA or the UK, you have the following rights over your personal data, which we honour regardless of where our servers are located:
- Access and portability — obtain a copy of your personal data in a commonly used, machine-readable format (Articles 15 and 20).
- Rectification — correct inaccurate or incomplete data (Article 16).
- Erasure — delete your account directly in the app: this blocks login immediately, and after a 30-day grace period (during which you may restore it yourself) your personal data is permanently deleted with no exceptions. If you would like your data erased sooner, email tap@noonring.ai and we will action it manually (Article 17).
- Restriction and objection — restrict or object to certain processing, including any direct marketing (Articles 18 and 21).
- Withdraw consent — at any time, where processing is based on consent, without affecting prior processing (Article 7(3)).
- No automated decisions — we do not make decisions about you based solely on automated processing that produce legal or similarly significant effects (Article 22).
To exercise any of these rights, email tap@noonring.ai. We will respond within one month (Article 12(3)). We may ask you to verify your identity first. You also have the right to lodge a complaint with your local data protection supervisory authority.
Hong Kong PDPO
As a Hong Kong company, NoON complies with the six Data Protection Principles of the Personal Data (Privacy) Ordinance (Cap. 486): personal data is collected lawfully and fairly for purposes directly related to the Service (DPP1); kept accurate and no longer than necessary (DPP2); used only for the purposes for which it was collected, unless you consent otherwise (DPP3); protected by appropriate security safeguards (DPP4); handled under transparent, publicly available policies — this document (DPP5); and accessible and correctable by you (DPP6). You may request access to or correction of your personal data under sections 18 and 22 of the PDPO by emailing tap@noonring.ai. We may charge a reasonable fee as permitted by the Ordinance. Complaints may be made to the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong — pcpd.org.hk.
EU Representative
NoOn has not yet appointed a representative in the European Union under Article 27 GDPR. Until we do, please direct any enquiry, request, or complaint relating to your data protection rights to tap@noonring.ai, and we will respond within the timeframes set out in this Policy.
Personnel
If you are a NoON worker or applicant, we collect information you voluntarily provide to us. We use the information collected for Human Resources purposes in order to administer benefits to workers and screen applicants.
You may contact us in order to (1) update or correct your information, (2) change your preferences with respect to communications and other information you receive from us, or (3) receive a record of the information we have relating to you. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.
Sale of business
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of NoON or any of its Corporate Affiliates (as defined herein), or that portion of NoON or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with NoON, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.
Governing law
This Privacy Policy is governed by the laws of Hong Kong without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy, except that, if you are in the EEA or the UK, nothing in this Policy deprives you of the protections of the GDPR or UK GDPR, including the right to bring a claim in your country of residence.
The laws of Hong Kong, excluding its conflicts of law rules, shall govern this Agreement and your use of the app. Your use of the app may also be subject to other local, state, national, or international laws.
By using NoON or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our app, or use our services. Continued use of the app, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.
Your consent
We’ve updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site and how it’s being used. By using NoON, registering an account, or making a purchase, you acknowledge that you have read and agree to be bound by this Privacy Policy. Separately, where we rely on your consent under the GDPR for specific processing — for example, when you first share your profile via your ring, or opt in to marketing emails — we ask for that consent individually, and you can withdraw it at any time in the app or by emailing us.
Links to other websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by NoON. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.
Cookies
NoON uses “Cookies” to identify the areas of our app that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies. We use two categories of cookies on noonring.ai: (1) strictly necessary cookies, used for shopping cart and checkout functionality, which do not require your consent; and (2) analytics cookies (Google Analytics), which are not strictly necessary and are only set once you have given your consent via our cookie banner. You can change your cookie preferences at any time.
Blocking and disabling cookies and similar technologies
Wherever you’re located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our app from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser’s help menu for more information.
Payment details
In respect to any credit card or other payment processing details you have provided us, we commit that this confidential information will be stored in the most secure manner possible. Payments are processed by our payment provider; full card numbers are not stored on NoON’s systems.
Kids' privacy
We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. For users in the EEA and the UK, the Service is not directed at anyone under 16, and we do not knowingly process personal data of children under 16 without verifiable parental consent (Article 8 GDPR). If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Changes to our privacy policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.
Third-party services
We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services (“Third-Party Services”). You acknowledge and agree that NoON shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. NoON does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services. Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties’ terms and conditions.
Tracking technologies
- Cookies. We use Cookies to enhance the performance and functionality of our platform but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the platform as we would not be able to remember that you had logged in previously.
Information about General Data Protection Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under protection from being replicated or used in the wrong way.
What is GDPR? GDPR is an EU-wide privacy and data protection law that regulates how EU residents’ data is protected by companies and enhances the control the EU residents have, over their personal data. The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.
What is personal data? Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.
The Data Protection Principles include requirements such as:
- Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.
- Personal data should only be collected to fulfil a specific purpose and it should only be used for that purpose. Organizations must specify why they need the personal data when they collect it.
- Personal data should be held no longer than necessary to fulfil its purpose.
- People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.
Individual Data Subject’s Rights — Data Access, Portability and Deletion. We are committed to helping our customers meet the data subject rights requirements of GDPR. NoON processes and stores personal data only with vetted service providers under contract. NoOn does not operate a messaging or conversation feature, so no conversation data is collected or retained. As set out under “How Long Do We Keep Your Information?” above, deleting your account blocks login immediately, gives you 30 days to restore it yourself, and then permanently erases your personal data with no exceptions. We’ve been set up as self service from the start and have always given you access to your data and your customers data. Our customer support team is here for you to answer any questions you might have about working with the API.
California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above. You may exercise the following rights: Right to Know and Access; Right to Equal Service; Right to Delete; and the right to request that a business that sells a consumer’s personal data, not sell the consumer’s personal data. If you make a request, we have one month to respond to you. We do not sell the Personal Information of our users. For more information about these rights, please contact us.
California Online Privacy Protection Act (CalOPPA)
CalOPPA requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above. CalOPPA users have the rights to Know and Access, Equal Service, and Deletion, and the right to request that a business that sells a consumer’s personal data, not sell the consumer’s personal data. If you make a request, we have one month to respond to you. We do not sell the Personal Information of our users
Contact Us
Don’t hesitate to contact us if you have any questions.
- Email: tap@noonring.ai
For privacy requests (access, correction, export, deletion) or to request our Data Processing Agreement and sub-processor list, email tap@noonring.ai with the subject line “Privacy Request”. We respond within one month.
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