PRIVACY POLICY

This policy is provided to the clients of Exchangers HK Limited in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”).

1. Disclosure Obligation

1.1

From time to time, it is necessary for clients and various other individuals (including without limitation applicants for foreign exchange and remittance services (collectively “money services”), corporate clients, the applicants’ shareholders, directors, controlling persons, officers and managers of a corporate client or applicant, partners or members of a partnership, beneficial owner, trustee, settlor or protector of a trust, account holder of a designated account, payee of a designated payment, representative, agent or nominee of a client, or any other persons with whom a client has a relationship that is relevant to the client’s relationship with Exchangers HK Limited or its associates) (collectively “data subjects”) to supply Exchangers HK with data in connection with various matters such as the opening or continuation of accounts and the establishment or continuation of business relationship or provision of money services or compliance with any laws, guidelines or requests issued by regulatory or other authorities.

1.2

Failure to supply such data may result in Exchangers HK being unable to approve the opening of or continue accounts or provide money services.

1.3

Exchangers HK will collect data from the following: (i) the data provided by the data subjects for the handling of money services, when data subjects instructs to execute remittance), (ii) a person acting on behalf of the data subjects whose data are provided, and (iii) other sources (for example, information obtained from data agencies).

2. Use of Personal Data

2.1

Users

All personal data concerning the client (whether provided by the client or any other person, and whether provided before or after the date the client receives the Terms and Conditions containing this information) may be used by any of the following companies or persons (each, a “User”):

  • Exchangers HK and any of their associate companies (collectively “Exchangers HK”);
  • any director, senior officer or employee or the agent of Exchangers HK;
  • any person (such as lawyers, advisers, nominee, custodian etc.) authorized by Exchangers HK when carrying out the client’s Instructions and/or the business of Exchangers HK;
  • any actual or proposed assignee of any rights and obligations of Exchangers HK in relation to the client;
  • any governmental, regulatory or other bodies or institutions, whether as required by law or regulations applicable to any member of Exchangers HK;
  • any financial institutions the client will or may transact with;
  • any third party service provider who provides administrative, telecommunications, computer, payment, debt collection or securities clearing or other services to Exchangers HK in connection with the operation of its business (including their employees, directors and officers);
  • any person in accordance with applicable laws and regulatory requirements including through or pursuant to any rules, judgment, decision or ruling of the courts, arbitral tribunals, Financial Dispute Resolution Centre Limited, governmental, regulatory or other bodies or institutions, whether as required by the laws and regulatory requirements; and
  • any institutions (for example the beneficiary bank) and their employees, directors and staffs that must be involved in order to handle the money services instructed by the data subject.

2.2

Purposes

All personal data concerning the client may be used by any User for the following purposes:

  • the processing of applications for, and daily operation of services provided by Exchangers HK to client and, where appropriate, non-client or to other persons for whom client acts as guarantor or for whom client provides third-party security;
  • the managing of relationship of clients and non-clients;
  • maintaining client’s or any surety’s credit history for present and future reference;
  • carrying out new or existing client verification and credit checking procedures and assisting other financial institutions to do so;
  • ongoing Account administration and services in connection with the client's account, including the collection of amounts due, enforcement of security, charge or other rights and interests;
  • designing further products and services or marketing existing or future products and services of IPS to the client;
  • transferring of such data to any place outside Hong Kong;
  • comparison with the client’s personal data (irrespective of the purposes and sources for which such data were collected , and whether collected by a User or any other person) for the purpose of: (A) credit checking; (B) data verification; and/or (C) otherwise producing or verifying data which may be used for the purpose of taking such action that a User or any other person may consider appropriate (including action that may relate to the rights, obligations or interest of the client or any other person);
  • designing money service-related services and products for the data subject;
  • the enforcement of data subjects’ obligations, including without limitation the collection of amounts outstanding from data subjects and those providing security or guarantee for data subjects’ obligations;
  • providing on the terms of any other agreements and services relating to the client;
  • meeting any obligations, requirements or arrangements in connection with any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future (“Laws”) (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
  • meeting any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future and any international guidance, internal policies or procedures (e.g. guidelines or guidance given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information);
  • meeting any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents with jurisdiction (together the “Authorities” and each an “Authority”) that is assumed by, imposed on or applicable to Exchangers HK;
  • any other purpose relating to the execution of the client's Instructions or in connection with the business or dealings of Exchangers HK
  • complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
  • conducting any action to meet obligations of Exchangers HK to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/ or any acts or attempts to circumvent or violate any Laws relating to these matters;
  • enabling an actual or proposed assignee of Exchangers HK, or participant or sub-participant of Exchangers HK’s rights in respect of the data subject to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;
  • verifying data subjects’ identities with any financial institutions in connection with any transactions; and
  • purposes relating thereto.

2.3

Use of Data in Direct Marketing

Exchangers HK intends to use and/or transfer the client’s data to any related companies of Exchangers HK for direct marketing and Exchangers HK requires the consent (which includes an indication of no objection) of the client for that purpose. In this connection, please note that:

  • your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by Exchangers HK from time to time may be used by Exchangers HK in direct marketing;
  • the following classes of services, products and subjects may be marketed:
    1. money exchange, remittance, cryptocurrency transaction and related services and products;
    2. reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to in clause 2.3(b)(i) above; and
    3. donations and contributions for charitable and/or non-profit making purposes.

If a client does not wish Exchangers HK to use and/or transfer the client’s data for use in direct marketing, the client may, without charge, exercise the right to opt-out.

3. Rights of Access and Correction

3.1

The client has the right to have access to and correction of the client’s personal data as set out in the Ordinance. In general, and subject to certain exemptions, the client is entitled to:

  • enquire whether Exchangers HK holds personal data in relation to the client;
  • request access to the client’s personal data within reasonable time, at a fee which is not excessive, in a reasonable manner and in a form that is intelligible;
  • request the correction of the client’s personal data; and
  • be given reasons if a request for access or correction is refused, and object to any such refusal.

4. Contact Person

4.1

If the client wishes to request access to and/or correction of personal data concerning the client, the client should address the client’s request to the Data Protection Officer at Exchangers HK. Contact of the Exchangers HK’s Data Protection Officer is:

Address: RM 1015, 10/F, Beverley Commercial Centre, 87-105 Chatham Road, Tsim Sha Tsui, Kowloon, Hong Kong

5. Other Disclaimer

5.1

Exchangers HK endeavors to ensure the accuracy and reliability of the information provided on or through the website(s) of Exchangers HK but do not warrant or guarantee its accuracy or reliability and accepts no liability (whether in tort or contract or otherwise) for any loss or damage arising from any inaccuracies or omissions or otherwise howsoever arising.

5.2

By accessing this site and any of its pages clients are agreeing the terms and conditions set out above.

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Exchangers HK, Ltd.

Hong kong

Opening hour : 10:00~18:00