NanoMatriX of Hong Kong ("NanoMatriX") understands and respects your concerns about the use of your personal information, collected from you that identifies or is able to identify you, or other natural persons in the organization that you represent, as (a) natural person(s) ("Personal Information") through your use of the web site NANOMATRIXSECURE.COM that NanoMatriX owns (the "Site"). The Site also includes versions designed for browsing on mobile devices and the use of such devices is governed by this Privacy Policy as well.

Except where otherwise expressly indicated herein or on the Site, this Privacy Policy applies only to information collected on the Site and does not apply to information collected outside of the Site. Before using or submitting information to the Site please review this Privacy Policy carefully.

If you are acting on behalf of others, you must ensure any other users of the Site are made aware of this Privacy Policy. You and such other users are collectively referred to as “you”.

We believe that you should know which information we collect about you, and how that information is used, maintained, and, in some cases, shared. The following sets forth our privacy practices and policies, applicable to users of the Site. This Privacy Policy is part of the NanoMatriX Terms of Service.

By using the Site, you agree to allow us to collect and process information as described below, even if that includes sensitive data.

This Privacy Policy does not apply to services provided by our business partners or other companies that NanoMatriX does not own or operate. For information on how other such providers of products or services process Personal Information, please consult their respective privacy policies.

Name and address of the responsible party:

NanoMatriX International Limited

18/F, Unit 6 & 7, Workingfield Commercial Building, 408-412 Jaffe Road, Wanchai

Managing Director:

Alfons Futterer


NanoMatriX is the data controller for your Personal Information.

The purpose of processing your Personal Information is to enable and enhance the use of the Site, including enabling additional services and functionality. What that means in terms of what data we collect and process, how and where we process it, and for how long, is described below.

It is important that you read this, as you by taking the Site into use, gives us and our partners your consent to process your Personal Information.


The legal basis for the processing of Personal Information is your consent and data protection law.

Your Personal Information is processed in accordance with the Hong Kong SAR implementation of Personal Data (Privacy) Ordinance (Cap. 486) and best practices described in the General Data Protection Regulation (“GDPR”) (EU) 2016/679. This gives you strong rights as a data subject. Hereunder you have the right to:

    • have your Personal Information deleted
    • have any incorrect Personal Information corrected
    • information from us, as data controller, regarding the data processing

Hong Kong law applies. Exclusive legal venue is Hong Kong SAR.

Any surrender of data is voluntary, but some basic information is needed to enable the Site to operate.

The Personal Information will be kept and stored for approximatley 13 months. This may be subject to change, depending on if your case with NanoMatriX has been completed, however, you will be updated accordingly.


If you register with NanoMatriX through the Site, NanoMatriX collects and processes the following information from you:

  1. Name, job title, physical and email addresses; and
  2. phone number.

In addition, NanoMatriX, through the Site, automatically collects and processes general data from your computer or mobile device, such as your web browser type and version, and operating system of your computer.

Some of the above data may be collected by use of cookies (a small file that is sent by our web server to a device being used to access or use the Services). Storing cookies is usual practice where a service needs to retain its users' preferences, and we use cookies to keep track of our users' choices and to differentiate them from other users of our services. It helps provide users with a better experience. Please see our Cookie Policy for more information.

We may process this Personal Information for purposes of operating, debugging, maintaining, improving, and optimizing the Site, marketing, and/or to maintain customer relationships. NanoMatriX performs analysis of the data, for the above purposes and also for the purpose of providing its business partners access to relevant data.

You consent to the above described collection and processing of Personal Information.

Third-party cookies utilised by us

 (1) Google Analytics

 This website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics utilises a specific form of “cookies”, text files that are stored on your computer, allowing analysis of the use of the website by you. The information on your use of this website generated by the cooked will, as a rule, be transferred to a Google server in the USA and stored there. We advise you that on this website Google Analytics has been enhanced by the code “gat._anonymizeIp();” in order to guarantee anonymised capturing of IP addresses (so-called IP masking). Through IP anonymisation on this website, your IP address will be shortened by Google within the territory of the EU or member states of the European Economic Area. The full IP address will only be transferred to a Google server in the USA only in exceptional cases and shortened there.

