PRIVACY POLICY

Privacy Notice: Version 1                                        Effective date: 2 October 2024

  • I. Introduction

Shinglix LTD (“Shinglix”) (identification number 76315093) is a company incorporated under the laws of Hong Kong, with its registered office at Room 1406, 14/F, Solo Building, 41-43, Carnarvon Road, Tsim Sha Tsui, Hong Kong is the responsible party for the processing of Personal Data collected through your access of our Website, Apps and use the Services as per protection laws. Capitalised terms used in this Privacy Policy have the same meanings as those defined in Shinglix LTD Service Terms of Use and the Personal Data (Privacy) Ordinance (“Ordinance”).

This privacy policy (“Privacy Policy”) describes how and why we collect, store, use, and manage the information, and data, including Personal Data, that you provide or we collect when you visit our Website, Apps and use the Services. It also tells you how you can access and update and/or data and make certain choices about how personal information and/or data that you provide to us is used.

By accessing our Website, Apps and using the Services, you accept the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access to our Website, Apps or use of the Services.

We reserve the right to update or modify this Privacy Policy from time to time. Such updated or modified versions shall apply from the date of publication on Website and/or in Apps, unless otherwise expressly stated, and you waive any right you may have to receive specific notice of such changes or modifications. Your continued access to the Website and Apps or use of the Service shall constitute your acceptance of such updates or modifications.

  • II. How we process your Personal Data
  • 1. Principles of Personal Data processing

We are committed to protecting the privacy and security of Personal Data entrusted to us by you. In order to ensure transparency and compliance with applicable data protection laws and regulations, we adhere to the following principles of Personal Data processing:

Lawfulness, Fairness, and Transparency: we process Personal Data in a lawful, fair, and transparent manner. We ensure that you are aware of the purposes for which your Personal Data is collected, used, and disclosed. We also inform you about rights and provide with clear and easily understandable information about our data processing practices.

Purpose Limitation: we collect Personal Data for specified, explicit, and legitimate purposes, and we do not process Personal Data in a manner that is incompatible with those purposes. We only collect and use Personal Data to the extent necessary to fulfill the stated purposes and in accordance with the consent obtained, contractual obligations, compliance with legal obligations or legitimate interests.

Data Minimization: we only collect and process Personal Data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. We strive to minimize the amount of Personal Data we collect and retain, ensuring that the data is accurate, up-to-date, and necessary for the intended purposes.

Accuracy: we take reasonable steps to ensure the accuracy of Personal Data and keep it up-to-date. We rely on you to provide accurate and complete information, and we provide mechanisms to update or correct their Personal Data when necessary.

Storage Limitation: we retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. When Personal Data is no longer needed, we securely delete or anonymize it to prevent unauthorized access or use.

Integrity and Confidentiality: we implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, accidental loss, alteration, or disclosure. We maintain the confidentiality, integrity, and availability of Personal Data through physical, technical, and administrative safeguards.

Accountability: we take responsibility for our data processing activities and have implemented measures to ensure compliance with applicable data protection laws. We maintain records of our data processing activities, conduct regular assessments of our privacy practices, and provide training to our employees on privacy and data protection.

It is important to note that these principles guide our approach to Personal Data processing, and we continuously review and update our practices to ensure ongoing compliance with evolving legal and regulatory requirements.

  • 2. Scope

We only process your Personal Data if this is necessary to provide a functional Website, Apps or to provide you with our Services. The processing of Personal Data only takes place based on the appropriate legal basis and as permitted by law.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website, Apps or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Website, Apps, the choices you make and the products and features you use.

The personal information we may collect is described below:

Personal Information provided by you

You may provide information about you when you sign up to use Services. This also includes information you provide through your continued use of our Services, enter a competition, promotion or survey, and when you report a problem with our Services. The information you give us include your name, address, e-mail address, Wallet address, phone number, financial information (including credit card, debit card, or bank account information), geographical location, social security number, personal description and photograph.

We may also need additional commercial and/or identification information from your e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under Applicable Law.

In providing personal data of any individual (other than yourself) to us during your use of our Services, you warrant and represent that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Notice.

With regard to your use of our Services we may automatically collect the following information:

a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

b) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer support number.

Information collected from other sources:

We may receive information about you if you use any of the other websites we operate or the other Services we provide. We are also working closely with third parties and may receive information about you from them. For example:

a) The banks you use in the Service will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;

b) Partners may provide us with your data;

c) Advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our Website;

d) We may engage a Partner to carry out KYC and AML procedures, including information and documentation collection and processing.

e) We may collect and process information about you from publicly accessible sources or governmental and other databases.

