Privacy statement

This privacy statement applies to the websites, as well as the "ELVN" messenger app (in the following: ELVN app) of Platin Genesis Asia Limited, represented by the managing director Alexey Rudnev, Unit 2512, 25/F Langham Place Office Tower, 8 Argyle Street, Mongkok
Hong Kong (in the following: Platin Genesis Asia Limited). Privacy has a high priority for Platin Genesis Asia Limited. As citizens of the European Union can also visit the website or use the ELVN app, the following provisions shall apply. In the following, the user will find information as to which data are collected during the registration or use of the ELVN app as well as during the visit to the website, and how these are used, processed, or passed on.

Responsible body for the data processing is:

Platin Genesis Asia Limited
Unit 2512, 25/F
Langham Place Office Tower
8 Argyle Street, Mongkok
Hong Kong


Data protection officer of the responsible body is:

SBS Data Protect GmbH Hans-Henny-Jahnn-Weg 49 22085 Hamburg


For the assertion of the rights specified in this privacy statement or for questions on the use, collection, or processing of personal data, the user shall contact the aforementioned data protection officer.

Platin Genesis Asia Limited, as the responsible body according to the provisions of data protection laws, shall be obligated to protect the personal data and privacy of data subjects and to treat these confidentially. The collection, storage, modification, transfer, blocking, deletion, and use of personal data is based on the applicable statutory provisions, in particular the General Data Protection Regulation (GDPR).

The data of the users are protected at Platin Genesis Asia Limited by technical and organisational security precautions against access by unauthorised people, accidental or intentional manipulation, destruction or loss. 

I. Data processing when using the website

(1) Access data and cookies

In the case of merely informative use of our website, if you do not register or provide us with information in some other way, we will only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data that is technically necessary for us to display our website to you and to ensure stability and security:

IP address

Date and time of the query

Time zone difference to Greenwich Mean Time (GMT)

Content of the request (specific page)

Access status / HTTP status code

respectively transmitted amount of data

Website from which the request comes


Operating system and its interface

Language and version of the browser software

However, our web server stores these data separately from other data, and it is not possible for us to assign these data to a specific person. After an anonymous analysis for statistical purposes, these data will be deleted immediately. The data are analysed to serve the legitimate interest of Platin Genesis Asia Limited to optimise our offer. The legal basis is Art. 6 para. 1 sentence 1 letter f) of the GDPR.

In addition to the aforementioned data, cookies are stored on your computer when using our website. Cookies are small text files that are stored on your hard drive in the browser you are using, allowing certain information to be passed to the entity that sets the cookie. Cookies cannot run programs or transmit viruses to your computer. They are used to make the Internet offer more user-friendly and effective overall.

The Platin Genesis Asia Limited website uses the following types of cookies, the scope and operation of which are explained below:

a) Transient cookies are automatically deleted when you close the browser. These include, in particular, the session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close the browser.

b) Persistent cookies are automatically deleted after a specified period, which may be different depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

c) Third party cookies are not deposited by the Platin Genesis Asia Limited, but by third-party providers on a user's computer and can be read out on the user's computer when the website is visited again. Unlike cookies that are used by the Platin Genesis Asia Limited itself, these are service providers who collect mostly advertising-relevant information about users.

d) Flash cookies are not detected by your browser but by your Flash plug-in. These objects store the required data regardless of your browser and do not have an automatic expiration date.

You can configure your browser setting according to your wishes and, for example, decline the acceptance of third-party cookies or all cookies. If you do not want any processing of the Flash cookies, you must install an appropriate add-on, e.g. "Better Privacy" for Mozilla Firefox ( or the "Adobe-Flash-Killer-Cookie" for Google Chrome. You can prevent the use of HTML5 storage objects by using private mode in your browser. In addition, we recommend that you regularly delete your cookies and the browser history manually.

We are also pointing out that disabling cookies may not enable you to use all features of this website.

The use of cookies is in the legitimate interest of Platin Genesis Asia Limited to optimise our offer. The legal basis is Art. 6 para. 1 sentence 1 letter f) of the GDPR.

(2) Collection and use of personal data during contact request

As part of a request via our contact form or by e-mail, only the personal data provided by the users will be collected and processed. The data transmitted by the users as part of a contact request are collected, processed, and used exclusively to process their concerns.