 Google will use this information on our instructions to evaluate your usage of this website, to compile reports on the website activities and to perform other services connected to the website usage and internet usage for the website operator. The IP address transmitted from your browser in the context of Google Analytics will not be combined with other Google data. You can prevent the storage of cookies through a corresponding setting of your browser software; see 7c. above. Furthermore, you can prevent the gathering of data generated by the cookie and related to your usage of the website (incl. your IP address) by Google as well as the processing of this data by Google, by downloading and installing the plug-in available at the link http://tools.google.com/dlpage/gaoptout?hl=de . You will find more detailed information on conditions of use and data protection at http://www.google.com/analytics/terms/de.html  or at http://www.google.com/intl/de/analytics/privacyoverview.html .

(2) Google AdWords

 This website utilises Google AdWords, an analysis service from Google and, in the context of Google AdWords, conversion tracking. In this respect, a cookie for conversion tracking is stored on the hard drive of your computer (so-called “conversion cookie”) when you click on an advertisement placed by Google. These cookies lose their validity after 30 days and do not serve for personal identification. If you visit certain pages on our website, we and Google can recognise that you have clicked on the advertisement and were passed on to this page.

 The information obtained with the help of the conversion cookies serves to prepare statistics for AdWords customers who use conversion tracking. Through these statistics, we learn the total number of users who clicked on the advertisement placed by Google and called up a page provided with a conversion tracking tag. However, we do not obtain any information with which the personal identification of users is possible. We cannot match the data obtained to specific users.

Along with conversion tracking, we also utilise the functions

  • remarketing
  • target groups with joint interests
  • user-defined target groups with joint interests
  • target groups prepared to purchase and
  • similar target groups* demographic and geographic orientation.

Using Google’s remarketing function, we reach users who have already visited our website. This way we can present our advertising to target groups that have already showed interest in our products or services. In addition, AdWords ascertains what joint interests and features the users of our website demonstrate, on the basis of user behaviour on the websites in Google’s advertising network (“display network”) in the past 30 days as well as with the help of context-related search machines. On the basis of this information, AdWords then finds new potential customers, whose interests and features resemble those of our website’s users, for marketing purposes. Remarketing specific to target groups occurs through the combined use of cookies, such as, for example Google Analytics cookies and Google DoubleClick cookies.

You can find further information on the topic of terms of use and data protection in the context of Google AdWords at this link:


5.QR Code Tracking

 IP Address

 We use the IP address to determine the country where the QR code was scanned. After the lookup the IP is stored anonymously in the database. It is not possible to relate to a person using the anonymous IP address.

 GPS Position

 The GPS Position can only be retrieved from users who have enabled their location sharing services on their scanning device.  Furthermore, there will be links to this Privacy Policy and and possibly an Opt-In box to make the permission concrete.

Phone Number

 From the browser in which the target URL of the QR code is requested, only very limited information can be extracted. It is not possible to retrieve the device's phone number or any other contact information, unless the customer volunteers this information.

Landing Pages

 If our landing pages ask for additional information, there will be a link to this Privacy Policy and possibly an Opt-In checkbox if the brand owner deems this necessary.


The Personal Information we collect from you may be transferred to and computer processed on servers placed in:

  1. the United States,
  2. Singapore and
  3. Hong Kong

depending on your location, and the Site instance to which you connect.

The data is stored on servers belonging to Amazon.com, Inc., Seattle, Washington, USA and Google Inc., Mountain View, California, USA. These companies are certified under the EU US Privacy Shield framework. The EU Commission deems transfer of data to companies certified under the framework to offer adequate protection of personal data (more info).

The processing is conducted by personnel that may be located in Hong Kong, Germany and Singapore. You consent to the above described transfer and processing of Personal Information.


NanoMatriX does not share Personal Information for any commercial or marketing purpose unrelated to the delivery of NanoMatriX services without asking you first.

