Updated as at 17 Sep 2020
This explains how we comply with applicable data protection regulations, including the Hong Kong Personal Data (Privacy) Ordinance and the EU General Data Protection Regulation showing the reasons and purposes for which we collect personal data and the ways we access your personal data records.
What information do we collect?
We collect information from you when you register on our site, accept our terms on our site, place an order for our services, subscribe to our newsletter or fill out a form. When ordering services or registering on our site, as appropriate, you may be asked to enter your name, e-mail address, mailing address or phone number. You may, however, visit our site anonymously.
What do we use your information for?
We collect your information to enable us to provide the requested services to you and for improving service, customer support, and browsing experiences for our site visitors. We will indicate clearly on relevant forms and applications as to whether the information is mandatory or voluntary. Should the information be mandatory, you must submit valid personal information in order to complete the application to respective services. Without such information, we will not be able to undertake the service.
Any of the information we collect from you may be used in one of the following ways:
- To process transactions in accordance with our services (your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested);
- To personalize your experience (your information helps us to better respond to your individual needs);
- To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
- To send periodic emails (the email address you provide for order processing may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, or product or service information related or tangential to the services we have historically offered);
- To meet regulatory and/or compliance obligations (we are required to verify your identity and obtain additional information when your account transacts in fiat currencies).
Security of Personal Data
We will keep your personal data confidential and limit access to your personal data to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law. We refer to industry standards and use reasonable administrative, technical and physical security measures to protect your personal data from unauthorized access, destruction, use, modification or disclosure.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. In order to deliver requested services to you, we may transfer your personal data to sub-contractors (“Sub-processors”) who assist with operations, settlements and other bank-office processing which requires them to access data including details of trades made, email addresses and physical addresses (for matching bank payments on occasion). Individual and corporate Know Your Client processes may also be undertaken by Sub-processors including performing identification checking and validation of individual or corporate documents, KYC/KYB checks on applicants and related parties such as directors and beneficial owners, and various other checks to ensure the integrity of our systems, transactions and processes. Trusted third parties who operate our website may also receive elements of personal data as Sub-processors.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Our legitimate interests in processing your personal data
In deciding what data we collect, and what uses we make of that data, we have carefully balanced your interests, as a customer or potential customer providing personal data to us, and your reasonable expectations, with the needs of our business.
We have a legitimate interest in using your data, in addition to providing the service you have engaged us to deliver or registered your interest in us delivering, for the purposes of fraud prevention, intra-group transfers, IT security, direct marketing of our related services, and disclosing information about possible criminal acts or security threats to the authorities.
Your right to object
You may at any time require us to stop using your personal data for direct marketing, by contacting us at any of the contact points below.
If you wish us to stop using your personal data for a purpose other than direct marketing, we will stop unless our legitimate interests prevail. In such circumstances, it is possible that we will be unable to fulfil the services you have contacted us to provide and you may remain liable for charges for the services foregone.
Disposal of Personal Data
We shall not retain your personal data in a form which permits the identification of the data subject for longer than needed for the legitimate purpose or purposes for which we originally collected it, including for the purpose of satisfying any legal, accounting or reporting requirements. Generally, we store data for 7 years. We shall securely delete or destroy data retained at the end of such period, and require our Sub-processors to do likewise.
Data Access and Amendment Requests
Relevant privacy laws and regulations permit you to request us to provide you with access to the personal data we hold in relation to you (if any), and to amend such data if it contains errors. We shall honour such requests, although we reserve the right to charge a reasonable fee, as allowed by applicable legislation.
If you have any inquiries regarding the access and amendment of information, or other query regarding our information policies and practice, please contact: firstname.lastname@example.org