This also includes passing on to the Internet service provider commissioned with the provision of our website. Platin Genesis Asia Limited respects the principle of data economy. It only communicates the data that are absolutely necessary for the specific transaction. The data will continue to be used to communicate with users. Platin Genesis Asia Limited does not pass on the personal data of the users without their revocable and explicit consent to third parties.

Platin Genesis Asia Limited stores this information until the consent is revoked. 

This data processing is based on Art. 6 para. 1 sentence 1 lit. a) GDPR in conjunction with the consent of the user.

(3) Use of social media plug-ins

Platin Genesis Asia Limited currently uses the following social media plug-ins: Pinterest, Facebook, Twitter, VK, Tumblr, YouTube.

The so-called two-click solution is used. This means that if the user visits the page of Platin Genesis Asia Limited, initially no personal data will be passed on to the providers of the plug-ins. The user recognises the provider of the plug-in by the mark on the box on their first letter or the logo. Platin Genesis Asia Limited gives the user the opportunity to communicate directly with the provider of the plug-in via the button. Only if they click on the highlighted field and thereby activate it, the plug-in provider shall receive the information that the user has called up the corresponding website of Platin Genesis Asia Limited. In addition, the data referred to in the "Access Data" section of this statement will be transmitted. In the case of Facebook, according to the respective providers in Germany, the IP address is anonymised immediately after collection. Activation of the plug-in means that the user's personal data are transmitted to the respective plug-in provider and stored there (for US providers in the USA). Since the plug-in provider collects the data, in particular via cookies, Platin Genesis Asia Limited recommends that users delete all cookies through the security settings of their browser before clicking on the greyed-out box.

Platin Genesis Asia Limited has no influence on the collected data and data processing operations, nor is it aware of the full extent of the data collection, the purposes of the processing, or the retention periods. It also has no information to delete the data collected by the plug-in provider.

The plug-in provider stores the data collected about the user as usage profiles and uses these for purposes of advertising, market research and/or tailor-made design of their website. Such an analysis is carried out in particular (also for non-logged-in users) to display needs-based advertising and to inform other users of the social network about the activities of the user on the website of Platin Genesis Asia Limited. The user is entitled to a right of objection to the formation of these user profiles, wherein they must contact the respective plug-in provider to exercise this. Through the plug-ins, Platin Genesis Asia Limited allows users to interact with social networks and other users, so that they can improve their offers and make them more interesting to users.

The data are passed on regardless of whether the user owns an account with the plug-in provider and is logged in there. When logged in to the plug-in provider, their data collected from us will be directly associated with their existing account with the plug-in provider. If the user activates the activated button and, for example, the page is linked, the plug-in provider will also store this information in the user's user account and publicly share it with the user's contacts. Platin Genesis Asia Limited recommends that users regularly log out after using a social network, but especially before activating the button, as this will prevent them from being assigned to their profile with the plug-in provider.

Further information on the purpose and scope of the data collection and their processing by the plug-in provider is provided to the user in the following privacy statements of these providers. There, the user will also receive further information on their rights and options to protect their privacy.

Addresses of the respective plug-in providers and URL with their privacy notes:

a. Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;; more information on data collection:, as well as Facebook is subject to the EU-US-Privacy-Shield,

b. Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; Twitter is subject to the EU-US-Privacy-Shield,

c. Tumblr, Inc., 35 East 21st St, 10th Floor, New York, NY 10010, USA; Tumbler is subject to the EU-US-Privacy-Shield,

d. LLC "V Contacts", 1-N, bld. 12-14, letter A, Khersonskaya st., St. Petersburg, Russia; VK has been voluntarily subjected to the European General Data Protection Regulation GDPR,

e. Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA; Pinterest is subject to the EU-US-Privacy-Shield,

f. YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, more information on data collection: YouTube is subject to the EU-US Privacy Shield, Framework.

Insofar as consent of the user to data processing is required, this is based on Art. 6 para. 1 sentence 1 letter a) of the GDPR and otherwise based on Art. 6 para. 1 sentence 1 letter f) of the GDPR to safeguard the legitimate interests of Platin Genesis Asia Limited, namely the optimisation of its offer.

(4) Facebook fan page

For the information service offered here, Platin Genesis Asia Limited accesses the technical platform and services of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland (in the following: Facebook).

