1.    Background

We recognize and value the trust that you place in us when providing us with your personal data. We are committed to safeguarding the privacy and security of your personal data. This Global Personal Data Protection Notice (this "Notice") is provided to you by Bletchley Park Asset Management (Hong Kong) Limited in connection with Bletchley Park Asset Management (Hong Kong) Limited's website, mobile application, platforms, services, or products that you access or use. 

References to “Eqonex”, "we", "our", or "us" in this Notice is to such relevant Eqonex entity. However, as noted below your information may be shared with other Eqonex Group entities.
If you are resident in the European Economic Area ("EEA") or the UK, then the entity giving you this Notice as listed above will be your main controller and have primary responsibility for processing your personal data and complying with the EU General Data Protection Regulation and the UK General Data Protection Regulation and companion privacy laws in the EEA and the UK (collectively, the "GDPR").  
To the extent personal data is collected in Singapore, by using the website, mobile application, platforms, products and services, you consent to the collection, use and disclosure of such personal data you provide to us pursuant to this Notice.

The Notice is intended to notify you as to how we process your personal data, and how you may exercise your rights with respect to such data. This Notice must be read with any other information that we may provide when we are collecting or otherwise processing your personal data. 
We may amend this Notice at any time. To the extent necessary under applicable law, we will notify you of material changes that we make to this Notice. You should cease using or accessing our products and services if you do not accept such changes. The word "including" or "for example" shall not be limiting in this Notice.  
In this Notice, "processing" or "process" shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

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2.    What personal data is being collected and how?

We may collect and otherwise process different types of personal data from multiple sources, including: (i) collecting personal data directly from you; (ii) personal data that is automatically generated about you; and (iii) personal data that we receive about you from other Eqonex Group entities or third parties. 

 

Personal data collected directly from you 

We may collect your personal data directly from you, for example, through: (i) our online or paper forms; (ii) entering into an agreement with us; (ii) online and other electronic platforms which we offer or which we have agreed that you may use; (iii) corresponding with us by email or post; (iv) speaking to us in person or over the telephone; or (v) visiting our offices. 

Your personal data that we may collect in this manner could include, your:

 

• Identity/Contact information: including your first name, last name, middle names, maiden name, marital status, title, date of birth, gender, and photograph identification, residential address, delivery address, email address, telephone numbers; 

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• Financial data: including your bank account and payment card details, revenue information, financial and investment background, monthly income amount, expected deposit amount, and source of funds;

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• Services data: including your usernames and passwords, details about payments to and from you, other details of services you have obtained from us or we have obtained from you, your digital wallets, and transaction information, and your interest, feedback and survey responses;

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• Professional information: including your job title, email address, phone number, addresses, employment status, employer name, previous positions, and professional experience; and

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• KYC/Verification information: including information about your criminal convictions and offences (if any), passport information, driving licence, national ID number, utility bill (or other proof of address document), country of residence, biometrics for liveness verification (e.g. selfies and videos), country of origin/nationality, country of domicile/tax residency, ongoing monitoring, PEP information, tax reference number.

 

Personal data collected automatically from you

We may collect your personal data from your use of Eqonex's (i) website; (ii) any platforms or exchanges; (iii) mobile applications; or (iv) other services or products operated by Eqonex: 

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• Usage data: including IP address, website usage and other technical data such as details of your visit to our websites, mobile applications, platforms, services services, or products or information collected through cookies and other tracking technologies (please refer to our Cookie Notice for more details); and

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• Information from our platforms and exchanges: including information collected through your use of the Eqonex's website, mobile applications, platforms, services, or other products (such as digital asset exchange or digital asset custody), including device type, operating system, browser, location and IP address.

 

Personal data received from other sources 

We may collect your personal data from: (i) publicly available information; (ii) third parties (such as other virtual asset service providers); and (iii) other Eqonex Group entities:

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• Identity/Contact Information & KYC/Verification information: including information obtained from third party service providers in carrying out KYC checks, other background checks, PEP/Sanctions screening, negative media screening, ongoing monitoring and any other checks required by law or regulation as well as through interactions with governmental or regulatory bodies or other authorities in relation to you or on your behalf;
   

• Financial data: including information from your bank or business partners;

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• Professional information: including from third party referees and other checks; and

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• Publicly available information: including information from public registers of individuals; public registers of companies, charities, law firms, chartered accountant, stock or commodities exchange participants, mutual and other entities; public registers of sanctioned persons and entities; other public sources.

 

Personal data that you provide to us relating to third parties

By providing us with any personal data relating to a third party (for example, personal data relating to your spouse or partner, children, parents, or a Connected Person), you hereby represent and warrant to us that you have (i) obtained the consent of such third party; or (ii) are otherwise permitted under applicable law, in either case (i) and (ii), to provide us with his/her personal data for us to process such data in accordance with this Notice. 

"Connected Person" may include any beneficial owner, authorised signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or granter of trust, mandate holder, power of attorney holder, surety, third party security provider, provider of funds, founder and/or employee, payee of designated payment, representatives, agents or nominees.

3.    What happens if you do not provide us with certain personal data?

Failure to provide us with the relevant personal data notably KYC/Verification information, in cases where you are legally or contractually required to provide it, may result in our being unable to establish or continue our business relationship with you or to provide products and services to you.

4.    How will the personal data be used?

The nature of your interaction with us will determine how Eqonex will process your personal data. The relevant specific purposes and lawful bases (to the extent required by applicable data protection laws) for which Eqonex will process your personal data are set out in the Tables of Processing below depending on which of the following categories applies:
•    For visitors to our website and mobile application
•    For users or prospective users of our platforms, products and services
•    For visitors to our offices
•    For representatives of our service providers or professional advisers or investors or other counterparties
•    For all visitors, users, representatives, professional advisers, investors and other counterparties

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