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Global Personal Data Privacy Notice


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.

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; 

  • 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;

  • 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;

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

  • 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: 

 

  • 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

  • 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:

 

  • 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;

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

  • 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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5.    Will my personal data be used for any automated decision-making (including profiling)?


In general, Eqonex will not conduct any processing activities relating to your personal data that involves any automated decision-making (including profiling). Typically there is always human involvement. However, where Eqonex makes a decision or profiles through automated means, then Eqonex will put systems in place that comply with applicable laws.


6.    Will your personal data be shared?


Eqonex is a global firm and as such any personal data that we collect, or you provide to us may be shared with and processed by any Eqonex Group entity, including employees and contractors that work for Eqonex for any of the purposes as listed in this Notice.
In addition, for the purposes as set out in this Notice, Eqonex may share personal data with third parties, including third parties in various jurisdictions around the world, including: Singapore, the European Economic Area, UK, Hong Kong, Australia, USA, Philippines, Vietnam, Seychelles and any other third party jurisdictions. The third party recipients with whom Eqonex may share personal data are set out in the Tables of Processing above.


In case of international transfers of personal data, the laws of certain jurisdictions may provide a lower level of protection with respect to your personal data relative to the laws of your home country. We will protect your personal data in such international jurisdictions in accordance with applicable law. To illustrate, if you are resident in the EU/EEA/UK, we have implemented the following safeguards in relation to international transfers of personal data to the extent required by applicable law:

 

  • As between different Eqonex Group entities, we have implemented Data Controller to Data Controller data sharing agreement that incorporates the European Commission-approved standard contractual clauses as well as additional country specific requirements); 
     

  • As between relevant Eqonex Group entities and its/their third party recipients, we have implemented either (i) Data Controller to Data Processor data transfer agreements that incorporate the European Commission-approved standard contractual clauses as well as additional country specific requirements; or (ii) Data Controller to Data Controller data sharing agreement that incorporates the European Commission-approved standard contractual clauses, as well as additional country specific requirements.

7.    How long do we keep your personal data?


We will retain your personal data only as long as is necessary to fulfil the purpose for which this data was collected, unless a longer retention period is required by applicable law.


To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


This means that we will usually keep your personal data for the lifetime of your use of our website, mobile application, platforms, services or products, and then thereafter for such period as we are required or permitted to keep your personal data under applicable laws after you have ceased to use our website, mobile application, platforms, services or products. In cases where you are not onboarded as a customer, we will usually keep your personal data for a limited period of time, unless you have subscribed to our mailing list, in which case we will retain your personal data until you unsubscribe.


8.    What rights do you have?


Under certain circumstances and in accordance with applicable laws, you may have the right to request us to:

 

  • provide access to personal data we hold about you;

  • rectify any inaccuracies in your personal data that we hold;

  • delete any of your personal data that we no longer have a legitimate interest to process;

  • where we process your personal data based on your consent, withdraw your consent so that we stop that particular processing;

  • port your personal data and to request the transmission of such data to another organization;

  • object to any processing of your personal data based on our "legitimate interests" unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

  • object to any processing of your personal data for direct marketing purposes (including any profiling activities in connection with direct marketing); or

  • restrict how we process your personal data whilst a data protection complaint is being investigated.

You may exercise any of these data protection rights (to the extent applicable) at any time using the contact details for Eqonex set out below. Some of these rights may be limited (e.g. the right to withdraw consent) where we are required or permitted by applicable laws to continue processing your personal data to defend our legal rights or meet our regulatory or contractual obligations. Depending on applicable laws a fee may be payable and there may be circumstances in which Eqonex can refuse your request. For example, Eqonex may, in certain circumstances and where allowed under applicable laws, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We also note in the section below titled “Additional considerations with respect to blockchain and digital assets” additional limitations with respect to your rights in connection with certain blockchain and digital assets


You may also have the right to complain to the relevant supervisory authorities or data protection regulators if your data protection rights have been infringed by us, including:
 

Hong Kong

https://www.pcpd.org.hk/english/complaints/how_complaint/flowchart/handling_flow_chart.html

 

Luxembourg

https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html

Philippines

https://privacy.gov.ph

Singapore

https://www.pdpc.gov.sg/Contact-Us

UK

https://ico.org.uk/make-a-complaint/

9.    Additional considerations with respect to blockchain and digital assets 


Importantly, you may not be able to exercise all of your data protection rights with respect to certain blockchain and digital assets. This is because certain blockchain records are public and decentralized, and we may not be able to (for example) alter, delete or modify such records in order to comply with your data protection-related requests.


10.    How to get in touch


If you have any query or concern or complaint in relation to this Notice and Eqonex's processing of your personal data, please contact: [email protected]

 

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