According to the ECJ, there is a shared responsibility in the sense of Art. 26 of the GDPR between Facebook and the operator of a Facebook fan page for the personal data processed via the Facebook fan page. Facebook and Platin Genesis Asia Limited have therefore concluded an agreement on the shared responsibility, which can be found here:

Platin Genesis Asia Limited provides you with the following information on the data processing on the Facebook fan page:

  1. Responsible people

Your personal data on the Facebook fan page of Platin Genesis Asia Limited are processed under joint responsibility with Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland.

  1. Data processing

When accessing a Facebook fan page, the IP address of your device is transmitted to Facebook. According to Facebook, this IP address is anonymised and deleted after 90 days, at least insofar as it is a German IP address. In addition, Facebook stores further information about the terminals of its users, for example, the Internet browser used. If necessary, it is thus possible for Facebook to assign IP addresses to individual users. If you are logged into your Facebook account while visiting our fan page, there will be a cookie with your Facebook ID on your device. Because of this cookie, Facebook can understand that you visited our fan page and how you used it. Facebook uses this information to present content or advertising tailored to you.

If you do not want this, you should log out of your Facebook account or deactivate the "Remember me" function. We also recommend deleting cookies on your device and closing and restarting your browser. This process deletes Facebook information that Facebook can use to link to you.

However, if you want to use the interactive features of our fan page, you would have to log in to Facebook again with your Facebook log-in information. This also makes it possible for Facebook to link to you again.

In which way Facebook uses the data from the visit of Facebook pages for its own purposes, to what extent activities on the Facebook page are assigned to individual users, how long Facebook stores these data and whether data from a visit to the Facebook page are passed on to third parties are not conclusively and clearly mentioned by Facebook and are not known to us. As a user of our fan page, we can merely refer you to the comments made by Facebook on privacy.

The data collected on you in this connection will be processed by Facebook and, where appropriate, transferred to countries outside the European Union.

What information Facebook receives and how it is used is described by Facebook in general terms in its data usage policies. There you will also find information about contact options for Facebook as well as the setting options for advertisements. The guidelines for using data are available through the following link: .

You will find the full data guidelines of Facebook here:

The privacy policy of Facebook contains more information about data processing:

Options for objection (so-called opt-out) can be set here: and here

Facebook Inc., the US parent company of Facebook Ireland Ltd., is certified under the EU-US. Privacy-Shield and is obligated to comply with the requirements of European data protection law. You will find more information on the privacy shield status of Facebook here:

The transmission and further processing of users' personal data to third countries, such as the USA, as well as the associated possible risks for you as a user cannot be judged by us as the operator of the Facebook fan page.

  1. Insight feature

As part of the so-called "Insights" feature, Facebook also provides a series of statistical data for Platin Genesis Asia Limited as the fan page operator. These statistics are generated and provided by Facebook. As the fan page operator, we have no influence on the generation, in particular we cannot prevent this feature. As part of the "Insights" feature, the following information is presented to us for the categories "Fans", "Followers", "People reached" and "People engaged" for a selectable period of time:

Page activities such as page views, page preview, actions on page; reach activities such as Likes, People Reached and Referrals, contribution activities such as Post Interactions, Video Views, Comments, Shared Content.

In addition, statistical information about the Facebook groups linked to our fan page will be provided. In addition, in accordance with Facebook's terms of use, which each user has consented to when creating a Facebook profile, we can identify the followers and fans of the page and view their profiles and other shared information.

For more information, please contact Facebook through the following link:

Platin Genesis Asia Limited uses these data, available in aggregated form, to make posts and activities on the fan page more attractive to users, for example, for content- and schedule related planning of posts. The legal basis for this data processing is Art. 6 para. 1 p. 1 letter f of the GDPR, namely our legitimate interest in optimising our offer.

  1. Storage period

We store the information provided by Facebook for as long as your interest in deletion or anonymisation does not prevail.

If you no longer want the data processing described here in the future, please use the "Unlike" and/or "Unfollow" features to unlink your user profile to our fan page.

  1. Your rights as data subject

We recommend that you direct any queries or other questions regarding your rights listed at the end of this privacy statement to Facebook, as only Facebook has complete access to the user data. Should you nevertheless send your request to us, it will of course be processed and additionally forwarded to Facebook.

