- Collection of information
- Uses made of the information
- Disclosure of your information
- Third-party web services
- Third-party sites
- Data transfer
- Your rights
- Contact us
This policy, together with Terms of Service, sets out the basis on which Holdex Limited of 22/F, 3 Lockhart Road, WanChai, Hong Kong (Company Number 2615128) (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called “Holdex Limited” or “we”) collects personal data from you and how we process such data.
By visiting our website https://holdex.io/ (our "Site") or using Holdex Platform or any other applications or software we provide from time to time (collectively our “App”), you accept and consent to the practices set out below.
Collection of information
For the purposes outlined in Clause 2, we may collect and process the following information about you:
Information you give us - information that you provide us (which may include your name, address, email address, telephone number, passport, credit card information and other personal description) by filling in forms on our Site or our App, or by corresponding to us (by phone, email or otherwise), for example:
- when you register for an account with us in our App;
- when you report any problem to us;
- when you use certain features on our Site or our App;
- when you request any support from us; or
- when you complete any survey or questionnaire we send you.
Information we collect about you - information automatically collected when you visit our Site or use our App, for example:
- technical information, including the Internet protocol (IP) address used to connect your computer to the internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, downloaded errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number;
- personal information that you provide online and on applications or other forms, or through discussions we have with you or your representatives, such as your name, address, state authority issued identification number, date of birth, income, employment information, and any information about your personal goals or objectives connected to your visit to our Site and/or usage of our App; and
Information we receive from third parties - information received by third parties we work with, for example, business partners, subcontractors in technical, payment and delivery services, advertising network, analytics providers, search information provider, or credit reference agencies.
We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.
Uses made of the information
We use information held about you for the following purposes:
providing, improving and developing our services;
researching, designing and launching new features or products;
presenting content and information in our Site and our App in the most effective manner for you and for the device you use;
providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
responding or taking part in legal proceedings, including seeking professional advice;
communicating with you and responding to your questions or requests;
purposes directly related or incidental to the above; and we share and use non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders for
showing trends about the general use of our services; and
advertising and measurement purposes of specific partners’ via their cookies or similar technologies.
Disclosure of your information
We do not share your personal information with companies, organizations, or individuals outside of Holdex except in the following cases:
We may share your personal information outside of Holdex when we have your consent. For example, if you want to join a token sale through our platform, we will get your permission before sharing your personal information with the project running the sale. We’ll ask for your explicit consent to share any sensitive personal information.
For external processing:
personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfillment of your order, the processing of your payment and the provision of support services);
our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Schedule 1 of the Securities and Future Ordinance (Cap. 571) of the Law of Hong Kong;
actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world;
persons under a duty of confidentiality to us;
For legal reasons we will share personal information outside of Holdex if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
meet any applicable law, regulation, legal process, or enforceable governmental request;
enforce applicable Terms of Service, including investigation of potential violations;
detect, prevent, or otherwise address fraud, security, or technical issues;
protect against harm to the rights, property or safety of Holdex, our users, or the public as required or permitted by law;
persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
When you share your information:
Many of our services let you share information with other people, and you have control over how you share. For example, you can share referral link. Remember, when you share information publicly, your content may become accessible through search engines.
Third-party web services
On our Site we use the following third-party web services:
Yandex, for web traffic analytics;
Rollbar, for tracking of technical malfunctions;
HelpScout, for customer support and knowledge base.
The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), APIs, web server logs and web beacons to help
us analyse new visitors’ use our Site; and
our customers comply with relevant regulations.
The information collected through these means (including IP addresses) is described in these service providers’ respective policies.
Our Site, our App or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for any practices of third-party websites.
All facilities (e.g. servers) used to store and process the information you give us adhere to reasonable security standards no less protective than the security standards of the facilities where Holdex processes and stores its own information of a similar type.
Where we have given you (or where you have chosen) a credentials (login & password, or other methods) that enables you to access certain parts of the Site, you are responsible for keeping this credentials confidential. We ask you not to share credentials with anyone.
We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons referred to in Clause 3 above who operate outside Hong Kong.
You have the right to:
check whether we hold personal data about you;
access any personal data we hold about you;
require us to correct any inaccuracy or error in any personal data we hold about you; and
require us to delete any personal data we hold about you, including your account.
Any request under Clause 8.1 may be subject to a small administrative fee to meet our cost in processing your request.
We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our App after the changes come into effect means that you agree to be bound by the revised policy.
If you have any questions, comments or requests regarding personal data, please address them to: [email protected]