  • 3. Legal basis for processing under Ordinance

We use the following legal bases when processing your Personal Data.

Processing necessary for the performance of the contract between you and us or in order to take steps at your request prior to entering into a contract with us

We may process data on this basis for the following purposes:

- To create and manage Client accounts, ensuring access to the Website, Apps and Services.

- To manage Wallet addresses.

- To provide customer support and address Client inquiries related to Website, Apps and Services usage.

Processing necessary for compliance with legal obligations

We may process data on this basis for the following purposes:

- Anti-Money Laundering (AML) Compliance: to verify Client’s identity and fulfill AML/CTF Requirements

- Regulatory Reporting: to compile and submit required reports to regulatory authorities.

Processing necessary to protect our legitimate interests

We may process data on this basis for the following purposes:

- To identify and prevent fraudulent activities.

- To implement security measures that protect Client’s funds and sensitive information.

- For analytics to improve the Website functionality and Client experience.

- To send promotional offers and updates about Website.

Processing based on your consent

We may process data on this basis for the following purposes:

- Customized services: to offer personalized experiences based on individual preferences.

- Data Sharing with Partners: to share specific information with third-party Partners for integrated services.

  • III. Automated Data Processing and Decision Making, Cookies
  • 4. Automated Data Processing

Every time you visit our Website, our system automatically collects data and information about the computer system you used to access our Website.

The following data may be collected:

  • Browser information (type and version);
  • Operating system;
  • Your internet service provider;
  • Your IP address;
  • Date and time of access;
  • Websites from which your system reaches our Website;
  • Websites accessed by the Client’s system via our Website.

The data is also stored in the log files of our system. This data is not stored together with your other Personal Data.

The data is stored in log files serves the purpose of ensuring the functionality of the Website. In addition, the data serves us to optimize the Website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

For data processing subject to Ordinance, the legal basis for the temporary storage of data and log files is our legitimate interests.

5. Automated Decision Making

We may use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of our services and to ensure decisions are fair, consistent and based on the right information. Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a person.

We may make automated decisions about you that relate to:

  • Opening accounts:
  • KYC, anti-money laundering and sanctions checks
  • identity and address checks
  • Detecting fraud:
  • monitoring your account to detect fraud and financial crime

Our legal basis is one or more of the following:

- keeping to contracts and agreements between you and us

- legal obligations

- legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities)

  • 6. Cookies

In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted Service, we use cookies and similar technologies in order to track the interaction of Clients with the Website and Apps. This section explains the different types of cookies that may be set when the Client uses the Website and Apps, helping to understand and manage them as he/she wishes.  

A cookie is a small file that is stored locally at the Client’s technical device as soon as the App is being used and/or the Website being visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection, version of browser, the type of operating system used, device characteristics and the IP address of the connected device used. Should the Client visit the Website and/or open the App again later, a cookie will transmit this data back to the Website and App. The cookies don't store personal information like the Client’s name or address.

Types of Cookies

We use different types of cookies:

  • Session cookies only last only while the Client is visiting the Website and/or using the App and help the Website and the App to learn more about Client’s behavior during a single session and to help the Client to use the Website and the App more efficiently. Session cookies are deleted when you close your browser. Legal basis for processing is legitimate interest, as these cookies are essential for providing the service you request.
  • Persistent cookies have a longer lifespan and aren't automatically deleted when the Client leaves the Website or closes the App. These cookies are primarily used to help the Client to sign-in again quickly, for security and analytical purposes. The Website and the App do not use any information whilst the Client is logged off. Legal basis for processing is consent for analytics purposes, legitimate interest for security purposes. Persistent cookies remain on your device after you leave the Website or App and can last for up to 12 months unless deleted manually.
  • We use first-party cookies that is when the cookies are placed on the Client’s device directly by the service. For example, first-party cookies are used to adapt the App to the language preferences and analyze user experience of the Client. Legal basis for processing is legitimate interest for improving user experience and providing tailored services. These cookies may last up to 12 months.
  • Third-party cookies are placed on the Client’s device by our partners and service providers. Legal basis for processing is consent for advertising and social media functionalities. The retention period for third-party cookies is determined by our partners and service providers and may last up to 24 months.
  • Necessary cookies. These cookies are strictly necessary to provide the Client App’s services. Legal basis for processing is legitimate interest, as these cookies are crucial to providing the requested services. The retention period for necessary cookies is session duration, deleted after closing the browser or app.
  • Authentication cookies. These persistent cookies help the Service to identify the Clients so that the Client could log in automatically. Legal basis for processing is legitimate interest to enhance user convenience and security. The retention period for authentication cookies remains active for up to 12 months.
  • Analytics cookies. These cookies help us to understand how the App is being used, and help to customize and improve the service. Legal basis for processing is consent, as analytics cookies are only used when users provide explicit consent. Retention period for analytics cookies is 24 months.

