PRIVACY POLICY

Your privacy is important to us. At SNC Limited (“we”, “us” or “our”), we are committed to protecting the privacy, confidentiality and security of the personal information we collect and hold by complying with the requirements under the Hong Kong Privacy (Data Protection) Ordinance (Chapter 486 of the Laws of Hong Kong) (“PDPO”). 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. It applies to us and all of our related companies, affiliates and associates.

How do we collect personal information?

We collect personal information from you in the following circumstances:  when you register an account with us; order products or services from us; subscribe to our newsletter; or complete any application form to us or submit a query or request to us. In some cases, we may be required by law to collect personal information about you. The personal information will generally be acquired through our channels, but we may however obtain information through a third party, such as representatives, agents or contractors who provide services to us, or third parties whom may refer you to us as they think you may be interested in our products or services.

What information do we collect?

The kinds of personal information that we collect and hold about you may include:

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.

We use personal data that we collect about you for the following purposes:

EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information based on our contract with you to comply with our legal obligations, to satisfy our legitimate interests as described above and to satisfy on your consent.

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 may not use your personal information unless we have received your consent.  You can opt-out of receiving marketing communications from us by contacting us using the contact details set out below.

We may use your following personal information for the purpose of direct marketing:

We may use your personal information to market the following products and/or services to you:

If we use your personal data in any direct marketing communications, you have the right to request that we provide you with the source of that personal data. There is no fee for requesting this information. We will provide you with the source of the personal data, unless it is impracticable or unreasonable to do so.

Please indicate your consent to receiving information relating to the above by contacting us using the contact details set out below.

We may also use and disclose your information for other purposes in accordance with your requests or instructions.

Who do we disclose your personal information to?

We may share personal information about you with:

Under this privacy policy, you consent to your personal information being disclosed in such circumstances.

In some cases, the people to whom we disclose your personal information may be located overseas. There may not be in place data protection laws which are substantially similar to, or serve the same purposes as Hong Kong. As such, your personal information may not be protected to the same or similar extent as in Hong Kong.

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 HTTP over Transport Layer Security (TLS) 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 update these physical and technical security processes and procedures from time to time to address new and emerging security threats that you become aware of. 

Do we retain your personal information?

Yes, however your personal data will not be kept longer than required.

We may retain your personal information for a period of at least six (6) years from the date on which we collect the information until the last transaction is completed with you or our relationship ends (whichever occurs last). At our discretion, we may retain personal data for longer than this period if we consider it necessary or desirable to do so to meet our legal or regulatory obligations.

Can you access and correct your personal information?

Yes. If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g. 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 data held by us, if we are satisfied that, having regard to the reasons for which we hold your personal data, that personal data is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that data.

Do we use cookies?

Yes, we use cookies on the our website to monitor and observe your use of our websites, compile aggregate data about that use, and provide you with more effective service (which may include customising parts of our websites based on your preferences and past activities on those websites). “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.   

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use our website.

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties here required to do by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

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 site, providing personal information and/or using any of our products or services, you agree that you consent to our privacy policy, as updated from time to time.

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.snct.io.

European Economic Area Users & Data

If you are a resident of the European Economic Area (the “EEA”), we are the controller with respect to your personal information. We determine the means and purposes of processing data in relation to e-wallet and cryptocurrency transactions.

If you are a resident of the European Economic Area (the “EEA”), we are the controller with respect to your personal information. We determine the means and purposes of processing data in relation to e-wallet and cryptocurrency transactions.

Legal basis for processing personal information

Our legal bases for processing under General Data Protection Regulation are described above in the sections entitled “What do we use your personal information for?”. We may process your personal information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, our rights or safety and our customers or others.

Direct Marketing

If you are a current customer residing in the EEA, we will only contact you by electronic means (email) with information about our services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

If you are a new customer and located in the EEA, we will contact you if you are located in the EU by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to use your personal information in this way, or to pass your personal information on to third parties for marketing purposes, please contact us to opt-out immediately. You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting products and services

 

Individual Rights

EEA users have the following rights, which can be exercised by contacting us:

(a)You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.

(b) The processing is unlawful and you oppose the deletion of your personal information and request the restriction of its use instead.

(c) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defence of legal claims.

(d) You have objected to processing, pending the verification of whether our legitimate grounds of us processing your data override your rights.

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 0303 123 1113, casework@ico.org.uk.

Your rights to personal information are not absolute. Access may be denied when:

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 data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact us by using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department 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 us at:

 

SNC Limited

Email: support@snct.io