Política de privacidad

GLOBALEXCHANGE HONG KONG LIMITED PRIVACY POLICY

PRIVACY POLICY

This section contains the Privacy Policy which we apply to your Personal Data.

Who collect and control your Personal Data?

Data user	Global Exchange Hong Kong Limited
REGISTERED OFFICE	6/F., Alexandra House, 18 Chater Road, Central, Hong Kong
EMAIL	http://www.globalexchange.hk/indexen.html#contact-menu

What Types of Personal Data may we collect and hold?

The personal data collected will be information that identifies you, such as your name, date of birth, nationality, Identity document type and number, address and other information provided by you.

For what purposes is your Personal Data processed?

1.- Purposes of collection.

Pursuant to Personal Data (Privacy) Ordinance, you are required to provide your personal data for (a) establishing contractual relationship with us, including but not limited to purchase and / or sale of foreign currencies with us, online reservation of any of our services and / or products, purchase of prepaid SIM cards and job applications; (b) process your complaint and / or enquiry; (c) satisfy any legal and / or regulatory requirements applicable to us and / or Eurodivisas, S.A.; (d) contact you for any of the above purposes.

It is obligated to provide your personal data requested by us. Failure of providing the personal data by you may result in us being unable to provide products and services, assess your application, or process any other requests, enquiries, or complaints from you, or any of the purposes listed above.

2.- Direct Marketing.

We must obtain your consent before using your personal information for direct marketing purposes. With your consent, if any, we and Eurodivisas, S.A. may also engage third parties to provide marketing services on their behalf, and may share the information described above with these third parties for such purposes.

If you have consented to the receipt of commercial information / Direct Marketing communication, some of your data (name, email address and telephone number) will be included in a Commercial File belonging to Global Exchange and may be used to keep you informed of promotional activities and new products of Global Exchange, and you may be sent (by email or post) information relating to news, offers, promotions and new products of the Eurodivisas, S.A..

We shall never disclose your personal data to third parties for commercial purposes without your express consent.

Is your Personal Data safe?

In compliance with applicable laws and regulations, Global Exchange has adopted the necessary technical and organisational measures for maintaining the required level of security in relation to personal data processed. Global Exchange also has access to mechanisms required to avoid unauthorised access, to the extent possible.

By way of example:

• We aim to safeguard the security of your personal data during transmission using Secure Sockets Layer software (SSL), which codifies the information introduced.
• We have physical, electronic and procedural systems for the collection, storage and disclosure of our clients’ personal data. Due to our security procedures, we may on occasion ask you for proof of your identity before providing you with confidential information.

To whom will your Personal Data be disclosed?

Your personal data may be disclosed to the following transferees in Hong Kong or overseas for the above purposes: (a) third party agents, contractors and advisors who provide administrative, communications, computer, payment, security or other services which assist Global Exchange to carry out the above purposes; (b) legal and professional advisors of Global Exchange; (c) government and authorities within or outside HKSAR as required or permitted by law; and (d) our holding company, Eurodivisas, S.A..

Your personal data may be transferred internationally to providers of services, in particular providers of iCloud services (for example, AWS). The servers of these providers shall be located in the EU. Nevertheless, in the event that the servers are located in countries outside the EU, Global Exchange shall ensure that the personal data are processed with the same level of protection which would have applied if they had remained in Hong Kong, ensuring that standard clauses adopted by the Office of the Privacy Commissioner for Personal Data of Hong Kong are entered into with the recipient of the information.

For how long will your Personal Data be stored?

Personal data shall be kept for as long as there is a mutual interest in achieving the purposes for which they are processed and, when they are no longer necessary for such purpose, they shall be suppressed employing appropriate security measures to ensure their pseudonymisation or total deletion.

Notwithstanding the above, data relating to currency exchange transactions will be kept in accordance with the provisions of anti-money laundering regulations (10 years).

What rights do you have to protect your Personal Data?

You may exercise your rights in relation to Personal Data in the following manner:

• 1. You can confirm whether we are processing your Personal Data or not and, if so, (1) have access to them, (ii) request that they be corrected if you believe they are not correct, or (iii) request that they be erased if, among other reasons, you believe they are no longer necessary for the purpose for which you provided them.
• 2. In certain circumstances, you may also request us to restrict the processing of your data, or even object to any further processing of your data. In this case, we shall stop using such data, except for legitimate reasons or the exercise or defence of possible legal claims.
• 3. If we use your personal data to prepare behavioural profiles (for example, to better understand your interests and needs through your browsing activity on our website or app) in a wholly automated manner, you will have the right to be informed thereof, to challenge any decision based on those profiles or simply to express your opinion.
• 4. You will also have the right to request the portability of the data which you have provided to us in order that, if you so wish, we send the data directly to you or to a third party mentioned by you, in a commonly used and machine-readable format.
• 5. You may, of course, at any time withdraw any specific consent to use your Personal Data which you may have given us.

Please note that your rights may be limited due to compliance with the legal and supervisory requirements set out in the AMLO and the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism issued by Honk Kong Monetary Authority

For any matters relating to your Personal Data, please contact our Data Protection Officer via the contact methods indicated above.

Any exercise of your rights shall be free of charge.