Privacy Policy

Updated July 13, 2022

Elephant Please’s Privacy Policy describes how Elephant Please Limited (“Elephant Please”), collects, uses and shares your personal data. Please take a moment to familiarise yourself with our privacy practices, accessible via the headings below and contact us if you have questions.

What is Personal Data

At Elephant Please, we strongly believe in privacy rights – and that those rights should not differ depending on where you live in the world. That’s why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by Elephant Please as “personal data”, no matter where the individual lives. This means that data that directly identifies you – such as your name – is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you – such as the order number – is personal data. Aggregated is considered non-personal data for the purposes of this Privacy Policy.

This Privacy Policy covers how Elephant Please Limited or its subsidiary handles personal data when you interact with us on our websites. Elephant Please may also link to third parties on our services. Elephant Please’s Privacy policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

Privacy Rights

At Elephant Please, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to all our customers and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from Elephant Please. Elephant Please does not sell your data.

Personal Data Access and Correction

Under the Personal Data (Privacy) Ordinance, you are entitled to be informed by us whether we hold your personal data, to have access to such data and to correct such data if they are inaccurate.

Any such data access request has to be made in writing and be sent to our Data Protection Officer by e-mail to: dataprivacy@elephantplease.com.

A reasonable fee might be charged for all data access or related requests.

There may be situations where we cannot grant your request – for example, if you ask us to delete your transaction data and Elephant Please is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardises the privacy of other, is frivolous or vexatious, or would be extremely impractical.

Personal Data Collected from You

At Elephant Please, we believe that you can have great services with great privacy. This means that we strive to collect only the personal data we need. The personal data Elephant Please collects depends on how you interact with Elephant Please. When you create an account, rent an item, list an item, search for an item, leave reviews for the other party, connect to our services, contact us, participate in online questionnaires, or otherwise interact with Elephant Please, we may collect a variety of information, including:

  • Account Information: Data including, but not limited to, name, email address, account status, age, connected social media accounts, and profile picture
  • Device Information: Data from which your device could be identified, such as device operating system and browser used
  • Contact Information: Data such as name, email address, region of residence, phone number or other contact information
  • Payment Information: Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information
  • Transaction Information: Data about items rented or lent, or other purchases on Elephant Please platforms
  • Fraud Prevention Information: Data used to help identify and prevent fraud.
  • Usage Data: Data about your activity on and use of our offerings, such as movement on our websites, including browsing history, search history, product interaction, crash data, performance, and other diagnostic data and other usage data.
  • Location Information: Data such as a general approximate location.
  • Government ID Data: We may ask for a government-issued ID in certain circumstances, including when setting up certain accounts or managing rentals, or as required by law.
  • Other Information You Provide to Us: Details such as the content of your communications with Elephant Please, including interactions with customer support and contacts through social media channels.

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our services or respond to requests you may have.

Personal Data Received from Other Sources

Elephant Please may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our services and assist us in security and fraud prevention, and from other lawful sources.

  • Individuals: Elephant Please may collect data about you from other individuals – for example, if that individual has sent you a promo code, link to participate in Elephant Please events or shared content with you.
  • At Your Direction: You may direct other individuals or third parties to share data with Elephant Please. For example, you may direct your social media account provider to share data about your account with Elephant Please for an account set up.
  • Elephant Please Partners: We may also validate the information you provide – for example, when creating an account, with a third party for security and for fraud-prevention purposes.

For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

Use of Personal Data

Elephant Please uses personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

Elephant Please uses your personal data only when we have a valid legal basis to do so. Depending on the circumstances, Elephant Please may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, protect your vital interests or those of other persons, or to comply with the law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.

  • Power Our Services: Elephant Please collects personal data necessary to power our services, which may include personal data collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting. For example, if you would like to rent an item, we collect data on which item, the period, cost and other relevant data to provide you with the service requested.
  • Process Your Transactions: To process transactions, Elephant Please must collect data such as your name, item in question, and payment information.
  • Communicate with You: To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Elephant Please, you may not opt out of receiving these important notices.
  • Security and Fraud Prevention: To protect individuals, employees, and Elephant Please and for loss prevention and to prevent fraud, including to protect individuals, employees, and Elephant Please for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
  • Personal Data Used for Personalisation: If you choose to personalise your services or communications where such options are available, Elephant Please will use information that we collect so that we can offer you those personalised services or communications.
  • Identification of users: In case of disputes, personal data provided will be used to identify appropriate and relevant users, for follow-up actions.
  • Comply with Law: To comply with applicable law – for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.

