Privacy Statement

As a payment technology institution, processes large amounts of data from our customers, who are using the services provided by , and our customers’ customers (consumers). Both the customer and the consumer are invaluable to . Therefore it is extremely important to to ensure careful and secure processing of our customers’ and consumers’ data, in particular their personal data.

Through this Privacy Statement, (“”, “we”, “our”, “us”) informs you about the way in which processes personal data of (potential) customers, business partners, consumers and website users. At , we value your privacy. If you have any questions regarding our use of your personal data, you can reach out to us via the contact details provided at the bottom of this Privacy Statement.

Please read our Privacy Statement to understand how we process your personal data.

1. Who is ?
2. ’s responsibilities
3. What personal data does process?
4. Does process sensitive personal data?
5. Where does collect and use your personal data for?
6. How long does keep your personal data?
7. How does secure your personal data?
8. Does share your personal data with third parties?
9. Does use cookies?
10. What rights do you have?
11. How can you contact ?

1. Who is ?

is a payment service provider that offers her customers (for instance webshops) the possibility to accept online payments from their consumers (payers). is supervised by the Hong Kong Customs and Excise Department as a regulated payment service provider under Hong Kong law. Via , a customer can give its consumers the choice between different payment methods, such as bank transfer, credit card, afterpay and other payment methods. You could come into contact with if you have a webshop or want to use ’s services for other reasons, if you have paid via a webshop or website that uses ’s services.

2. ’s responsibilities

For all activities and purposes mentioned in this Privacy Statement, acts as the controller as referred to in the EU General Data Protection Regulation 2016/679 (GDPR). acts in this position that:
● Determines which personal data must be processed for the correct execution of a payment;
● Determines for which other purposes the personal data may be processed as long as these purposes are in accordance with the purpose for which the personal data were obtained by ;
● Has to comply with legal obligations, for example under the Hong Kong Customs and Excise Department, the Hong Kong Money Laundering and Terrorist Financing (Prevention) Act; and
● Has drawn up its own general terms and conditions that are directly applicable to the customer and the consumer.

3. What personal data does process?

processes your personal data because you use ’s services and/or because you provide personal data to yourself. An overview of the personal data processed by , depending on the product or service you use and in what capacity, is provided below.

Customer

Please note that in principle, we process data about your business. Business information is not considered personal data. However, if you act as a sole trader, (some of) your business information may be qualified as personal data. Therefore, the data listed below is personal data we will process from you (especially information about the legal representatives of your company). If you use ’s services as a customer, the following personal data are processed:

●Your first and last name;
● Your date of birth;
● Your place of birth;
● Your address details;
● Your telephone number;
● Your email address;
● Your IP address;
● Your internet browser and device type;
● Your ID document details (if you are the legal representative);
● Other personal data that you actively provide, for example by creating a personal environment on our website, in written correspondence and via telephone.

Consumer

If you use ’s services as a consumer, the following personal data are processed:

● Your payment details (e.g. bank account number or credit card number);
● Your IP address;
● Your internet browser and device type;
● In some cases, your first and last name;
● In some cases, your address details;
● In some cases, your e-mail address and/or telephone number;
● In some cases, information about the product or service that you have purchased from our customer;
● Other personal data that you actively provide, for example in written correspondence or via telephone when you contact our customer service.

The cases in which we might process your personal data but don’t always necessarily do so, might depend on for example the payment method you use, the API's our customers use and whether you as consumer contact our customer service.

Business Partner

If you are our business partner, the following personal data are processed:

● Your first and last name;
● Your telephone number;
● Your email address;
● In some cases and depending on the relationship, your ID document details;
● Other personal data that you actively provide, for example in correspondence via e-mail and telephone.

4. Does process sensitive personal data?

’s websites, services and products are not aimed at activities that require special categories of personal data to be processed. therefore requests that you do not provide any of such information. Furthermore, has no intentions at all of collecting personal data about website users who are minors, even if they have permission from their parents or guardians. Unfortunately, cannot check whether a website user is a minor and therefore advises parents or guardians to be involved in their children’s online activities in order to prevent minors’ data from being processed by .

