“Personal data” is data that can be used to identify a natural person. Examples of personal data include name, address, contact details, identification numbers, financial information, transactional information based on your activities on our Applications, telephone numbers, email address, images, and any other information of a personal nature.
We may collect and process personal data provided directly by you. We also process, insofar as necessary, personal data provided to us by third parties, including publicly accessible data, personal data legitimately provided by other group companies, personal data collected through your use of our (or our service provider’s) digital technologies and services, and personal data provided by other trusted third parties (including our service providers).
You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your data in writing, so that we may take all reasonable measures to keep our records of your personal data correct and up to date.
When our collection is based on consent, you have the choice, at any time, not to provide your personal data to us or to withdraw your consent previously provided to us. However, do note that if you do so, we may be unable to fulfill the purposes for which we require the personal data, continue to provide our products or services to you (e.g. processing your transactions), and/or fulfill any contractual relationship which may be in place between us.
Our Applications and/or services are not intended to be accessed or used by children, minors or persons who are not of legal age. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us.
1. Personal Data you give us
You may voluntarily give us your personal data by filling in forms on the Applications or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you register on the Applications, use our services or the services provided by our service providers, or when you report a problem with the Applications. See Clause I.4 for more information on how we collect your personal data.
Examples of personal data you may provide to us include (depending on the nature of your interaction with us) your name, passport or other identification number, telephone number, mailing address, email address, identification data (such as copies of your identification document, driver’s license or personal photograph), financial and credit card information, and any other information relating to any individuals which you have provided to us in any forms submitted to us, or via other forms of interaction with you. See Clause I.2 for more information on the types of personal data we may collect from you.
2. Personal data and/or information we collect about you
With regard to each of your visits to or use of our Applications, we may collect the following information and/or personal data that are relevant to our relationship with you, as well as copies of documents verifying such information:
Apart from personal data, we may collect other types of information which are not related to an individual and which are anonymous. For example, the number of website visitors and the number of website users using a particular service.
3. How we collect your personal data
We may collect your personal data directly or indirectly through various channels, such as:
4. Personal Data we receive from other sources and third parties
Depending on your relationship with us, we may also collect and receive your personal data from third party sources, for example, from:
We may also receive personal data about you if you use any of the other websites or platforms we operate (or operated by our affiliate or related companies), or other services we (or our affiliate or related companies) provide.
1. General Purposes.
We collect, use, disclose and process your personal data, including data provided by you, data we collect about you and data provided by third parties, in the following ways and upon the following grounds:
We may, if necessary or required by law, provide your personal data to law enforcement agencies, regulatory organisations, courts or other public authorities. Where appropriate, we will attempt to notify our customers about legal demands for their personal data. You agree that we may not be able to do so if such notification is prohibited by law or court order, when the request is an emergency, or when the burden or expense of notifying the customers would be unreasonable to us. We may dispute such demands when we believe that the requests are disproportionate, vague or lack proper authority, but we do not promise or undertake to challenge every demand.
2. Marketing purposes
In order for us, or for authorized third parties permitted by us, to market or advertise products, events, and/or services that are of specific interest and relevance to you, we may analyze, use, process and/or rely on your personal data provided to us, or data collected from your interactions with us. However, no marketing or advertising, using your personal data in non-aggregated and/or identifiable form would be carried out unless you have provided us with your consent to use your personal data for such marketing or advertising purposes. If you do not want us to use or process your personal data for the purposes of marketing or advertising, you can withdraw your consent at any time by contacting us. You can exercise your right to prevent such use or processing by checking certain boxes on the forms we use to collect your personal data. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS or other means) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, subject to your consent. If you are a new customer, and where we permit selected third parties to use your data for marketing or advertising purposes, we (or they) will contact you by electronic means only, subject to your consent.
3. Legitimate business interests
We may also collect, use, disclose and process your personal data for the following purposes to safeguard, support and/or carry out our company’s legitimate business interests such as:
1. Where we store your personal data
The security of your personal data is our top priority. We shall take care in implementing and maintaining the security of our services and Applications, as well as that of your personal data. We employ procedures and policies that incorporate industry best practices to ensure the integrity of your personal data and to prevent instances of unauthorized use.
Please note that it is impossible to fully guarantee the security of your personal data. While we take reasonable steps to safeguard your personal data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from any unauthorized or unintended access that is beyond our control (e.g. hacking or cybercrimes), or abuse of your information. We recommend that you take independent safety precautions to protect your personal data, particularly your credential information such as your username and password. You hereby agree that we shall not be liable for any information leakage and other losses not caused intentionally or otherwise by our gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures. For the avoidance of doubt, we do not make any warranty, guarantee, or representation that your use of our systems or applications is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.
2. For how long will your data be stored?
We will process and store your personal data for as long as it is necessary in order to fulfill the purposes we collected it for, and to satisfy our business, contractual, legal, regulatory and/or statutory obligations (including audit, accounting or reporting purposes). We may thus be required to retain certain information, including personal data or information of users, users’ profiles, identification verification materials, information relevant to AML/KYC/CTF procedures, account information, account agreements, and other agreements between us and third parties, account statements, and other records, for an extended period of time.
We will assess and respond to requests to delete personal data and we shall accordingly delete personal data provided that the personal data is no longer required in order to fulfill our business, contractual, legal, regulatory and/or statutory obligations, or the fulfillment of any obligations to preserve records according to applicable laws and regulations.
In general, how long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may also be retained for longer e.g. where we are required to do so by law.
3. Anonymized data
In some circumstances we may anonymize and/or aggregate your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.
Your personal data may be made available, disclosed or shared to our related parties and/or within our group of companies in order to provide our services or Applications to you, for management and compliance purposes, and to utilize shared group IT functions.
We may share, transfer, disclose, or allow access to your personal data to third parties in connection with the purposes described in Clause II, including without limitation the purposes described below:
We will ensure that all companies and/or third parties to whom we disclose your personal data will only process it in accordance with our instructions and on our behalf. We will, where appropriate and permissible, enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws. All such companies and third parties will be required by us to meet the requirements of applicable data protection legislation and our strict privacy and retention policies to keep your personal data secure at all times.
When we transfer your personal data internationally and where required by applicable law, we will put in place appropriate safeguards, including but not limited to EU Model Clauses or rely on EU Commission adequacy decisions. You may obtain details of these safeguards by contacting us.
Other rules about personal informationl
We may use your personal information for market research purpose; the details will be hidden and can only be used for statistics. You can refuse to participate at any time. Any surveys and polls, which we require you to finish, cannot be transferred to third-parties. The only requirement is to disclose your email if you want to participate and the answer will be saved separately from your email.
We protect customers’ information by
We are NOT responsible for resolving all claims related to the interests of the members in the event that the personal information provided by the member when register is incorrect.
We will provide our users and members with information you should know before participating in the payment for service, ensuring the transactions are safe and secured.
We will have mechanisms/plans/solutions to ensure safe transaction. We will specify the security mechanism of customers’ payments, handling complaints and compensation for damage in the event of payment information of the customer via website has been altered, deleted, destroyed, copied, disclosed, illegally transferred, or caused damage to customers.
The collection and use of information for each customer is only done when there is the consent of the customer, except in the cases where enforced by the laws.