The future is global, be part of Global Exchange
The future is global, be part of Global Exchange
I – OWNERSHIP.
In compliance with the provisions of The Personal Data (Privacy) Ordinance (Cap. 486) which, regulates the collection and handling of personal data, we hereby inform you that the personal data communicated will be incorporated into a database owned and operated by Global Exchange Hong Kong Limited (hereinafter Global Exchange), which has the following details:
Identification: Global Exchange Hong Kong Limited.
Company Number: 2538505.
Registered address: 6/F., Alexandra House, 18 Chater Road, Central, Hong Kong.
Postal address: Unit 2013-2014, Level 20, Tower I, Metroplaza, 223 Hing Fong Road, Kwai Fong, New Territories, Hong Kong.
II – CONTACT.
For any matter related to the processing of personal data of natural persons by Global Exchange, please contact us through the following e-mail address: email@example.com.
III - PERSONAL DATA.
Global Exchange will collect the following data:
1. EXCHANGE OF CURRENCY AND SERVICES: Data provided for the provision of Global Exchange services. The services will be identified at the time of data collection and registration.
Data collected: Name, surname, ID/Passport, contact address, address, e-mail address, contact telephone and other necessary data according to the service requested, and that will be exclusively necessary to register for the services of Global Exchange.
Purpose: the registration of data subjects for the provision of services and to establish and maintain business relationships.
Legitimation: the existing legal or contractual relationship necessary for the provision of the service and the legitimate interest for the development of commercial relations.
Storage periods: the data will be kept for the time necessary for the purpose of the processing, and once this is completed it will be available to the public administration, judges and courts, for the legal periods established addressing and defending possible responsibilities arising from the processing.
2. SALES CONTACT: in response to inquiries and contact requests received by any means, Global Exchange services, as well as the maintenance of business relationships:
Data collected: Name, telephone, e-mail and inquiry.
Purpose: Respond to requests for information that the data subject has made by any means with regards to Global Exchange products and services, and establish and maintain business relationships.
Legitimation: Based on the provision of consent, Global Exchange is entitled to process the data of the data subject provided through the contact request, and in accordance with the legitimate interest for the development and maintenance of commercial relations.
Storage periods: the data will be kept until the moment in which the data subject requests the cancellation or deletion of his data and once deleted, they will be kept at the disposal of the public administration, judges and courts, for the legal periods established for the attention and defence of the possible responsibilities arising from the processing.
3. PROMOTIONAL MATERIAL or NEWSLETTERS: the sending of information, news, notices, reminders and promotions that could be of interest to the data subject, relating to the activities of Global Exchange.
Data collected: e-mail address, name and surname.
Purpose: the registration of data subjects for the submission of information, news and promotions, and to establish and maintain business relationships.
Legitimation: provision of the data subject's consent to Global Exchange for registration in promotional services, and legitimate interest for the development of commercial relations.
Storage periods: the data will be kept until the moment in which the data subject requests the cancellation or deletion of their data and once deleted it will be kept at the disposal of the public administration, judges and courts, for the legal periods established addressing and defending the possible responsibilities arising from the processing.
4. CLIENTS/SUPPLIERS: Professional personal data provided by Clients/Suppliers for the provision of services and management of the legal or contractual relationship.
Data collected: Name, surname, ID no., professional contact address, e-mail address, contact telephone no.
Purpose: the management of the contractual relationship of the service.
Legitimation: the existing legal or contractual relationship necessary for the provision of the service.
Storage periods: the data will be kept for the time necessary for the purpose of the processing or deletion, and once completed or deleted it may be kept for a period of ten years at the disposal of the public administration, judges and courts, addressing and defending possible responsibilities arising from the processing.
5. ACCESS CONTROL AND SECURITY: Data collected by video surveillance cameras:
Data collected: Images.
Purpose: to control access to and management of the internal security of Global Exchange facilities.
Legitimation: legitimate interest in guaranteeing the security of the facilities on the part of the owner, justifying the fact that the images are necessarily captured when accessing these facilities.
Storage periods: The data will be kept for a maximum period of one month, unless it was necessary to keep it for a longer period due to being convenient to clarify any infraction or illicit act detected.
IV - TRANSFERS OR COMMUNICATIONS OF DATA.
Your personal data will not be transferred to any third party without a legal basis that legitimates this transfer (legal relationship, court or administrative order, etc.).
Your personal data may be transferred internationally to service providers, primarily iCloud service providers (e.g. AWS). These providers may have their servers located inside or outside of the Hong Kong Special Administrative Region of the People's Republic of China. However, in the event that the servers are located in countries outside the Hong Kong Special Administrative Region of the People's Republic of China, Global Exchange will ensure that personal data are processed with the same level of protection as would have been the case had they remained in Hong Kong, ensuring that standard clauses adopted by the Privacy Commissioner for Personal Data (PCPD) have been signed with the recipient entity.
There are data communications to third parties for the provision of services by third parties such as processors with whom Global Exchange has signed the corresponding Data Processor contracts and verified that they meet sufficient guarantees to implement appropriate technical and organisational measures, so that the processing is carried out in accordance with the requirements of the PCPD, ensuring the protection of the rights of the data subject.
V - EXERCISE OF RIGHTS.
The Data Subject has recognised his/her rights to the access, rectification, suppression, limitation, opposition and portability of his/her data. Similarly, he/she is protected by the right to withdraw his/her consent to the processing by Global Exchange. He/she also has the right to lodge a complaint with the supervisory authority.
At any time, the data subject may exercise his/her rights by sending a communication, attaching a document that accredits his/her identity and expressly indicating the right he/she wishes to exercise, to Global Exchange at the address indicated above or by sending an email to the following address: firstname.lastname@example.org.
Global Exchange is obliged to comply with the regulations on the prevention of money laundering and the financing of terrorism. Compliance with this policy may result in the application of certain restrictions on the exercise of your rights.
VI - TECHNICAL AND ORGANISATIONAL SECURITY MEASURES.
In compliance with current regulations, Global Exchange has adopted the necessary technical and organisational measures to maintain the level of security required for the personal data processed. It is also equipped with the necessary mechanisms at its disposal to prevent, as far as possible, unauthorised access.
We work to protect the security of your personal information during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you enter.
We have physical, electronic, and procedural security systems in place for the collection, storage, and disclosure of customer personal information. Our security procedures mean that we may occasionally ask you for proof of identity before providing you with confidential information.
VII - DATA PROVIDED.
The Data Subject undertakes to communicate as soon as possible to Global Exchange any modification and rectification of their personal data in order for the information contained in the Global Exchange Activity Records to be updated at all times.
Based on the legitimate interest of Global Exchange, the personal data of the Data Subject may be used for the establishment or maintenance of commercial relations by any means, including electronic means, regarding information of interest in relation to Global Exchange products and services, and the Data Subject may at any time oppose such processing for commercial purposes by sending a written communication to the postal address indicated, or by sending an e-mail to the address: email@example.com.
GLOBAL EXCHANGE HONG KONG LIMITED; May, 2019.