Last edited – 17/07/2024

Notifs Privacy Policy

Your privacy is important to us. We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements under applicable laws and regulations. We are equally committed to ensuring that all our employees and agents uphold these obligations. This policy explains how we manage personal information within our organisation.

How we collect personal information?
1. when you register for an account on our website;
2. when you order products or services from us;
3. when you subscribe to our newsletter or fill out a form;
4. when you submit a query or request to us; and
5. when you apply for a job with us.

In some cases we may be required by law to collect certain types of personal information about you.

Where we collect personal information from you, we will generally do so ourselves.
However, in some cases we may collect personal information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

What information do we collect?
1. identifying information, such as your name;
2. enhanced identifying information, such as a copy of your identity card,
passport or proof of address information;
3. contact information, such as your e-mail address, mailing address or phone
number;
4. usernames and passwords that you create and additional information that
you provide (such as your digital wallet address) when you register for an
account with us;
5. social media information, such as the username of your Facebook, Instagram
and Telegram accounts and comments/messages/posts you make via our
social media platforms; and
6. records of our communications with you, including any messages you send to
us.

Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

You may, however, visit our site anonymously.

What do we use your personal information for?

We may use your personal information for the following purposes:
1. to primarily verify your identity in accordance with anti-money laundering
requirements when you are dealing with us;
2. to determine your eligibility for any of our products or services;
3. to answer your queries or requests;
4. to enable us to provide our products and services and personalise your
experience by better responding to your individual needs;
5. to improve our website based on your information and feedback;
6. to process digital asset transactions;
7. to send periodic emails for keeping you informed of our activities, such as
information and updates pertaining to your order, occasional foundation
news, updates, related product or service information;
8. to comply with our legal and regulatory obligations (including but not limited
to verifying your identity and obtain additional information when appropriate);
9. to manage and resolve any legal or commercial complaints or issues; and
10. to carry out planning and forecasting activities and other internal processes.

Direct marketing
We may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). We will not use your personal information for direct marketing purposes unless we have received your consent. We will not provide your personal
information to any third parties for direct marketing purposes. You can, at any time, opt-out of receiving marketing communications from us by clicking the “unsubscribe” link on our e-mails or by contacting us (see Contact Details section at the bottom).

We may use your following personal information for the purpose of direct marketing:
1. identifying information, such as your name;
2. contact information, such as your e-mail address, mailing address or phone
number;
3. products and services portfolio information and demographic data held by us
from time to time
We may use your personal information to market the following products and/or
services to you, in each case subject to our legal and regulatory obligations:
1. purchasing and/or trading digital assets;
2. providing, managing or accessing mobile wallets and/or debit cards for
holding digital assets;
3. over-the-counter digital asset trading; and
4. other products or services related to digital assets.
We may also use and disclose your information for other purposes in accordance
with your requests or instructions.

How do we protect and store your information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. All personal information provided to us is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our database, which can only be accessed by those with special
access rights to our systems, and are required to keep the information confidential.

We also take steps to monitor access to and modification of your information by our contractors, advisers, consultants and staff members, and ensure that they are aware of and properly trained in their obligations for managing your privacy.

We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical
storage facilities. Unless required by legal or regulatory obligations, we will not keep your personal information for longer than is necessary for the fulfilment of the purpose of collection.

Do we use cookies?
Yes, we use cookies to help us remember and understand your preferences for future visits.

“Cookies” are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information and the webpage you are currently viewing. Most internet browsers have a facility that will allow you to disable cookies altogether – please refer to your browser’s help menu to find out how to do this. While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

Do we disclose any personal information to third parties?
We do not sell or trade your personally identifiable information to any third parties.
We may share personal information about you with:
1. your representatives, advisers and others you have authorised to interact
with us on your behalf;
2. our staff, contractors, advisors and consultants who need the information to
discharge their duties for the purposes as described above;
3. related entities to our foundation for the purposes described above;
4. our business partners engaged in digital asset services and development;
5. our agents and service providers that assist us in operating our website,
providing products and services to you, or otherwise conducting our
business;
6. other parties for marketing and advertising uses; and
7. government authorities who ask us to disclose that information, or to other people as required by law.

In some cases the people to whom we disclose your personal information may be located overseas. Further, we may have servers located overseas. There may not be in place data protection laws which are substantially similar to, or serve the same purposes as the applicable data privacy laws in Hong Kong. This means your personal information may not be protected to the same or similar level in Hong Kong.

Access and correction
If you want to access any of the personal information that we hold about you or to correct some aspect of it (eg because you think it is incomplete or incorrect), please contact us using the contact details set out below. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it
would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.

Even if you do not request access to and/or correct your personal information held by us, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.

Third party links
Occasionally, at our discretion, we may include links to third party products or services on our website. These third party sites have separate and independent privacy policies. Further, we do not verify their content. We therefore have no responsibility or liability for the content and activities of these linked sites.

Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Your Consent
By using our website, providing personal information, using any of our products or services and/or ticking the relevant opt-in box provided, you agree that:
• you consent to this privacy policy, as updated from time to time; and
if you have provided personal information to us relating to any other person, you:
• have a right to provide that information;
• have provided a copy of this privacy policy, as updated from time to time, to
that person; and
• each such person has agreed to those terms.

In such cases, references in this privacy policy to terms such as “you” and “your” also refer to such persons. Please note that for the purposes of direct marketing as described in this privacy policy, your express consent will be explicitly sought.

Changes to our Privacy Policy
We may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations. The latest version of this policy will be available at www.notifs.co.

Complaints
We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal information and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact us using the contact details set out below.

We will make a record of your complaint and refer it to our internal complaint resolution committee for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Hong Kong Privacy Commissioner for Personal Data.

Contact details
If you want any further information from us on privacy matters, please contact our Data Protection Officer at:

hello@notifs.co