The Client can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device.

The data processed by cookies for the aforementioned purposes, when this data is recognized as a personal, is processed for the purposes of performance of the contract between Shinglix and the Client, Shinglix’s legitimate interests and compliance with legal obligations.

  • IV. Data Sharing

7. Disclosure of Your Data

We may disclose your personal information with selected third parties including:

a) Partners, involved in Service provision for the performance and execution of any agreement we enter into with them or you;

b) Advertisers and advertising networks solely to select and serve relevant adverts to you and others; and

c) Analytics and search engine providers that assist us in the improvement and optimization of the Website and Apps.

We also may disclose your personal information to third parties:

a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply Holders Service Terms of Use and other applicable agreements, or to protect the rights, property, or safety of Shinglix, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

c) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;

d) to prevent and detect fraud or crime;

e) in response to a subpoena, warrant, court order, or as otherwise required by law;

f) to assess financial and insurance risks;

g) to recover debt or in relation to your insolvency; and

h) to develop customer relationships, services and systems.

8. International Transfers

We confirm that all Personal Data is stored on servers located within the European Union (EU) and/or in compliance with any national data localization requirements of the respective countries, where such requirements exist. Furthermore, we confirm that all Personal Data is transferred within the EU or the European Economic Area (EEA). No Personal Data is transferred to third countries that are not subject to an adequacy decision by the European Commission, or that do not provide a level of data protection equivalent to that of the EEA.

V. Your Rights

You have the following rights under the applicable data protection laws:

Information and Access. The right to know whether your Personal Data is being processed, right to get information regarding processing of Personal Data, right to request a copy of Personal Data being processed. The right to information about public and private entities with which we have shared data.

Rectification (correction). The right to correct your Personal Data in a situation when such data available to us or disclosed to third parties is inaccurate or incomplete.

Erasure. The right to request deletion of Your Personal Data from Our database so that the Service is not able to continue processing and storing of such data, with exceptions, provided in applicable law. We may not be able to agree to your request. As a regulated financial services provider, we must keep certain customer personal data even when you ask us to delete it. If you've closed your Account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We’ll always let you know if we can't delete your personal data.

Restrict processing. The right to introduce the restriction regime on the processing of Your Personal Data, so that in each case the data may be processed only upon your separate consent.

Data portability. The right to request for the Personal Data to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by you.

Object. The right to object to processing of your Personal Data in a case when the corresponding processing is not performed on the basis of your consent. If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object. However, if there is an overriding reason why we need to use your personal data, we will not accept your request. If you object to us using personal data which we need to provide our services, we may need to close your account as we won’t be able to provide the services.

Withdraw consent. Right to withdraw consent to processing of your Personal Data by us or third parties to which we have previously disclosed your Personal Data.

Automated decision. If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.

Lodge a complaint. If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:

  • writing to Shinglix LTD, Room 1406, 14/F, Solo Building, 41-43, Carnarvon Road, Tsim Sha Tsui, Hong Kong; or
  • sending an email to privacy@shinglix.com.

  • VI. Duration of processing and security

We only store your Personal Data for as long as necessary to serve the purpose of the processing and we delete Personal Data or block access to it as soon as such purpose ceases to apply.

Furthermore, Personal Data may be stored if this has been provided for by the applicable law (for example for book keeping or mandatory archiving purposes). The data will also be blocked or deleted if a storage period prescribed by the applicable law expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

We have implemented reasonable technical and organizational precautions to protect the confidentiality, security and integrity of your personal information from accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access. We cannot guarantee the security of information transmitted to us over the internet.

VII. Retention period of personal data

We seek to ensure that we only keep your personal data for the longest of:

  • the period necessary for the relevant activity or services;
  • any retention period that is required by law; or
  • the period in which litigation or investigations might arise in respect of the services.

We are required to keep certain personal data for specified time periods by KYC, anti-money laundering, banking and e-money laws. In line with AML regulations, regulated financial companies are obliged to store the User's data for ten years after the termination of the Client’s relationship with the User or the date of the occasional transaction.

Where we independently define the compatible purposes or are under a legal obligation, Personal data  will be destroyed after our purposes for collecting the personal data have been satisfied or after three (3) years from the provision of data to our system, whichever occurs first.

VIII. Changes to our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the Website as part of Privacy Notice. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

IX. How to contact us

If you have any questions about this Privacy Notice and Privacy Notice, or implement your rights, you can contact us by email: privacy@shinglix.com.