II. Data processing using the ELVN app

In order to best protect your transmitted data, Platin Genesis Asia Limited uses SSL encryption and TLS encryption as part of the ELVN app. All data transmitted by you to the servers of Platin Genesis Asia Limited as part of the use of the app - such as for queries or log-ins - cannot be read by third parties due to these encryptions.

(1) Data provided by the user

When the user installs and/or uses the ELVN app, the following data will be processed, which the user will provide to Platin Genesis Asia Limited:

  1. Account information: In order to create an ELVN app account, the following data of the user are requested: Mobile phone number, username (alias).

This data processing is done for the purpose of implementing the contract for the use of the ELVN app in accordance with Art. 6 para. 1 sentence 1 letter b of the GDPR.

  1. Sending messages: Messages sent by users within the ELVN app are stored on Platin Genesis Asia Limited servers as part of the provision of the Messenger service. The messages are stored on the servers at most as long as the user's interest in deletion does not prevail. Subsequently, these data will be deleted. The messages are also stored on the users' devices.

This data processing is done for the purpose of implementing the contract for the use of the ELVN app. The legal basis is Art. 6 para. 1 sentence 1 letter b of the GDPR.

(2) Automatically collected data

When the user installs and/or uses the ELVN app, the following data are processed and automatically collected:

  1. Usage and log information: Platin Genesis Asia Limited collects information about the user's activity in the ELVN app. Here, the following are processed:

Time, frequency and duration of user activities and interactions with other users; log files and diagnostic-, crash-, web page- and performance logs and reports; time of registration by the user; user's current status (online or offline); time of last use of the service; time of last update of profile information.

This data processing is done for the purpose of carrying out the contract for the use of the ELVN app. The legal basis for this data processing is Art. 6 para. 1 sentence 1 letter b) of the GDPR.

  1. Device and connection data: When the user installs, uses, or accesses the ELVN app, the ELVN app captures device and connection-specific information. This includes:

Information on the hardware model and operating system used, battery level, signal strength, app version; information about the browser, mobile network, and connection, including phone number, mobile or Internet service provider, language and time zone, and IP address.

This data processing is done for the purpose of carrying out the contract for the use of the ELVN app. The legal basis for this data processing is Art. 6 para. 1 sentence 1 letter b) of the GDPR.

  1. Cookies: The ELVN app uses cookies to operate and provide the services, in particular for the provision of web-based services, for the improvement of the user experience, for the usage analysis, and for the purpose of the individual adaptation of the services. Cookies are small text files (see section I. of this privacy statement) that contain a string that can be placed on the computer or mobile device and that uniquely identifies the user's browser or device. The following cookies are used: session cookies; persistent cookies; third-party cookies.

The user can deactivate the cookies by following the instructions of the ELVN app. Platin Genesis Asia Limited points out that changing these settings may prevent the user from accessing certain parts of the app and that other parts of the app may not work properly.

This data processing is done for the purpose of carrying out the contract for the use of the ELVN app. The legal basis for this data processing is Art. 6 para. 1 sentence 1 letter b) of the GDPR.

(3) Storage period and deletion of the ELVN app / the ELVN app account

Platin Genesis Asia Limited stores the data collected by the users as long as the user uses the service of the ELVN app or until they have deleted their account, whichever occurs first. The user can delete their ELVN app account at any time by using the in-app "delete my account" feature. When the user deletes their ELVN app account, their undelivered messages and any other data that Platin Genesis Asia Limited no longer needs to operate and provide its services are deleted from the servers. If the user deletes the ELVN app from their device without deleting their ELVN app account, the collected data of the user will be stored at most as long as the interest of the user in deletion does not prevail. Subsequently, these data will be deleted.

III. Rights of the user as data subject

(1) The users of the website or the ELVN app have the right to:

- Information about the processing of their data

- Correction or deletion of their data

- Restriction of processing

- Objection against the processing

- Data portability

- Revocation of their given consent with effect for the future

- Complaint to the data protection supervisory authority

A list of all supervisory authorities can be found here:

(2) In order to enforce your aforementioned rights, you can resort to the data protection officer designated in the introduction of the privacy policy as well as to the Platin Genesis Asia Limited itself at any time.

(3) This privacy statement can always be seen and retrieved on the website, as well as in the Google Playstore and the Apple App Store through the ELVN app.

Privacy statement as of: 16/05/2019