This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.
1. Introduction
HA HK Limited ("HHL", "we", "our" or "us") respects personal data privacy and is committed to handling personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the "PDPO") and its six Data Protection Principles.
This Privacy Policy explains how we collect, hold, process, use, disclose, transfer, retain and protect personal data when you visit our website, contact us, submit an enquiry, apply to become a customer or representative of a customer, or, following licensing and commencement of operations, use our services.
2. Information We Collect
We collect, use, store and transfer different kinds of personal data about or relating to you, including but not limited to the following:
a) Identity and Contact Information, including:
- where you act in your personal capacity: your full name, passport number or other government-issued identification number, telephone number, residential or mailing address, email address, social media profile details, copies or images of your passport or identification documents, photographs or other representations of your likeness (including biometric information where permitted by applicable law), utility bills, driving licences, or other address verification documents; and
- where you are a shareholder, beneficial owner, director, employee, guarantor, authorized signatory, or other authorized representative (each, a “Relevant Individual”) of a corporate customer: your full name, passport number or other government-issued identification number, telephone number, residential or mailing address, email address, social media profile details, copies or images of your passport or identification documents, photographs or other representations of your likeness, utility bills, driving licences, or other verification documentation.
b) Financial Information, including information relating to your financial status, background, payment history, source of funds, and account or payment details, such as bank account information, credit or debit card details, and other payment-related information.
c) Transaction Information, including details relating to fiat currency transactions, payment activities, and the issuance, transfer, settlement, custody, administration, recording, or processing of payment tokens, digital assets, or securities involving your accounts or transactions with us.
d) Technical Information, including information relating to the devices, systems, and technology you use to access our website, mobile applications, products, or services, such as internet protocol (IP) address, device identifiers, login credentials, browser type, operating system, and related technical data.
e) Usage Information, including information regarding your interaction with and use of our website, applications, products, and services, such as browsing activities, cookies, IP addresses, session information, account activity, and related usage analytics.
3. How We Use Your Information
We collect personal information for:
- Customer onboarding;
- Identity verification;
- AML/KYC compliance;
- Transaction monitoring;
- Fraud prevention;
- Regulatory reporting;
- Customer support;
- Service improvement.
4. Disclosure of Information
We may disclose information to:
- Regulators;
- Law enforcement agencies;
- Banking partners;
- Payment processors;
- Identity verification providers;
- Compliance screening vendors.
6. Data Retention
Your personal information will be retained only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable laws or regulations, including but not limited to licensing obligations, KYC/AML compliance requirements, counter-terrorism financing obligations, legal or regulatory reporting requirements, the establishment or defense of legal claims, or the protection of our legitimate business interests. Upon expiry of the applicable retention period, we will securely delete, destroy, or anonymize the relevant personal information in accordance with applicable laws and internal policies.
In order to provide the Services on a global basis and for the purposes described in this Privacy Policy, the personal information we collect may be transferred to, processed, or stored in jurisdictions outside the country or region in which you reside or access the Services. Such jurisdictions may have data protection laws that differ from those applicable in your location.
Where required under applicable laws, we will take reasonable and appropriate measures to ensure that your personal information remains protected during any cross-border transfer, processing, or storage, in accordance with this Privacy Policy and applicable data protection legislation. We will also require third-party recipients of your personal information to implement appropriate technical, organizational, and contractual safeguards to protect your information. Such measures may include entering into data processing agreements, adopting standard contractual clauses, or implementing other legally recognized transfer mechanisms approved by the relevant regulatory authorities.
If you would like further information regarding these safeguarding measures, please contact us using the contact details provided in this Privacy Policy.
7. Security Measures
We implement reasonable administrative, technical, and physical safeguards to protect personal information. All personal data is kept confidential and we take all reasonable measures to protect it from unauthorised or accidental access, misuse, disclosure, alteration, processing or loss, by implementing appropriate physical, electronic, administrative and supervisory controls.
8. Your Rights
Subject to applicable laws, you may request:
- Access to personal information;
- Correction of inaccurate information;
- Withdrawal of consent where applicable.