Privacy Policy

Effective date: 29 August 2026

Version: 1.7

This Privacy Policy explains how THT GLOBAL LIMITED, operating the MANJAM Services for relevant transactions, collects, uses, discloses, and protects personal information.

1. Controller/contact details

THT GLOBAL LIMITED

Company No.: 78843181

Business Registration Certificate No.: 78843181-000-09-25-0

Registered Office: Unit B53, 2/F, Kwai Shing Industrial Building Phase 1, 36–40 Tai Lin Pai Road, Kwai Chung, New Territories, Hong Kong

Customer Support: support@manjam.app

Telephone: +852 6279 9717

Privacy inquiries: privacy@manjam.app

Customer support: support@manjam.app

2. Information we collect

Information you provide

• name, email, telephone number, account credentials;
• billing and delivery addresses;
• order, product request, size, preference, and communication data;
• identity and verification documents for high-value or regulated-risk orders;
• refund, complaint, and support information;
• where Live Chat is enabled, message content, sender role, sent/read timestamps, unread state, conversation status, staff assignment and support-handling notes;
• user-submitted content.

App and catalogue activity

• email or Apple sign-in identity, one-time verification codes, session identifiers and internal user identifiers;
• profile, country/region and delivery information;
• catalogue browsing, searches, viewed items, saved items, bag contents, recent items and local drafts;
• item-request references submitted as an image, link or description;
• request, quote and order history associated with an account;
• referral, invite and affiliate attribution identifiers where a referral feature is used.

Some saved items, bag contents, recent items and drafts may be stored locally on the device or browser. Website preview records are not currently synchronized with the live app account.

Transaction information

Depending on the features actually enabled for your account and order, this may include:

• Order ID, amount, currency, payment or funding status;
• MANJAM Balance ledger information where applicable, including Cash Balance, MANJAM Credit, Available/Reserved/Settled/Released movements, exact shortfall amounts shown at checkout, funding-consent records, funding source references and related chargeback/refund records;
• payment-processor reference;
• 3-D Secure and authentication result;
• limited card information such as brand and last four digits where provided by the payment processor.

MANJAM does not intentionally store complete card numbers or security codes when payment is handled on a secure payment page provided by a payment processor.

Automatically collected information

• IP address;
• device, browser, operating-system, and app information;
• usage events, log data, cookies, and similar technologies;
• checkout consent timestamp and policy version;
• fraud and security signals.

Fulfillment and evidence information

For order verification and dispute handling, we may retain:

• sourcing and supplier records;
• item photographs/video and identifiers;
• packaging and dispatch records;
• tracking, signature, and proof of delivery;
• customer communications.

3. How we use information

We use personal information to:

• create and manage accounts;
• respond to sourcing requests;
• confirm, process, and fulfill orders;
• process payments, MANJAM Balance movements, releases and refunds where enabled;
• authenticate and inspect products;
• provide tracking and support;
• route, continue and quality-control authenticated support conversations;
• prevent fraud, item substitution, payment abuse, and security incidents;
• perform identity, sanctions, export-control, and compliance checks;
• maintain accounting, tax, and legal records;
• respond to disputes, chargebacks, insurers, courts, regulators, and lawful requests;
• improve the website, app, and services;
• send service messages and, where permitted, marketing communications.

4. Legal bases where applicable

Depending on your location, we process information because it is necessary to:

• perform a contract or take steps at your request;
• comply with legal obligations;
• protect legitimate interests such as fraud prevention, security, recordkeeping, and dispute handling;
• protect vital interests;
• obtain consent where required.

5. Sharing

We may share relevant information with:

• payment processors, banks, card networks, and fraud-prevention providers;
• boutiques, suppliers, authenticators, logistics providers, warehouses, insurers, and customs brokers;
• cloud, communications, analytics, customer-support, and security providers;
• professional advisers and auditors;
• affiliated companies providing operational support;
• regulators, law-enforcement, courts, and authorities where required;
• parties to a merger, financing, reorganization, or sale, subject to appropriate safeguards.

We do not sell personal information for money. We do not receive or share full payment-card credentials when those details are handled by the payment processor.

6. International transfers

MANJAM operates internationally. Information may be processed in Hong Kong and in countries where service providers, suppliers, logistics partners, or affiliated entities operate.

Where required, we use contractual or other lawful transfer safeguards.

7. Retention

We retain information only as long as reasonably necessary for the purposes described.

Typical periods may include:

• account data: while active and for a reasonable period afterward;
• transaction, tax, sourcing, and payment-dispute records: for the period required by applicable law, accounting rules, and relevant payment-network requirements;
• identity-verification records: only for the necessary compliance and risk period;
• support conversations, read/assignment state and related audit events: for a proportionate period needed to continue support, protect the service, handle disputes and meet legal obligations;
• MANJAM CONNECT applications: during review and for a limited period afterward to manage reapplications, fraud, disputes and legal obligations;
• security logs: for a proportionate period based on risk.

We may retain information longer where a dispute, chargeback, investigation, legal hold, or enforcement matter is pending.

8. Security

We use administrative, technical, and physical safeguards appropriate to the nature of the information.

No system is completely secure. Protect access to your device, email and Apple account, and contact us immediately about suspected unauthorized access.

9. Your rights

Depending on your location, you may have rights to:

• access or receive a copy of personal information;
• correct inaccurate information;
• delete information;
• restrict or object to processing;
• withdraw consent;
• receive portable data;
• appeal a privacy decision;
• complain to a data-protection authority.

These rights may be limited by legal, accounting, fraud-prevention, dispute, or record-retention requirements.

Submit a request to privacy@manjam.app. We may verify your identity before responding.

10. Account deletion

Customers can request account deletion through the public Account Deletion page or by contacting privacy@manjam.app from the email associated with the account. We may verify identity before acting on the request. Where an in-product deletion control is available, it may also be used.

Eligible Live Chat content is deleted or de-identified with the account; minimum support audit, security, dispute or legal-hold records may be retained where lawfully necessary. Deleting an account does not require deletion of records we must retain for completed transactions, MANJAM Balance obligations, chargebacks, legal obligations, fraud prevention, accounting, or active disputes. If customer-funded Cash Balance exists when Balance is active, account closure does not forfeit that value; any remaining balance obligation must be resolved under the applicable Balance Terms, payment rules and mandatory law.

11. Children

The Services are not intended for persons under 18. We do not knowingly accept orders from children.

12. Marketing

You may unsubscribe from promotional emails using the link provided or by contacting us. Transactional and security communications may still be sent.

13. Cookies

See the Cookie Policy for information about cookies, analytics, and preference controls.

14. Changes

We may update this Policy prospectively. The current version will be published with an updated date.

15. Contact

privacy@manjam.app

THT GLOBAL LIMITED

Company No.: 78843181

Business Registration Certificate No.: 78843181-000-09-25-0

Registered Office: Unit B53, 2/F, Kwai Shing Industrial Building Phase 1, 36–40 Tai Lin Pai Road, Kwai Chung, New Territories, Hong Kong

Customer Support: support@manjam.app

Telephone: +852 6279 9717

Partner, affiliate and referral data

When a person applies to or participates in MANJAM CONNECT, we may process identity and contact details, country, business and tax information, social or professional profiles, audience information, application responses, referral identifiers, clicks, attributed customer and order references, commission calculations, reversals, payout details and compliance records.

Customer mapping is used for commercial attribution. Partners do not receive customer payment credentials or unrestricted access to customer personal data. For an accepted agency or business partner, limited attribution and earnings information may be visible to authorized administrators of that same partner organization according to role-based access.