Privacy Policy

Effective date: February 1st, 2024
Last updated: July 25th, 2024

1. INTRODUCTION

This privacy policy ("Privacy Policy") governs the collection, processing, sharing and use of your data in relation to your use of the platform, website, the applications and/or services operated by DolpTrade (collectively, the “Services”). In this Privacy Policy, "we", "our" and "us" refers to DolpTrade Group, together with our parent and affiliates, and "you" refers to the user of the Services.

We will use and process your data in accordance with the provisions of this Privacy Policy and applicable laws. By continuing to use the Services or to access our platform, website or web contents, you are deemed to have accepted the terms of this Privacy Policy, and to expressly acknowledge and, where required, consent to our processing of your data for the purposes outlined in, or otherwise in accordance with, this Privacy Policy. If you do not agree with the terms of this Privacy Policy, we may not be able to make the Services available to you.

For the purpose of this Privacy Policy,“data”means all and any data we collect,use and process during your use of the Services.

2. SCOPE OF THIS PRIVACY POLICY

To the extent there is any inconsistency between this Privacy Policy and the any other privacy statement or information collection statement you have consented to, this Privacy Policy shall prevail.

Please also note that this Privacy Policy does not apply to: (i) information collected by third-party service providers (including any third-party websites) that you may access through the Services; or (ii) information collected by other companies and organisations who advertise their services via our Services.

3. CONSENTS FROM CONNECTED PERSONS

To the extent that you provide data relating to any other person, including: (1) officers, directors, staff, employees, partners, agents or other representatives of any company or business you represent; and (2) your customers (each a “Connected Person”), you agree and acknowledge that you have notified the Connected Persons of this Privacy Policy and obtained their express consents to the use, retention and transfer of their data in accordance with this Privacy Policy (including any amendments or revisions thereto). You further agree and acknowledge that we are not responsible for any loss incurred due to or in relation to the failure of you to obtain such consent from any Connected Person.

4. CHANGES TO THIS PRIVACY POLICY

We may from time to time amend, supplement, revise, alter or add specific instructions, policies and terms to this Privacy Policy. All such amendments, supereminent, revisions, alterations or additions shall form part of this Privacy Policy.

Your use of the Services indicates your acceptance of the current version of this Privacy Policy, which may be amended from time to time. You can determine when this Privacy Policy was last revised by referring to "Last Modified" at the top of this Privacy Policy.

If we consider any changes to this Privacy Policy to be reasonably material, we will notify you prior to the change becoming effective. Notice of any change to this Privacy Policy will be posted via our Services, sent via direct communications to you or through other channels. If you do not agree to these changes, you should stop using our Services. By continuing to use our Services after any changes to this Privacy Policy, you are deemed to have accepted to the revised Privacy Policy.

5. COLLECTION OF DATA

The types of data we collect may include, but is not limited to:

(a) contact information: such as your (or Connected Persons’) legal name, business name, contact information, mailing address, email address, region of residence and telephone and mobile phone number;

(b) business information: such as your (or Connected Persons’) business registration number, business registration type, business licence, business registration certificate, registered address, business address, legal representative details, taxpayer identification number, VAT number, VAT certificate, registration region, date of registration and validity of registration;

(c) sales information: such as your (or Connected Persons’) resell permit, third-party sales website screenshots, sales platform details;

(d) Social account information: such as your (or Connected Persons’) social platform account, social platform link, social platform screenshots, and detailed information of the social platform to which you belong;

(e) bank account Information: such as your (or Connected Persons’) list of bank accounts owned and list of beneficiary bank accounts (including bank code, secondary bank code, bank region, bank account type, bank name, account number, etc.);

(f) transaction information: such as transaction date, transaction ID, transaction type, destination bank account (including bank name, bank code, secondary bank code, bank region, bank account type, bank account number, etc.), destination currency and transaction purpose; and

(g) know your client (KYC) information: such as KYC status and date of last KYC.

6. ACCURACY OF DATA

You are responsible for ensuring all data you provide is accurate and complete. Please see “Right to Access and Correction of Data” section for information about how you may access and correct your data.

