Privacy

REFLIB is operated by MNV LIMITED from servers in Hong Kong. Under the Personal Data (Privacy) Ordinance (Cap. 486, the “Ordinance”) we are the data user and you are the data subject.

This page also serves as the Personal Information Collection Statement required by Data Protection Principle 1(3): what we collect, why, who it goes to, and what rights you have.

Please note: this site is not one that collects nothing. We collect what is necessary to run the service and improve the product. If you do not agree with this policy, please do not use the site; by continuing to use it you are taken to consent to the collection and use described here.

1. What we record, and why

Every search, suggestion and AI answer is written to our own database with these fields:

  • Your search terms and AI questionsmeasuring result quality, finding queries that return nothing, deciding what to improve
  • Timestampusage trends over time
  • IP addressabuse and rate-limit investigation, and estimating distinct visitors
  • A hash of the IP addressgrouping activity for statistics without reading the address itself
  • Country or regionunderstanding traffic sources and enforcing regional availability
  • Browser user agentdevice and compatibility breakdown
  • Interface and search languagelanguage usage breakdown
  • Request path, status code, response time and sizeperformance monitoring and fault diagnosis
  • Referring pageunderstanding how visitors arrive
  • Result count, cache hit, and whether the upstream provider was calledservice quality and upstream API cost tracking
  • Which result you clicked, and its positionmeasuring whether the top results are the useful ones
  • The full list of results shown for each searchreconstructing what a visit looked like when investigating a complaint or a quality problem
  • Time engaged with the page and scroll depthtelling a five-second bounce apart from a five-minute read

2. Cookies and browser storage

  • reflib_vida random identifier for your browser, kept two years, used to tell repeat visits apart. No name, e-mail or account — there are no accounts here
  • reflib_sida random identifier for the current visit, expiring after 30 minutes idle, used to group one sitting together
  • reflib-theme / reflib-langyour own theme and language choices; never sent anywhere for analysis
  • reflib-history (browser storage, not a cookie)the last 50 queries you typed, kept only in this browser to offer back in the search box. Never uploaded; clear it from the dropdown under the search box

3. How we meet the six Data Protection Principles

  • DPP1 — Purpose and manner of collectioncollected only to run the service, prevent abuse and improve the product; not excessive; this page is the notice given before collection
  • DPP2 — Accuracy and duration of retentionrecorded automatically and not edited by hand; retention is set out in section 4
  • DPP3 — Use of personal datanot used for any new purpose, not used for direct marketing, and never sold or rented to anyone
  • DPP4 — SecurityHTTPS enforced site-wide; the admin dashboard sits behind Cloudflare Access with e-mail verification; the database is not reachable from the internet and only named operators can read it
  • DPP5 — Opennessthis page states our policies and practices, and is linked from the footer of every page
  • DPP6 — Access to personal datayou may request access to, and correction of, the data we hold about you — see section 6

4. How long we keep it, and where

  • Detail records are currently kept indefinitely; we do not delete them on a schedule. Retention limits are being introduced and this page will be updated to match when they are.
  • A separate aggregate layer (daily counts by region and language) holds no IP address, visitor identifier or search term, cannot be traced to any individual, and is kept long-term to support trend analysis.
  • Data is stored on our own server in Hong Kong.
  • The database is backed up daily and backups are kept for 30 days.

5. Who can see it, and who it goes to

  • Only the people who operate this service can read the raw records, for operations and analysis.
  • We do not sell, rent or supply personal data to third parties for marketing.
  • We will disclose data where required by law to Hong Kong law enforcement or a court, or where necessary to protect the legitimate interests of the service, its users, or the public.

6. Your rights (DPP6)

You may ask whether we hold personal data about you, request a copy, and require correction of anything inaccurate. Write to [email protected].

Because the site has no accounts, we hold no name or e-mail to identify you by. You will need to give us enough to locate the records — for example your visitor identifier (the value of reflib_vid), the approximate time of the searches, and the IP address you used. If we cannot match a request to specific records, we cannot comply with it.

As the Ordinance requires, we will respond within 40 days; if we cannot comply, we will say why within the same period.

7. Upstream services and cross-border transfer

The service depends on the following third parties, and your queries pass through their systems:

  • Brave Search APIperforms the actual search. Your search terms are sent to its servers and handled under its own privacy policy. We send it no identifier beyond what the connection itself reveals
  • Cloudflarecontent delivery, DDoS protection and regional rules. Every request passes through its network, which handles your IP address and region
  • Servers of those services may sit outside Hong Kong, so your queries involve a cross-border transfer. By using this site you acknowledge and consent to that transfer.

8. What we do not do

  • No accounts; we never ask for your name, e-mail or phone number.
  • No third-party advertising or analytics code (no Google Analytics, no Facebook Pixel).
  • No selling of data and no direct marketing.

9. Complaints

If you have a question or complaint about how we handle personal data, write to [email protected].

You also have the right to complain directly to the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.

This policy may be updated from time to time. Last updated: September 2026.

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私隐政策 · Privacy — REFLIB