Privacy Policy

Last updated: 17 May 2025

Dollar Media Technology Limited ("Silverpathian", "we", "us", or "our") is committed to protecting your personal information. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have in relation to it. It applies to all visitors and customers of our website silverpathian.com and purchasers of our products.

1. Data Controller

The data controller responsible for your personal data is:

Dollar Media Technology Limited
Kam Fone Mansion, 16 Kamfong Street,
Yau Tsim Mong District, Kowloon,
Mong Kok, Hong Kong
Email: support@silverpathian.com

2. Personal Data We Collect

We collect only the minimum personal data necessary to provide our products and services. This may include:

• Identity data: full name
• Contact data: email address, phone number
• Delivery data: shipping address, postal/ZIP code, country
• Transaction data: product ordered, order reference, correspondence related to your order
• Technical data: IP address, browser type and version, time zone, operating system (collected automatically via cookies and server logs)
• Device data: firmware version and app logs if you use the Silverpathian Suite companion application

We do not collect or store any cryptographic private keys, seed phrases, wallet addresses, or cryptocurrency balances. These remain solely on your hardware device.

3. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contract performance: to process and fulfil your order, arrange delivery, and provide customer support.
• Legal obligation: to comply with applicable laws, including tax, accounting, and consumer protection regulations in Hong Kong.
• Legitimate interests: to improve our products, prevent fraud, maintain website security, and communicate important product or security updates.
• Consent: where you have given explicit consent, for example to receive marketing communications. You may withdraw consent at any time.

4. How We Use Your Data

We use your personal data exclusively for the following purposes:

• Processing and fulfilling orders, including coordinating shipping and delivery
• Communicating with you about your order status, warranty, or support requests
• Sending critical product security or firmware update notifications
• Complying with legal and regulatory obligations
• Detecting, preventing, and investigating fraud or security incidents
• Improving our website and products based on aggregated, anonymised analytics

We do not use your personal data for automated decision-making or profiling.

5. Sharing of Personal Data

We do not sell, rent, or trade your personal data to third parties. We may share your data with trusted service providers acting on our behalf, strictly limited to:

• Shipping and logistics partners — to deliver your order (name, address, phone number)
• Payment processors — where applicable, to facilitate payment (we do not store full payment card data)
• Email service providers — to send transactional and support emails
• Cloud hosting providers — for website and data storage infrastructure

All third-party providers are contractually required to process your data only as instructed and in accordance with applicable data protection laws. We may also disclose your data if required to do so by law, court order, or governmental authority.

6. International Data Transfers

Dollar Media Technology Limited is based in Hong Kong. If you access our website or purchase our products from the European Economic Area (EEA), the United Kingdom, or other jurisdictions with data protection laws, your data may be transferred to and processed in Hong Kong or other countries. We ensure that appropriate safeguards are in place for any such transfer, including standard contractual clauses where required.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes set out in this policy, or as required by law:

• Order and transaction records are retained for a minimum of 7 years in accordance with Hong Kong tax and accounting regulations.
• Customer support correspondence is retained for 3 years from the date of the last interaction.
• Website technical logs are retained for up to 12 months.

When data is no longer required, it is securely deleted or anonymised.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of access: obtain a copy of the personal data we hold about you
• Right of rectification: request correction of inaccurate or incomplete data
• Right of erasure: request deletion of your data where it is no longer necessary or you withdraw consent
• Right to restriction: request that we restrict processing of your data in certain circumstances
• Right to data portability: receive your data in a structured, machine-readable format
• Right to object: object to processing based on our legitimate interests
• Right to withdraw consent: withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at support@silverpathian.com. We will respond within 30 days. If you are located in the EEA or UK and are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.

9. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encrypted communications (HTTPS/TLS), access controls, and regular security reviews. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

10. Children's Privacy

Our website and products are not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, please contact us immediately and we will delete it.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and recommend you review their privacy policies independently.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this policy periodically. Continued use of our website after changes constitutes acceptance of the revised policy.

13. Contact

For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact us at:
support@silverpathian.com
Dollar Media Technology Limited, Kam Fone Mansion, 16 Kamfong Street, Mong Kok, Hong Kong