1.1 Purpose of this Privacy Policy
Explora Consulting (referred to in this Privacy Policy as “Explora Consulting”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit us at or our Product’s (defined hereunder) website at (collectively the “Website(s)”) regardless of where you visit it from, or use our product Hummingbird Analytics (“Product(s)”) and tell you about your privacy rights and how the law protects you.This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Product(s) and/or Website(s), including but not limited to any data you may provide through creating an account with the Product(s) (“Account”), administering your organization’s licensing account, registering for a Explora Consulting event, or contacting us for support.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

1.2 Data Controller
Explora Consulting is a “data controller” of your personal data.
In simple terms, this means that we (i) “control” your personal data, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or as otherwise permitted by law.

1.3 Contact Information and Complaints
If you have any questions about this Privacy Policy or any questions regarding our use of your personal data, please contact our data privacy manager at, or at for any questions in regards to the use of the Product(s).

Our full contact details are:
8th Floor, Morrison Commercial Building, No.31 Morrison Hill Road, Wan Chai, Hong Kong Attn: Data Privacy Manager​

If you are currently staying within the European Economic Area, you have the right to make a complaint at any time to your country’s supervisory authority for data protection issues. For a current list of national data protection authorities, please visit the European Data Protection Board’s website at We would, however, appreciate the chance to deal with your concerns before you approach your country’s supervisory authority, so please contact us in the first instance.

1.4 Changes to this Privacy Policy and Personal Data
This Privacy Policy is regularly reviewed and was last updated on May 2019. We may amend or update our Privacy Policy from time to time. For this purpose, we will provide you notice of amendments to this Privacy Policy and update the “last updated” date above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 Third-Party Links
The Product(s) and the Website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you use our Website(s), we encourage you to read the privacy policy of every website you visit.


2.1 The types of personal data we collect, use and store about you will depend on the services you have requested from us and/or the nature of your interaction with us. The personal data we store is adequate, relevant and limited to what is necessary for the purpose of processing with the utmost lawfulness, fairness and transparency. With the Platform, we store the provided raw data and enrich it with a set of machine learning engines to provide additional information and insight. When you are using our Product(s) and/or Website(s), we collect and process the following types of your personal data:
  • your first name, last name, username or similar identifier (“Identity Data”);

  • your billing address, corporate email address and corporate telephone numbers (“Contact Data”);

  • your organisation corporate bank account and payment card details (“Financial Data”);

  • details about payments to and from you and other details of products and services you have purchased from us (“Transaction Data”);

  • your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Product(s) and/or Website(s) (“Technical Data”);

  • your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (“Profile Data”);

2.2 We further collect information about how you use the Product(s) and/or Website(s) (“Usage Data”), which is listed below:
  • Device and usage data: Data about your device and the product and features you use, including information about your hardware and software, how our Product(s) perform, as well as your settings

  • Payment and account history: Data about your payment and activities associated with your account.

  • Browse history: Data about the webpages you visit on our website(s).

  • Device, connectivity, and configuration data: Data about your device, your device configuration, and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings, and information about WLAN access points near your device.

  • Error reports and performance data: Data about the performance of the Product(s) and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.

  • Troubleshooting and help data: Data you provide when you contact Explora Consulting for help, such as the use of our Product(s) and/or Website(s), and other details that help us provide support. For example, contact or authentication data, the content of your communications with Explora Consulting, data about the condition of your device, and the use of our Product(s) and/or Website(s) related to your help inquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.

  • Searches and commands: Search queries and commands when you use our Product(s) and/or Website(s) with search or related productivity functionality.

  • Voice data: Your voice data, such as the search queries or commands you speak.

  • Text, inking, and typing data: Text, inking, and typing data and related information. For example, when we collect inking data, we collect information about the placement of your inking instrument on your device

  • Images and related information, such as picture metadata: we collect metadata from our client’s interaction with the Product(s) only for platform improvement and troubleshooting. For example, we collect the image you provide when you use a Bing image-enabled service.

  • Contacts and relationship: Data about your contacts and relationships if you use a product to share information with others, manage contacts, communicate with others, or improve your productivity.

  • Dummy data: we generate such data for testing.

  • Location data: Data about your device’s location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postal code level.

  • your preferences in receiving marketing from us and our third parties and your communication preferences (“Marketing and Communications Data”).

  • Client’s store staff data: store staff ID, first name, middle name, last name, Chinese name, email for purpose of sales performance analysis.

2.3 We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences. Furthermore, we do not modify private data, use our clients’ data for our internal purpose nor sell our client’s data, any insight from our client’s analysis or meta data collected from our client’s interaction with the Product(s).


3.1 Direct Interactions
We collect Identity Data, Contact Data and Financial Data about you that you provide to us by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;

  • register on our Product(s) and/or Website(s);

  • request other marketing material to be sent to you;

  • look for support services from us;

  • give us feedback or contact us in any way or form.

3.1 Direct Interactions
As you interact with our Product(s) and/or Website(s), we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

A cookie is a small file of letters and numbers stored by computer after being sent to your computer when you visit a website. Whenever you visit the same website again, the information stored in the cookie can be retrieved to notify the website of your previous activity. We use cookies to facilitate website navigation, maintain quality of online service, provide additional security, allow the customization of your access to the Website(s) and remember you when you return to the Website(s).

