Protecting your privacy
We are dedicated to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and other relevant regulations where applicable.
We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us (including but not limited to the bullion account and forex account), developing and providing various financial and consultation services and the billing and charging of our products and services (if applicable) (collectively, “Service(s)”)) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:
(a) the name, birth month and other details documented on your passport or other legal identity card and/or travel document;
(b) the nationality/place of residence/location/personal information declared by you and other relevant documents;
(c) contact details including but not limited to name, address, phone number, mobile telephone number and/or email address, etc.;
(d) Data that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details), etc.;
(e) payment details including but not limited to credit card, debit card and other electronic banking Data;
(f) account details or Data relating to Services registered with us including but not limited to the relevant PIN, username or password, account numbers and/or service numbers;
(g) device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
(h) information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
(i) your credit and service history to enable us to assess your eligibility to our offers of Services or to accommodate your request for transfer of Services or your account with us;
(j) all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
(k) any other Data as may be required by any members of us and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Services.
(l) In some instances, where required by law to do so, we may seek your consent to process the following types of “Special Data” to us so that we may further improve our Services and/or better tailor the type of information or content that we present to you:
(ii) gender and ethnicity;
(iii) marital status;
(iv) Month of birth;
(v) education and profession;
(vi) monthly income range;
(vii) hobbies and leisure activities;
(viii) the Services that you have subscribed for; and
(ix) contact details, etc.
Provision of the Special Data mentioned immediately above is optional although, where the requested Service is a personalised Service or provision of a product is dependent upon your provision of all requested Data, failure to provide the requested Data may prevent us from providing those particular Services to you.
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