5. Where does collect and use your personal data for?

If you (apply to) use ’s services as a customer, your personal data are processed for the following purposes:

● To assess your application;
● To draft and perform the agreement;
● To process payments;
● To send information about your product or service and updates and/or changes to it;
● To contact you in relation to your experience with our products and services and to inform you of other new or relevant products or services;
● To perform analyses for statistical and scientific purposes;
● To record evidence (if necessary);
● To provide support (such as via e-mail and phone);
● To ensure the safety and integrity of the financial sector, for example by identifying, investigating, preventing and actively countering (attempted) criminal/illegal conduct;
● To perform identity verification, customer due diligence (CDD), and ongoing monitoring as required under applicable AML/CTF regulations;
To comply with legal obligations as a financial institution, for example under the Hong Kong Customs and Excise Department and the Hong Kong Money Laundering and Terrorist Financing (Prevention) Act).

your personal data are processed for the following purposes:

● To process payments;
● To draft and perform the partnership agreement;
● To contact you in relation to your experience with our products and services and to inform you of other new or relevant products or services;
● To perform analyses for analytical and statistical purposes;
● To train and assess employees;
● To record evidence (if necessary);
● To provide support (such as via e-mail and phone);
● To ensure the safety and integrity of the financial sector, for example by identifying, investigating, preventing and actively countering (attempted) criminal/illegal conduct;
● To comply with legal obligations as a financial institution, for example under the Hong Kong Financial Supervision Act (Hong Kong Customs and Excise Department) and the Hong Kong Money Laundering and Terrorist Financing (Prevention) Act.

6. How long does keep your personal data?

will not retain your personal data longer than the mandatory statutory period or, if such a mandatory statutory period does not apply, no longer than is strictly necessary for the realisation of the purposes for which your personal data were obtained. For example, the personal data that receives relating to the assessment of your application as a customer, the preparation and performance of the agreement and the processing of payments, will not be kept longer than five years after rejection of your application or the termination of the agreement. This period has been determined in the Hong Kong Money Laundering and Terrorist Financing (Prevention) Act.

7. How does secure your personal data?

The protection of your personal data is very important to . has therefore taken various technical and organisational security measures to protect your data and to comply with applicable laws and regulations. uses, for example, network segmentation, techniques such as firewalls, anti-DDoS systems and file integrity monitoring, strong authentication, encrypted transfer of information, monitoring and alerting, and industry best practices for adequate encryption and system configuration.

Furthermore, organisational measures include role separation, least-privilege principles, personnel screening, strict procedures for managing adjustments, incidents, vulnerabilities and suppliers, and continuous training of our staff. The functionality of our security measures is tested periodically.

8. Does share your personal data with third parties?

Processors

shares your personal data with third parties if this is necessary to provide our products and services. When third parties will process your personal data on our behalf and under our strict instructions, those third parties act as so-called processors. concludes a data processing agreement with processors. This way, ensures that your personal data are always processed in a careful manner, protected with at least the same level of security we maintain and that the confidentiality of your personal data is guaranteed. nevertheless remains fully responsible for these processing operations and will therefore take all reasonable administrative, technical and physical measures to protect your personal data against unauthorised access, unintentional loss or alteration.

(Joint) Controllers

In those cases has concluded agreements in order to guarantee a thorough protection of your personal data where this is desirable or where required (namely where both parties acties as joint controllers).

If your personal data will be shared with third parties for purposes other than those described above, will only do so when legally permitted or after we have obtained your consent.

Cross-border data transfers

When providing our services, your personal data may in some cases be processed by third parties (as processor, as joint or independent controller) outside Hong Kong. If your personal data is processed outside Hong Kong. ensures that i) the correct contract is concluded with regard to data processing (processor agreement, joint controller agreement or controller-controller provisions if desired), and ii) an appropriate transfer mechanism is in place. In this way ensures that your personal data is always secured at at least the same level and that the confidentiality of your personal data is guaranteed.

9. Does use cookies?

uses functional, analytical and marketing cookies. A cookie is a small text file that is stored in the browser of your device such as a computer, tablet or smartphone when you first visit ’s websites. On the one hand, uses cookies with a purely technical functionality. These cookies ensure that the website works properly and, for example, remembers your preferred settings, so that is able to optimize the websites. On the other hand, uses cookies that keep track of your browsing behavior so that can offer you tailor-made content and advertisements. Some cookies on ’s websites are placed by third parties, for example advertisers and/or social media companies.

10. What rights do you have?

You have the right to access, correct, erase, restrict, transfer, or object to the personal data that processes, unless cannot execute these rights based on a legal obligation or whenever exceptions apply. For example, is required to keep certain personal and payment data based on legal obligations (as stated under point 6), which means that we cannot always delete all of your personal data when you request so.

You can send your request to exercise your privacy right(s) to [email protected]. prefers to establish that this request originates from you and that you are who you say you are. If we are not capable of verifying it is you directly, may ask you to send a copy of your identification (i.e. a passport or identity card). Please make sure that in this copy your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) have been redacted to protect your privacy. will then respond to your request as soon as possible, but in any case within one month after receipt, unless the request is of such excessive nature that we may extend that period with another 2 months.

11. How can you contact ?

If you have any questions regarding our use of your personal data, you can contact us via [email protected].