PRIVACY POLICY

HASHKEY HUB LIMITED (or hereinafter referred to as “HASHKEY ME” or “We”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap.486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all reasonable and practicable steps will be taken to ensure that personal data we held is accurate. We will use the users’ personal data which it may from time to time collect in accordance with this Privacy Policy.

We are committed to protecting the privacy, confidentiality, and security of the personal data we held complying with the requirements of PDPO with respect to the management of personal data. Meanwhile, we are equally committed to procuring that all our employees and agents uphold these obligations.

We reserve the right from time to time to revise this Privacy Policy. Where any changes to this Privacy Policy are material, we will notify the users by updating and issuing the new version on the display of the software. We have the right to decide whether or not to notify users by using the contact details they have provided to us. The users shall check the Privacy Policy periodically and pay attention to its revision. If disagreeing with the revised contents, the users shall stop accessing the software immediately. After the publication of the new version of this Privacy Policy, the continued use by the users of the software or the users’ continued relationship with us shall be deemed to be the users’ acceptance of and consent to this updated Privacy Policy, as amended from time to time.

We will take reasonable and practicable steps to ensure the security of the users’ personal data and to avoid unauthorised or accidental access, erasure or use for other purposes. This includes physical, technical, and procedural security methods, where appropriate, to ensure that the users’ personal data may only be accessed by authorised personnel.

Please note that if the users do not provide us with personal data (or relevant personal data relating to persons appointed by the users to act on their behalf), we may not be able to provide the information, products or services the users have asked for or process the users’ requests, applications, subscriptions or registrations.

Purpose

From time to time we may collect, disclose or process the users’ personal data in relation to identification information and contact details, including but not limited to the user's name or account name, mobile phone number, email address, operation records, asset transactions, wallet addresses,stored photos/videos/recordings, browser history, the relevant characteristic information of the device’s software and hardware (including the device model, operation system, device settings, unique device identifier (IMEI code), Media Access Control Address (MAC), device environment and etc.), the relevant location information of the device (including the user’s authorised GPS location and WLAN access point, Bluetooth and access base station and etc.), using the device’s microphone/camera, and requiring/allowing the users to login with their login names for the following purposes:

◇ processing the users’ applications and registration for our products and services;

◇ providing the users with our products and services and administering the users’ account in relation to such products and services;

◇ ensuring the safety in operations of our products and services, and preventing risks such as fraud and cyber-attacks, etc.;

◇ conducting research and statistical analysis and profiling of individuals to provide more accurate and customised services and content;

◇ conducting due diligence (“Know-you-customer”) and Anti-Money Laundering and Counter-Terrorism Financing review on the users; and

◇ for other purposes directly relating to any of the above as permitted by applicable laws.

Your user-side secret share on HASHKEY ME may be encrypted for back-up through third-party supervised service storage space of us. If you choose to keep the user-side secret share backup on your own but lose such secret share, we cannot guarantee that you will be able to recover your account.

Your account password on HASHKEY ME is not stored or synced to our servers. If you lose your HASHKEY ME account password, we cannot guarantee that you will be able to recover your account.

We may ask to collect more personal information from you so that you can use certain features on HASHKEY ME. If you do not consent to the provision of such personal information, you are deemed to have waived your right to use of certain features of HASHKEY ME.

In some cases, you may provide us with personal information that is not your own. If you provide information relating to others, you should ensure that you have obtained the consent of the information subject, allow us to collect personal information about the subject of that information, and that the information subject has consented to disclose his or her personal information to us. You agree that if such information subject files a claim against us for the collection, use and disclosure of our personal information in accordance with the terms of this policy, you agree to indemnify us for the same amount relating to any compensation and keep us free from such liabilities.

Passport or Identity Card Number

We may also collect and process the users’ passport or identity card number in compliance with PDPO (for example, conducting Anti-Money Laundering and Counter-Terrorism Financing review for the prevention or detection of crime) for the purpose of identifying the users.

How we use cookies

If the users access our information or services through the software, the users should be aware that cookies are used. Cookies are data files stored on the users’ browsers. The website automatically installs and uses cookies on the users’ browsers when the users access it, which are used to store the users’ preferences, enhance the function of this website, and facilitate the users’ browsing. The cookies used in connection with our website do not contain personal data. The users may refuse to accept cookies on their browsers by modifying the settings in their browsers or internet security software. However, if the users do so they may not be able to utilise or activate certain functions available on the website.

Utilisation of the users’ personal data

We may, in the following situations, be required to retain, process and/or disclose the users’ personal data to the following parties without prior consent of the user, including:
(1) comply with applicable laws and regulations;
(2) comply with a court order, subpoena or other legal process (whether in Hong Kong or elsewhere);
(3) comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong or elsewhere);
(4) provide to the third-party database for submitting behaviours concerning anti-money laundering, terrorism financing, and evading trade and economic sanctions;
(5) provide to a third party which provide services (such as legal, financial, management or technical services) to us;
(6) provide to any third party to whom our businesses or any part of our businesses will be sold or transferred to, if applicable;
(7) we may need to retain, process and/or disclose the users’ personal data in order to enforce any agreement with the users, protect our rights, property or safety, or the rights, property or safety of our employees; or
(8) other exceptional situations as permitted under applicable laws and regulations.

Corporate reorganisation

As we continue to develop our business, we may reorganise our corporate structure or undergo a change of control or business combination. In these circumstances it may be the case that the users’ personal data is transferred to a third party who will continue to operate our business or a similar service under either this Privacy Policy or a different privacy policy which will be notified to the users. Such a third party may be located and use of the users’ personal data in connection with such acquisition or reorganisation outside of Hong Kong.

Termination or cancellation

Should the users’ account or relationship with us be cancelled or terminated at any time, we shall cease processing the users’ personal data as soon as reasonably practicable following such cancellation or termination, provided that we may keep copies of the users’ data as is reasonably required for reasonable purposes, such reasonable purposes shall include keeping of records, use in relation to any actual or potential dispute, complying with applicable laws and regulations, enforcing any agreement we have with the users, and protecting our rights, property or safety, or the rights, property or safety of our employees.

Retention of the users’ personal data

Personal data provided by the users are retained for as long as the above-mentioned purposes for which such data were collected continue. As a general rule, we may retain records relating to contracts for 7 years from the date of termination of the contract and possibly for a longer period if an investigation or legal proceedings should commence within that period.

Language

If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

Contact us

The users are entitled to access and correct their information and contact us. If the users have any questions about this Privacy Policy or how we use their personal data, or if they would like to make a request for access or correction of their personal data, please contact us via the effective contact details on the display of the software.