Privacy Policy
Effective date: 1 November 2026
Last updated: 1 November 2026
This Privacy Policy explains how EQUITECH SOLUTIONS HK LIMITED (“EquiTech”, “we”, “us”, or “our”) collects, uses, discloses, stores, and protects personal data when you use the Equine Auction mobile application on the Apple App Store and Google Play, and the related service at `https://api.equitech-hk.com` (together, the “Services”).
EquiTech is a company in Hong Kong. The Services may be used worldwide. This policy is written for that use. Extra rights may apply depending on where you live, as described below.
EquiTech is the data user for the Services under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
1. Who we are
Company: EQUITECH SOLUTIONS HK LIMITED
Registered office: 21/F, CMA Building, 64 Connaught Road, Central, Hong Kong
Privacy contact: info@equitech-hk.com
Postal address: 21/F, CMA Building, 64 Connaught Road, Central, Hong Kong
Website: https://www.equitech-hk.com
If you have a question about this policy, or you want to exercise a privacy right, contact us at the email or postal address above.
2. Personal data we collect
We collect personal data you provide, data created when you use the Services, and identity data from Apple or Google when you sign in.
The Services do not ask you to create a password with us. They do not take payment, and they do not collect your phone number, postal address, precise location, or a mobile advertising identifier.
Information you provide
Identity and account data. When you sign in with Apple or Google, we receive the name, email address, and profile photo those services provide, and we store the role you choose (Buyer or Agent). If you use Sign in with Apple’s private email relay, we store the relay address Apple gives us. Agent sign-in is limited to an `@equitech-hk.com` email.
Notes and marks. On a lot you may save text, ratings, conformation marks, veterinary marks, sketches, photos, videos, and voice recordings. Those veterinary marks are your notes about a horse, not a medical record about you. Pen and highlighter strokes you draw on a pedigree page are stored for your account. Horses you star are stored for your account.
Questions. The words you type into Ask are sent to our service so it can answer from that sale’s catalogue.
Communications. If you email us, we keep the message and any attachment you send, so we can reply.
Information collected automatically
Use of the catalogue. While you are signed in, we record which horses you open and how long the horse page stays open, up to one hour for a single view.
App and device data needed to run the service. Our servers receive standard connection data such as IP address, the time of a request, and the app version, so the service can respond and so we can diagnose faults. The apps store a session token on the device so you stay signed in. We do not use advertising cookies, advertising SDKs, or a mobile advertising ID.
Permissions. The app asks for the microphone so you can record a voice note, and for the camera and microphone so you can take a photo or video note. You can refuse those permissions. The catalogue still works. We collect precise location only if a later version of the app asks for it and you grant it. This version does not.
Information from others
Apple and Google provide the identity details described above when you sign in, and they process installation of the app through their stores.
Sale catalogues, including material from New Zealand Bloodstock where that feed applies, describe horses, lots, and sales. That material is not your account data.
3. How we use personal data
We use personal data to:
provide the catalogue, your notes, your drawings, and your starred horses
create your account and keep you signed in
transcribe a voice note into text, and extract a short structured reading from that transcript, such as whether the note is positive or negative and any price limit you dictated
translate catalogue sentences and transcripts when you use Chinese, while leaving horse names and sale codes as written
answer an Ask question from the sale you have open
show Equitech staff signed in as Agents which signed-in people viewed or starred a horse, and for how long
give you the export of your notes, favorites, and pedigree marks from the account menu
keep the service reliable and secure, and diagnose errors
comply with law, and protect EquiTech, our users, and others
We do not sell personal data. We do not use it for direct marketing or targeted advertising. We do not use it for a new purpose that is materially different from the list above without notice, or without consent where the law requires consent.
4. Legal bases for processing
Where the law requires a legal basis, we rely on the following.
Contract. To provide the account, the catalogue, notes, and the other features you use.
Legitimate interests. To keep the service secure, fix faults, understand which horses attract interest, and limit Agent sign-in to the Equitech organisation. You may object where the law gives you that right.
Consent. For the microphone and camera, which you control in the device settings, and for any optional processing we ask you to agree to separately.
Legal obligation. Where we must keep or disclose information under Hong Kong law or another law that applies to us.
You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before you withdrew it. Refusing the microphone or camera stops voice, photo, and video notes. It does not stop the rest of the catalogue.
5. Cookies, SDKs, and tracking
The mobile apps do not use advertising cookies or cross-app advertising identifiers. They store a session token on the device so you remain signed in, and they store preferences such as language on the device.