Elephant Please does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.

Elephant Please retains personal data only for so long as necessary to fulfil the purposes for which it was collected, including as described in this Privacy Policy or as required by law. We will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

Sharing of Personal Data

Elephant Please may share personal data with Elephant Please or its subsidiary, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. Further, Elephant Please does not share personal data with third parties for their own marketing purposes.

  • Service Providers: Elephant Please may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services. Elephant Please service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the personal data we share for their own purposes and must delete or return the personal data once they have fulfilled our request.
  • Partners: At times, Elephant Please may partner with third parties to provide services or other offerings. Elephant Please requires its partners to protect your personal data.
  • Others: Elephant Please may share personal data with others at your direction or with your consent, such as when we share information with the item owner. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonable necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganisation, merger, or sale.

Protection of Personal Data

At Elephant Please, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working on these safeguards to help keep your personal data secure.

Children and Personal Data

Elephant Please understands the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 18 or the equivalent age as specified by law in your jurisdiction. That is why Elephant Please has implemented additional processes and protections to help keep children’s personal data safe.

To access certain Elephant Please services, a child must have an account. When a child applies for an account, permission should be sought from the parent. If a reasonable request to close an account is received from a legal guardian, with supporting documentation, the account will be closed by Elephant Please and services for the account will be suspended or terminated.

In addition, if we learn that a child’s personal data was collected without appropriate authorisation, it will be deleted as soon as possible.

Cookies and Other Technologies

Elephant Please’s websites, services and advertisements may use “cookies” and other technologies. These technologies help us to better understand user behaviour including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

  • Communication Cookies: These cookies are used to enable network traffic to and from Elephant Please’s systems, including by helping us detect any errors.
  • Strictly Necessary Cookies: These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your requests, and to preserve the contents of your item rental request.
  • Other Cookies: These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. Elephant Please also uses these cookies to remember choices you make while browsing, so we can provide you with a customised experience.

If you prefer that Elephant Please not use cookies, we provide you with the means to disable their use. If you want to disable cookies and you are using the Safari web browser, choose “Block all cookies” in Safari’s privacy settings. If you are using a different browser, check with your provider to find out how to disable cookies. Certain features of the Elephant Please website may not be available if all cookies are disabled.

In addition to cookies, Elephant Please uses other technologies that help is achieve similar objectives.

In some email messages Elephant Please sends to you, we provide a “click-through URL” that links you to content on the Elephant Please website. When you click one of these URLs, they pass through a separate server before arriving at the destination page on our website. We track this click-through to help us determine interest in particular topics and measure whether we are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

This Privacy Policy Statement only applies to this Website. If you click on any advertisement or hyperlink linking to another website, you will leave our Website for another location. We shall not be responsible for the privacy and security practices or the content of such websites and you should always check the privacy policy of all websites you clicked in.

Elephant Please generally treats data we collect using these cookies and similar technologies as nonpersonal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data in those regions. In addition, Elephant Please sometimes combines nonpersonal data collected from these technologies with other personal data Elephant Please holds. When we combine data in this way, we treat the combined data as personal data for purposes of this Privacy Policy.

Commitment to Your Privacy

To make sure your personal data is secure, we communicate our privacy and security guidelines to Elephant Please employees and strictly enforce privacy safeguards within the company.

Applicable Law

This Privacy Policy Statement shall be governed by and construed in accordance with the laws of Hong Kong, Special Administrative Region of the People's Republic of China.

Privacy Questions

If you have questions about Elephant Please’s Privacy Policy or privacy practices, you can contact our Data Protection Officer at dataprivacy@elephantplease.com, we will endeavour to help.

Elephant Please takes your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to your question or concern, including those inquiries received in response to an access or download request. In most cases, all substantive contacts receive a response within seven days. In other cases, we may require additional information or let you know that we need more time to respond.

Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person.

If you are not satisfied with Elephant Please’s response, you may refer your complaint to the applicable regulator. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

We reserve the right to revise, change or modify this Privacy Policy from time to time at our sole discretion by updating this Privacy Policy, posting or by inserting notices located on particular pages at this Website to that effect. Please remember to visit this page from time to time to review any amendments to the above Privacy Policy and their effect on your use of this Website. Your continued use of this Website implies your acceptance to such amendments.