7. PURPOSES OF USE OF DATA

You consent to our collection, holding, use and processing of your (and/or the Connected Person's) data for the following purposes and within the period necessary to achieve such purposes:

(a) to provide the Services to you;

(b) for customer onboarding and conducting screening, KYC or due diligence checks on you, your business and Connected Persons;

(c) to execute transactions for you, including billing and payment processing purposes;

(d) for administration and management of those services and goods which you have registered for and subscribed to, including the renewal of service contracts;

(e) to provide you with account registration, account setup and customer service and for verification of your identity, security, fraud-detection, archival and backup purposes in connection with the provision of the Services;

(f) for business planning and to develop and improve our Services, respond to customer queries and preferences, including through customer surveys, language and location customisation, personalised help and instructions, or other responses to your usage of the Services;

(g) to analyse, verify and enforce contractual rights, and/or to check your credit, payment and/or status in relation to supply of Services to you;

(h) to enable the daily operation of your account and/or to collect amounts outstanding in your account with us, including through the use of debt collection agents;

(i) to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services;

(j) to meet disclosure obligations and other requirements imposed by or for the purposes of any laws, regulations, rules, codes of practice or guidelines (whether applicable in or outside Hong Kong) binding on us and/or our affiliates anywhere in the world, including to make disclosure to any legal, regulatory, governmental, tax, law enforcement or other authorities (whether in or outside Hong Kong);

(k) to exercise our rights where it is necessary to do so, for example to detect, prevent, investigate and respond to security incidents or breaches, data scraping, fraud, abuse, intellectual property infringement claims, financial crimes and other potential breaches of applicable law;

(l) to maintain and develop our business systems and infrastructure, including to test and upgrade these systems, software verification or administering software upgrades;

(m) any other purposes as may be agreed to between you and us, including the purposes set out in any application or terms and conditions for the supply of specific Services; and

(n) to fulfill any other purposes directly related to (a) to (m) above.

8. DISCLOSURE AND SHARING OF DATA

All data held by us is kept strictly confidential but we may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide and transfer such information to the following parties (whether in Hong Kong or overseas):

(a) our subsidiaries, holding companies, associated companies and or affiliates of, or companies controlled by, or under common control with us;

(b) any person or company who is acting for or on behalf of us, or jointly with us, in respect of the purpose or a directly related purpose for which the data was provided;

(c) our business partners, agents, contractors, suppliers, service providers and other service providers engaged by us to assist with providing the Services, including service providers for purposes such as hosting or operating our Services, payment and transaction processing, rewards, vouchers and commercial goods delivery (where applicable), cloud services, e-mail communication, research, survey, marketing and data analysis services;

(d) any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureaux, or collection agencies, security agencies, necessary to establish and support the payment of any Services being requested;

(e) any law enforcement agencies, regulatory authorities, government departments and related organizations, courts and tribunals, as required or authorised by applicable laws;

(f) any proposed or actual participant, assignee or transferee of all or any part of our operation or business;

(g) any organisations who manage our business and corporate strategies (and for such purposes), including those involved in a transfer or sale of all or part of our assets or business and those involved in managing our corporate risk and funding functions;

(h) any other person or entity who is under a duty of confidentiality to us and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information.

9. COOKIES & SIMILAR TECHNOLOGY

A "cookie" is a small file containing a string of characters that is placed on your smartphones, tablets or other mobile or wireless devices when you access a website or other web content. We and our third-party tracking-utility partners may from time to time gather certain information automatically via such cookies and similar technologies and store it as log data.

We may use cookies and similar technologies on our website or other web content for various purposes, including:

(a) remembering you. For instance, cookies, and similar technologies can help us identify you as a registered user of our website or other web content or keep the preferences or information that you have previously provided;

(b) maintaining security and preventing fraud.

For a detailed policy please see our Cookies Policy, link: Cookies Policy

10. LOG FILES

We may automatically gather system-related and non-personally identifiable information and store it in log files, which are automatically recognised by our web server. This information includes IP addresses (the unique address which identifies your computer on the internet), browser type, ISP, referring/exit pages, operating system, data/time stamp, and clickstream data.

