Privacy Policy

Last updated: August 15, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

1. Introduction

Paysmart Capital Limited, together with its affiliates (“we”, “the Company” or “Paysmart”) is committed to protecting personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (the “PDPO”).

We will only collect, use, transfer, or disclose personal data in accordance with the PDPO, our Personal Information Collection Statement (“PICS”), and this Privacy Policy (“Privacy Policy”).

We may amend this Privacy Policy at any time and for any reason. The updated version will be available on our website at [www.liquid.com.hk]. You should check the Privacy Policy regularly for changes.

In this Privacy Policy, “personal data” means any data:

(a) relating directly or indirectly to a living individual;

(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and

2. When and what personal data do we collect?

The types of personal data we collect from you will depend on the circumstances in which that information is collected. If the personal data that we request from you is not provided, we may be unable to provide or continue to provide products and services to you.

The personal data collected and compiled by Paysmart usually includes your full name, identity card number, date of birth, address, contact details, information relating to bank accounts and transactions, and biometric data.

We may collect personal data about you when you:

Use our platform and request for services, products, or activities – including your identity and contact details, financial information about you, information about your income and existing investments;

Apply to open an account with us and use this account, and during the continuation of the company-customer relationship – including financial information about you, information about your income and existing investments;

Are a signatory, director, officer, or guarantor of a corporation opening an account with us – including your identity and contact details;

Apply for employment with us – including your identity and contact details, bank account information for payroll purposes, details regarding family members for medical insurance purposes, information about criminal record and other compliance-relevant data;

Send us correspondence – including your contact details to respond to you.

3. What do we use personal data for?

The purposes for which your personal data may be used will depend on the circumstances in which that personal data is collected.

We will inform you of the purposes for which we intend to use your personal data and the classes of persons to whom this data may be transferred (among other things) in the PICS at or before the time we collect your personal data.

Generally, we may use your personal data for:

The purpose for which you provided it to us;

Purposes which are directly related to the purpose for which you provided it to us;

Any other purposes to which you have consented;

Complying with any law and regulation binding on us, and any guidelines or notices issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations in connection with us and our products and services;

Complying with the obligations, requirements, or arrangements for disclosing and using personal data that apply to the Company or that the Company is expected to comply with according to:

(1) Any law in or outside Hong Kong, whether existing currently or in the future, including the laws relating to the detection, investigation, and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, or other unlawful activities, and/or acts or attempts to circumvent or violate these laws ("Crime-countering Matters");

(2) Any guideline, direction, demand, or request issued by any local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies of financial institutions, or stock exchanges ("Authorities and Organisations"), whether existing currently or in the future, including those relating to any law or Crime-countering Matters;

(3) Any present or future contractual or other commitments with any of the Authorities and Organisations that are assumed by or imposed on the Company by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant Authority or Organisation; and

Comparing or matching personal data, whether or not for the purpose of taking adverse action against you.

For example, we may use your personal data when you:

Use our platform – to process and evaluate your application, verify your identity, provide services, conduct credit checks, provide credit facilities, assist other institutions with credit checks, collect amounts from or pay amounts to you, design new financial products, detect and prevent fraudulent or criminal activities, and comply with legal disclosure requirements;

Apply to open an account – to process and evaluate your application, provide services, conduct credit checks, collect amounts due, and comply with legal obligations;

Are a signatory or guarantor of a corporation opening an account – to register you as a signatory or guarantor and comply with legal requirements;

Apply for employment – to evaluate your application, manage payroll and benefits, conduct performance evaluations, and comply with legal requirements.

4. Our use of cookies

By accessing our platform, you acknowledge that you have been informed of the use of cookies and authorize us to collect information via cookies. "Cookies" are small data files stored on your electronic devices after accessing certain websites or apps.

We use the following cookies:

Strictly Necessary Cookies: Essential for the operation of our platform.

Performance Cookies: Used to improve the website experience.

Functionality and Profile Cookies: Help the site remember your preferences and deliver personalized services.

Marketing Cookies: Track user interests to deliver relevant content.

You can disable cookies in your browser settings, though this may limit functionality.

5. Do we use personal data for direct marketing?

We may use your personal data to send you marketing materials and offers, but only in accordance with the PDPO. If we intend to use your data for direct marketing, we will inform you and give you the opportunity to opt out.

If you no longer wish to receive marketing materials, you may opt out by contacting our Data Protection Officer.

6. To whom do we disclose personal data?

Personal data held by us will be kept confidential but may be disclosed to third parties for purposes including:

To fulfill the purpose for which you provided it;

For any directly related purposes;

To comply with legal and regulatory obligations.

Third parties may include:

Service providers assisting with administrative tasks;

Our legal and professional advisors;

Related companies under the Hong Kong Companies Ordinance;

Government agencies or authorities as required by law;

Any other persons to whom you have consented.

If personal data is transferred outside of Hong Kong, the level of data protection in those places may vary.

7. How is personal data secured?

We take reasonably practicable steps to protect your personal data from unauthorized access, processing, loss, or misuse. This includes limiting access to employees and using encryption or other security measures.

8. Retention of personal data

We will not keep personal data longer than necessary for the fulfillment of the purposes for which it was collected.

9. Accessing and correcting your personal data

You may request access to or correction of your personal data by contacting us. Requests may be subject to verification of your identity, and we may charge a reasonable fee for complying with access requests.

For any questions regarding this Privacy Policy, please contact:

Data Protection Officer

Paysmart Capital Limited

Level 5, Core F, Cyberport 3, Cyberport Hong Kong

DPO@liquid.com.hk

PICS