Our API writes ordinary server logs. We do not use those logs to build an advertising profile.
If you block storage on the device, sign-in and saved notes on that device will not work as intended.
6. How we share personal data
We do not sell personal data. We share it only as follows.
You. Your notes, drawings, voice recordings, photos, videos, and favorites are available to the signed-in account that created them. Another buyer cannot open them.
Equitech Agents. A person signed in as an Agent with an `@equitech-hk.com` email can see catalogue engagement: which horses were viewed, for how long, and which are starred, together with the name and role of the signed-in person. That screen does not include the text, audio, photos, or drawings in your private notes.
Service providers. The Services run on Amazon Web Services. Voice notes, photos, videos, sketches, and catalogue files are stored there. Transcription uses Amazon Transcribe. Translation uses Amazon Translate. Ask, and the structured reading of a voice transcript, use Amazon Bedrock. These providers process that content so we can provide the feature. They are not permitted to use it for their own advertising.
Apple and Google. They provide sign-in and distribute the app. We do not send your notes to Apple or Google for advertising.
Professional advisers and authorities. Auditors, lawyers, insurers, courts, regulators, or law enforcement, where we must disclose information or where it is reasonably necessary to protect rights and safety.
A buyer of the business. If the business is sold or reorganised, personal data may transfer with it, under the same protections.
People you choose. Share on a horse opens your device’s share sheet or copies a link. What you then send is handled by the app you send it through.
7. International data transfers
We are in Hong Kong. Personal data is stored and processed on Amazon Web Services and may be processed in Hong Kong and in other countries where those Amazon services run, including for transcription, translation, and Ask. Those countries may not have the same data-protection law as your home country.
Where the law requires a safeguard for that transfer, we use a lawful mechanism, such as a contract with the provider, your consent, or another mechanism the law allows.
8. Data retention
We keep account information, notes, drawings, favorites, and horse-view records for as long as the account is in use. Voice, photo, video, and sketch files are kept for the same period, because they are the note.
If you ask us to delete the account, we delete or de-identify that personal data unless we need to keep it for a legal claim, security, accounting, or another legal duty. A copy you already exported stays on your device.
Server logs are kept only as long as we need them to operate and secure the service.
9. Security
Sign-in is handled by Apple or Google. After that, the app uses a session token with our API. Media files are stored privately and are shown with time-limited links. We limit access to production systems to people who need it for their work.
No method of storage or transmission is completely secure. If a breach is likely to cause a real risk to you, we will notify you and any authority the law requires us to notify.
10. Your privacy rights
You may, depending on where you live:
ask whether we hold your personal data, and ask for a copy
ask us to correct data that is inaccurate
ask us to delete the account, subject to records we must keep by law
object to or ask us to restrict certain processing
withdraw consent for consent-based processing
ask for a portable copy where the law requires it
complain to a privacy regulator
In the app. You can delete a note, remove a star, and export your notes, favorites, and pedigree marks from the account menu. Signing out on the device does not delete the account.
Hong Kong. Under the Personal Data (Privacy) Ordinance you may make a data access request or a data correction request. We aim to respond within 40 days after we have what we need to identify you and the data. We may charge a fee for a data access request where the Ordinance allows it.
EEA, United Kingdom, and Switzerland. If those laws apply to you, you may have rights of access, rectification, erasure, restriction, portability, and objection, and you may complain to your local supervisory authority.
United States. We do not sell personal data, and we do not share it for cross-context behavioural advertising. State privacy rights, where they apply, can be exercised by emailing us.
To use any of these rights, email `info@equitech-hk.com`. We may need to confirm that the request is from you.
11. Children’s privacy
The Services are for buyers and bloodstock professionals. They are not directed at anyone under 18, and we do not knowingly collect personal data from a child under 13, or under a higher age where local law requires it.
If you believe a child has given us personal data, email `info@equitech-hk.com`. We will delete it.
12. Third-party services
Sign-in and app installation are provided by Apple and Google under their own policies. Catalogue pages may link to a source such as a sale house or a video host. This policy does not cover those other services. Read their policies before you give them personal data.
13. Changes to this policy
We may update this policy. We will change the “Last updated” date at the top. If a change is material, we will also give notice in the app or by email where we have your address. The new version applies from the date we post it, unless a later date is stated.
14. Contact us
EQUITECH SOLUTIONS HK LIMITED
21/F, CMA Building, 64 Connaught Road, Central, Hong Kong