In addition to our duty of confidentiality to customers, we shall at all times fully observe the Personal Data (Privacy) Ordinance ("the Ordinance") of Hong Kong in collecting, maintaining and using the personal data of customers. In particular, we observe the following principles, save otherwise appropriately agreed by the customers:
- collection of personal data from customers shall be for purposes relating to the provision of financial services or related products;
- all practical steps will be taken to ensure that personal data are accurate and will not be kept longer than necessary or will be destroyed in accordance with the internal retention period;
- personal data will not be used for any purposes other than the data that were to be used at the time of collection or purposes directly related thereto;
- personal data will be protected against unauthorized or accidental access, processing or erasure;
- customers have the right of access to and for correction of their personal data held by us and that customers' request for access or correction will be dealt with in accordance with the Ordinance.
A customer's personal data is classified as confidential and can only be disclosed by us where permitted by the Ordinance or otherwise legally compelled to do so.
1. Personal Information we collect
We collect personal information when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
A. Information You Provide to Us
Account Creation: When you create an account or otherwise use the Services, we collect information such as your name, email address, password, ID documents, personal profile information, role within your team or enterprise, and others (“Personal Data“). It is mandatory for you to provide Personal Data; or else we will not be able to open an account for you and provide our services. We may also collect additional information which you can choose to share optionally such as your profile photo.
Your Communications with Us: We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us. We also collect the contents of messages or attachments that you may send to us, as well as other information you choose to provide, and that may be associated with your communications.
Payment Information: When you choose to subscribe for an investment or other paid service, we will collect payment information allowing you to pay us. Depending on the payment option chosen by you we use third-party payment providers to process payments on the Services. We may receive information associated with your payment information, such as billing address and transaction information, but we do not directly store payment information on the Services.
Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features: We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide via the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you understand that the personal information provided by you may be viewed and used by third parties for their own purposes.
Registration for Contests: We may run sweepstakes and contests. Contact information you provide may be used to inform you about the sweepstakes or contest and for other promotional, marketing and business purposes.
Conferences, Trade Shows, and Other Events: We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in the Services.
Job Applications: We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
B. Information Collected Automatically
Automatic Data Collection: We keep track of certain information about you when you visit and interact with any of our Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
- Cookies: Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
C. Information from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as a social networking site or a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings.
2. How we use your information
We use your personal information for a variety of business purposes, including to:
Provide the Services or Requested Information, such as:
- Opening, managing and maintaining the continuation of your accounts with us;
- Fulfilling our contract with you and performing our obligations under any agreement between you and us or other partners;
- Communicating with you, including updates on your investment process status, updates on your portfolio and generally providing newsletters and marketing materials;
- Managing your information;
- Complying with our requirements to make disclosure under any law, regulation or court order, or under and for the purposes of any guidelines issued by regulatory or other authorities;
- Processing your payments and otherwise servicing your investments and service purchases;
- Responding to questions, comments, and other requests;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support.
- Any other purpose directly related to the above-mentioned purposes.
Serve Administrative Purposes, such as:
- Authenticating and verifying individual and corporate identities and records of your account(s);
- Preventing and prosecuting potentially prohibited or illegal activities;
- Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Measuring interest and engagement in our Services, including analyzing your usage of the Services;
- Designing financial services or related products for your use and improving the Services;
- Ensuring internal quality control and safety;
- Fulfilling our duty under know-your-customer and anti money laundering provisions;
- Carrying out audits;
- Enforcing our agreements; and
- Complying with our legal obligations.
Marketing Our Products and Services: We may use personal information to tailor and provide you with content and advertisements. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us as set forth below.
Sharing Personal Information with our Partners: We may share personal information with our partners that provide investment products and other services to you.
Consent: We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use: We may use personal information and other data about you to create de-identified and/or aggregated information. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
If you have any questions or concerns about how such personal information is handled or would like to exercise your rights, you should contact the person or entity representing our partner (i.e., the data controller).
We use the following sub-processors:
- [Amazon Web Services](https://aws.amazon.com/) (USA)
- [MongoDB](http://www.mongodb.com) (USA)
- [PDFMonkey](https://www.pdfmonkey.io/) (USA)
- [Sendgrid](http://www.sendgrid.com) (USA)
- [Stripe](http://stripe.com) (USA)
- [Vercel](https://vercel.com/) (USA)
How We Use Automatic Collection Technologies: Our uses of Technologies fall into the following general categories:
- Operationally Necessary;
- Performance Related;
- Functionality Related; and
- Advertising or Targeting Related.
Cross-Device Tracking: Your browsing activity may be tracked across different websites and different devices or apps to provide a better experience for you. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
3. Disclosing your information to third parties
We may share your personal information with the following categories of third parties:
Service Providers: We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.
Business Partners: We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.
Affiliates: We may share personal information with our affiliated entities.
Advertising Partners: We do not use or share your information, including personal information, to advertise any third party’s products or services via the Services. We may use and share your personal information with third-party advertising partners to market our own Services and grow our Services’ user base, such as to provide targeted marketing about our own Services via third-party services. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.
4. International Data Transfers
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, Hong Kong SAR, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
5. Your Choices
General: You may have the right to object to or opt out of certain uses of your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
Mobile Devices: We may send you push notifications through our Apps. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our Apps. You may opt out of this collection by changing the settings on your mobile device.
Cookies and Interest-Based Advertising: You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android (https://support.google.com/googleplay/android-developer/answer/6048248?hl=en) and iOS (https://support.apple.com/en-us/HT202074). The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. Please note you must separately opt out in each browser and on each device.
6. Your Privacy Rights
Depending upon your location and in accordance with applicable laws, you may have the right to:
- Access personal information about you consistent with legal requirements and to information about the ways in which we have used and disclosed that information.
- Request Correction of your personal information where it is inaccurate or incomplete.
- Request Deletion of your personal information, subject to certain exceptions prescribed by law.
- Request Restriction or Object to Processing of your personal information by us.
- Ascertain our policies and practices in relation to your Personal Data.
If you would like to exercise any of these rights beyond the functions around privacy rights offered on our applications, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to submit your request via your account.
7. Data Retention
8. Security of your Information
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
9. Third-Party Websites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
10. Children's Information
The Services are not directed to users under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
11. Supervisory Authority
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
12. Additional Terms
For customers using Evident to from the European Economic Area (EEA), Switzerland, or the United Kingdom:
EU Data Protection Addendum. If Evident will be processing personal data from the EEA, Switzerland, or the United Kingdom on your behalf, a Data Protection Addendum and provisions in context of the General Data Protection Regulation will apply. For more information please refer to [GDPR Provisions](https://www.notion.so/GDPR-Provisions-4d7ed3db546c48278be46cafe4cb8f65) .