A cookie cannot give us access to your computer or to information beyond what you provide us and we don’t store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience on our Website(s). If you do not wish to enable cookies, you’ll still be able to browse the Website(s) and use them for research purposes.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.Our Product(s) and/or Website(s) use additional identifiers, such as the advertising ID in Windows, for similar purposes, and may also contain web beacons or other similar technologies, as described below.Explora Consulting uses cookies and similar technologies for several purposes, depending on the context or product, including:
  • Storing your preferences and settings
    We use cookies to store your preferences and settings on your device, and to enhance your experiences. Saving your preferences with cookies, such as your preferred language, prevents you from having to set your preferences repeatedly. If you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device.

  • Sign-in and authentication
    We use cookies to authenticate you. When you sign in to a website using your account, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.

  • Security
    We use cookies to process information that helps us secure our products, as well as detect fraud and abuse.

  • Storing information you provide to a website
    We use cookies to remember information you shared. When you provide information to Explora Consulting, we store the data in a cookie for the purpose of remembering the information.

  • Feedback
    Explora Consulting uses cookies to enable you to provide feedback on a website.

  • Analytics
    We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our product.

  • Performance
    Explora Consulting uses cookies to understand and improve how our Product(s) and/or Website(s) performs. For example, we use cookies to gather data that helps with load balancing; this helps ensure that our Product(s) and/or Website(s) remain up and running.

3.2.1 How to control cookies:
Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in Explora Consulting Edge, you can block or delete cookies by selecting Settings > Privacy > Advanced Settings > Cookies. Please refer to your browser’s privacy or help documentation to find Instructions for blocking or deleting cookies in other browsers.​

Certain features of our Product(s) and/or Website(s) depend on cookies. If you choose to block cookies, you cannot sign in or use some of those features, and preferences that are dependent on cookies will be lost. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, are deleted and will need to be recreated.​

Additional privacy controls that can impact cookies, including the Tracking Protection feature of Explora Consulting browsers, are described in the “How to access and control your personal data” section of this privacy statement.

3.2.2 Our use of web beacons and analytics services
Some of our webpages contain electronic tags known as web beacons that we use to help deliver cookies on our Website(s), count users who have visited those websites, and deliver co-branded products. We also include web beacons or similar technologies in our electronic communications to determine whether you open and act on them.In addition to placing web beacons on our Website(s), we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on a Explora Consulting website results in a purchase or other action on the advertiser’s website.

3.3 Third Parties
We are also working closely with third parties (including, for example, analytics providers and other third party providers of services).We will receive personal data about you from such third parties as set out below:
  • Contact Data, Financial Data and Transaction Data from providers of payment services such as WIRECARD, based inside and outside the EEA;

  • Contact Data from mailing list providers such as Mailchimp and Sangrid; and


4.1 Data Usage
We are committed to only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where we need to perform the contract we are about to enter into or have entered into with you (“Performance of Contract”).

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”).

  • Where we need to comply with a legal obligation (“Legal Obligations”).

We plan to use your personal data for the following purposes, and pursuant to the corresponding legal bases:
Type of Data
Lawful Basis and Basis of Legitimate Interest
Registration as a new customer
Type of Data:
Identity Data; 
Contact Data.
Lawful Basis and Basis of Legitimate Interest:
Performance of Contract
Signing in to the Product(s)
Type of Data:
Identity Data; 
Contact Data; 
Profile Data; 
Financial Data; 
Transaction Data.
Lawful Basis and Basis of Legitimate Interest:
Performance of Contract; 
Processing and delivery of your order
Type of Data:
Identity Data; 
Contact Data; 
Financial Data; 
Transaction Data; 
Marketing and Communication Data.
Lawful Basis and Basis of Legitimate Interest:
Performance of Contract; 
Legitimate Interest (to recover debts due to us).
Management of our relationship with you (i.e. notifications about changes to Privacy Policy and asking you to leave a review or take a survey)
Type of Data:
Identity Data; 
Contact Data; 
Profile Data; 
Marketing and Communication Data.
Lawful Basis and Basis of Legitimate Interest:
Performance of Contract; 
Legal Obligations;
Legitimate Interest (to keep your records updated and to study how customers use the Product(s) and our services).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please feel free to contact us any time. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.2 Data usage associated with Hummingbirds Analytics Account
Personal data associated with your account includes credentials, name and contact data, payment data, device and usage data, your contacts, information about your activities, and your interests and favourites. Signing into your account enables personalization, consistent experiences across products and devices, allows you to make payments using payment instruments stored in your account, and enables other features.​

The data associated with your account, and how that data is used, depends on how you use the account. Please refer to the table in the above Clause 4.1 for further details on the lawful basis and basis of legitimate interest on how we use your data.

4.2.1 Creating your Hummingbird Analytics account.
When you create an account, you will be asked to provide certain personal data and we will assign a unique ID number to identify your account and associated information. While our Product(s) involves payment, it requires a real name, you can sign in to.