This Policy serves as a notice to you concerning how YBEX may collect, use, process, store and disclose your “personal data”, “personally identifiable information” or other personal information (collectively, “Personal Data”) in connection with your access to and use of the Marketplace through either the Website or the App.
From time to time, it is necessary for you to provide us with Personal Data in connection with your use of the Marketplace. By agreeing to the User Agreement and completing the user registration, or by continuing to download, access or use the Website or the App, you will be deemed to have agreed to the terms of this Policy.
YBEX pledges to meet fully the requirements of the Personal Data (Privacy) Ordinance (Cap. 486). In doing so, we will ensure that our staff will strictly adhere to the terms of this Policy, including the security and confidentiality of your Personal Data.
Collection of Personal Data
In the course of your access to and use of the Marketplace through the Website or the App, you may disclose or be asked to provide or we may collect your Personal Data, including:
Information about your computer, mobile device or other item of hardware through which you access and use the Marketplace (including without limitation your IP address, geographical location, browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views, and any search terms you use); and
Information including your name, address, email address, phone number, age, sex, date of birth, nationality, proof of identification and proof of address.
The above information obtained by us may constitute your Personal Data. We have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services. Although you are not obliged to provide such Personal Data to YBEX, it may result in us not being able to render certain services to you in the event that you fail to do so.
Use of Personal Data
We may use the Personal Data that we obtained about you for the following purposes, including to:
Identify you as a user of the Marketplace;
Enable you to use the Marketplace;
Provide our services to you on the Marketplace;
Facilitate the Service Providers in providing to you remittance and money changing services;
Assist the Service Providers in complying with their obligations on anti-money laundering and counter-terrorist financing;
Provide you with marketing and promotional materials for your enjoyment or benefit as a member of the Marketplace (for further details, please refer to the paragraph entitled "Subscription of Newsletter/Promotional Materials/Marketing Materials" below);
Enable us to select and present information that matches your needs or to create personalized contents;
Design and provide products and services to you;
Compile and analyze information and aggregate statistics about your use of the Marketplace;
Notify you of changes we have made or plan to make to the Marketplace;
Request your feedback or comments regarding the Marketplace and Service Providers;
Deal with your enquiries or complaints regarding the Marketplace and Service Providers;
Analyze and improve the services offered on the Marketplace;
Protect and defend our rights, properties, employees, directors, shareholders, consultants and customers;
Make disclosure as may be required by any applicable law or regulation, government official or other authorities, or pursuant to any subpoena, court order or other legal process or requirement applicable to us or our affiliate; and
Enable any due diligence or other appraisals or evaluations for actual or proposed merger, acquisition, joint venture or financing transactions.
Disclosure or Transfer of Personal Data
Your Personal Data held by us will be kept confidential but YBEX may provide such information to the following parties (whether within or outside Hong Kong) in connection with the above purposes:
Affiliated entities of YBEX and their personnel and staff;
Entities with whom YEBX maintain referral or other commercial arrangements, including the Service Providers;
Any agent, contractor or third party that we work with in providing you with our services, including for fraud prevention, data entry, database management, promotions, marketing, customer service, technology services, and products and services alerts;
Entities that may be involved in any merger, acquisition, financing transactions or joint venture with us; and
Professional advisers, law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which YBEX is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement.
Subscription to Newsletter, Promotional Materials, or Marketing Materials
We may from time to time send you newsletters, promotional materials, and marketing materials based on your Personal Data. We may use your Personal Data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
Certain Personal Data held by YBEX from time to time may be used by us and/or our authorized personnel or staff in direct marketing;
YBEX may market to you goods and services which we believe may be of relevance to you. This may include goods and services that are offered by us, any of our affiliates, our business partners such as the Service Providers;
YBEX may also provide your Personal Data to certain third parties for use by them in marketing their own goods and services, including (i) our affiliates, (ii) business partners such as the Service Providers, and (iii) other third parties; and
Your consent to the use of your Personal Data for direct marketing purposes may be solicited by way of a check box at the time of user registration.
Suitable measures are implemented to make available to you the option to opt out of receiving such materials. In this regard, you may choose to sign up or unsubscribe for such materials by contacting email@example.com.
Cookies and Log Files
Our software will record the domain name server address and track the pages you visit and store such information in cookies, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without you being aware that they are occurring.
The security of your Personal Data is important to us. YBEX will always strive to ensure that your Personal Data is protected against unauthorized access. We have implemented appropriate electronic and managerial measures in order to safeguard, protect, and secure your Personal Data. All Personal Data obtained by us is only accessible by authorized personnel of YBEX or its authorized third parties, and such personnel and third parties would be instructed to observe the terms of this Policy when accessing such Personal Data.
YBEX follows generally accepted industry standards to protect your Personal Data, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, while YBEX strives to protect your personal information and data against unauthorized access, we cannot guarantee its absolute security.
You should safeguard your unique username and password by keeping them secret and confidential and never share them with anyone.
Retention of Personal Data
We will retain and procure our authorized third parties to retain your Personal Data only for so long as is necessary in accordance with the applicable laws and regulations.
Access and Contact Information
You are entitled to request access to or make amendments to your Personal Data kept with YBEX by contacting us by email at firstname.lastname@example.org. In the event that you wish to access or amend your Personal Data, we may request you to provide personal details in order to verify and confirm your identity. A HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. We may charge a reasonable fee for processing data access request.
Please contact us at email@example.com for any questions or comments regarding this Policy.