We may use this information, which does not identify users, to analyse trends, to administer our website or other web contents . We do not link this automatically-collected information to personally identifiable information.

11. ADVERTISING / DIRECT MARKETING

If you have elected to receive direct marketing communications from us, your (or Connected Persons’) data may be used by us to send you information about us and/or the latest news on our promotions and products. Such products and services (of ours or third parties) include the following:

(a) our Services and the products and services of our affiliate and subsidiary companies and business partners in relation to the facilitation of payment execution and transaction processing;

(b) third party providers of the above services and products and services relating to facilitation of payment execution and transaction processing and other products and services that we think may be relevant to you.

We may contact you via either e-newsletters and/or e-mails for this purpose. We will retain your (or Connected Persons’) data for as long as you wish to receive information from us. You can decide not to receive communications or updates from us at any time by: (i) notifying our Privacy Officer at [ support@dolptrade.com ]; or (ii) following the relevant instructions on our marketing communications.

Please note that we will not share your data with any advertisers unless you have given us your consent to do so.

For the avoidance of doubt, this consent is separate form and independent of the Services registered with us. Accordingly, it can be withdrawn at any time as per this Privacy Policy without reference to the duration of the Services, and will survive the termination or expiration of any applicable service contracts.

12. LINKS TO THIRD PARTY WEBSITES

Our platform, websites or web contents may contain links to other services (including websites) provided or operated by third parties. Your use of any such third party services, including any data you may provide to such third parties, may be subject to the third party’s terms of services and privacy policies. You should review these privacy policies carefully to understand the ways in which your data may be collected and used by such third parties.

This Privacy Policy only applies to any data collected by us, and does not apply to any services offered by or information practices of any third parties. We are not liable for any third party use of any data provided by you to them.

13. TRANSFER, STORAGE AND SECURITY OF DATA

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your data is used and stored may not be in your jurisdiction.

You hereby consent to the transfer of your data to places outside Hong Kong to carry out the purposes, or directly related purposes, as described in this Privacy Policy. If you provide data relating to the Connected Persons, you warrant that you have obtained their consents to the transfer of their data to places outside Hong Kong to carry out the purposes, or directly related purpose, as described in this Privacy Policy. Where such a transfer is performed, it will be done in compliance with the prevailing requirements of the applicable laws.

We treat the security of your (and Connected Persons’) data seriously. We utilize and use a variety of administrative, technical and physical safeguards and security measures to protect the data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and any other unlawful forms of processing. For instance, in some of our Services, we will use encryption technology (such as SSL) to protect certain sensitive Information provided by you to us. All the data is protected and only available to authorized personnel and subcontractors.

You should be aware that no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet. Our systems and the communications networks through which you access our Services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.

14. RETENTION OF DATA

Subject to applicable laws and regulations, we will only retain your (and the Connected Persons’) data for so long as is necessary to fulfil the purposes as set out under “Purpose of Use of Data” section above. Should your account be terminated for any reason, we will take steps to ensure that, subject to applicable laws and regulations and reasonable archival requirements, your (and the Connected Persons') data is no longer available through our Services, or otherwise used by us, within a reasonable period of time after such account termination.

15. RIGHT TO ACCESS AND CORRECTION OF DATA

You (and the Connected Persons) have the right to check what data we hold of you (or the Connected Persons) and to request correction of such data. If you wish to exercise the above mentioned rights, or if you have any questions about our processing of your (and the Connected Persons’) data, please contact our Privacy Officer via email at [ support@dolptrade.com ]. We will respond to all requests made to our [Privacy Officer] under this section in accordance with the prevailing requirements under applicable laws. Satisfactory proof and/or explanation of the inaccuracy is essential before we would consider correcting the specified data.

16. GENERAL

The English version of this Privacy Policy shall prevail over any other language's version (if any) which is provided for information purposes only.

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Privacy Officer via email at [ support@dolptrade.com ].