The following are the situations where we may share Personal Information:

  1. With your explicit consent: We may share Personal Information when we have your consent. One example of this would be if you sign up for additional programs offered by our partners. If you do this, we may share certain information with the partner.
  2. For external processing: We have vendors, service providers, and partners who may help with some of our data processing and storage, including customer support services at our partners. They may also assist with monitoring our servers for technical reasons. These vendors (as well as NanoMatriX personnel) can access certain information about you and your account in order to carry out their work. Such vendors are not allowed to use this data for non-NanoMatriX purposes.
  3. As part of business transitions (such as a merger, an acquistion by another company, or a sale of all or a protion of our assests or sale): your Personal Information may be among the items sold or transferred. We will request a purchaser to treat our data under the Privacy Policy in place at the time of its collection.
  4. For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, to respond to legal process, or comply with Hong Kong law.
  5. As necessary, to identify, investigate, prevent or take action regarding illegal activities or suspected fraud or other abuse of any NanoMatrix products or services.
  6. We may share non-Personal Information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish research, or help us generally improve our system. We may also share non-Personal Information with our partners, for instance if they are interested in offering other services on the Site. We take steps to keep this non-Personal Information from being associated with you and we require our partners to do the same.
  7. You consent to the above described sharing of Personal Information.


NanoMatriX has implemented various physical, electronic and procedural safeguards to protect the confidentiality and security of Personal Information under our control. For instance, NanoMatriX limits access to NanoMatriX systems that store such information to authorized personnel. NanoMatriX also employs the Transport Layer Security (TLS) protocol to protect your Personal Information.

NanoMatriX will maintain your Personal Information for as long as a business need exists, or as required by applicable laws, regulations, or government orders. When we dispose of Personal Information, we use commercially reasonable procedures to erase or render it unreadable.

NanoMatriX restricts its personnel from processing user data without authorization by NanoMatriX. NanoMatriX will impose appropriate contractual obligations upon its personnel, including relevant obligations regarding confidentiality, data protection and data security.

NanoMatriX will not disclose any Personal Information to any government, except as necessary to comply with the law or a valid and binding order of a law enforcement agency.


NanoMatriX may from time to time update this Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of the latest changes. Whenever a change to this policy is significant, we will place a prominent notice on www.nanomatrixsecure.com/privacypolicy, at least 10 days before the effective date.

If you have any questions regarding the terms of this policy, please contact NanoMatriX  by sending an email to safe@nanomatrixsecure.com or by writing to NanoMatriX, 18/F, Unit 6 & 7, Workingfield Commercial Building 408-412 Jaffe Road, Wanchai, Hong Kong.


NanoMatriX may from time to time update this Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of the latest changes. Whenever a change to this policy is significant, we will place a prominent notice on www.nanomatrixsecure.com/privacypolicy, at least 10 days before the effective date.

If you have any questions regarding the terms of this policy, please contact NanoMatriX  by sending an email to safe@nanomatrixsecure.com or by writing to NanoMatriX, 18/F, Unit 6 & 7, Workingfield Commercial Building 408-412 Jaffe Road, Wanchai, Hong Kong.


If you are an EU resident and you, have provided Personal Information to us, then you have the right to make a request to see the Personal Information that we reatin.

If you wish to submit a request to obtain your Pesonal Information, please do so by contacting safe@nanomatrixsecure.com with the subject line ‘Subject Access Request’or by writing to NanoMatriX, 18/F, Unit 6 & 7, Workingfield Commercial Building 408-412 Jaffe Road, Wanchai, Hong Kong.

You also each have the right to ask NanoMatriX:

  • Provide you with the personal data that we hold about you. This data may be passed onto a third party by you, or you can request us to pass this information to a third party on your behalf.
  • You may request for us to erase the data we hold about you. This can be done by request through contacting the email address: safe@nanomatrixsecure.com, with the subject line ‘Erase Personal Data’.
  • If any of your data is incorrect, you may rectify it.
  • You are permitted to restrict or object to the processing of your personal data.


Effective as of August 18, 2018

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