Privacy & Policy

PRIVACY POLICY FOR TRILLIONS HONG KONG LIMITED

1. PURPOSE

This Privacy Policy covers how Trillions Hong Kong Limited (“Trillions”) and its affiliates treat personal data that we collect and receive, including information related to your past use of Trillions products and services. Personal data is information about you that is personally identifiable like your name, address, email address, or phone number that would not otherwise publicly available.

This policy does not apply to the practices of companies that Trillions does not own or control, or to people that Trillions does not employ or manage. Where you are undertaking a transaction, all information which you provide will be shared with the respective licensed counterparties (“LC”) in the markets for which you are undertaking a transaction utilizing the Trillions platform (the “Platform”) and such LC shall have an independent right to your personal data.

2. SCOPE

This Privacy Notice explains how we handle the personal data that you share with Trillions.

3. PERSONAL DATA

“Personal data” is personally identifiable information that identifies you as an individual, such as your name, mailing address, email address, age range, and the like. We use personal data to better understand your needs and interests and to provide you with better service.

4. DATA SUBJECTS

Individuals accessing the Platform or who are registering to use the services on the Platform and who voluntarily provide personal data to us (“you” or “your”) are covered by this Privacy Notice.

5. TRILLIONS PRIVACY PRINCIPLES

Your privacy matters to us. Our business has been built on trust between our customers and ourselves. To preserve the confidentiality of all information you provide to us, we shall maintain the following privacy principles:

a) we only collect and use personal data that we believe to be relevant and necessary, in order to help us conduct our business and to comply with applicable laws;

b) we use your personal data to provide you with better customer services and products;

c) your personal data may be transferred to third parties, including Trillions companies or agents, either within or outside Hong Kong, as permitted by the applicable law. Any contracts with these third parties will include the necessary provisions to safeguard the personal data that is being transferred to them to a standard of protection that is comparable to The Personal Data (Privacy) Ordinance (Cap. 486) and this Privacy Notice;

d) we may be required by law to disclose your personal data to governmental or judicial bodies or agencies or our regulators, from time to time;

e) we shall take reasonable measures to ensure that your personal data in our possession or control is accurate and up to date; and

f) we protect the personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, or disposal of such data.

By maintaining our commitment to these principles, we will ensure that we respect the inherent trust that you place in us. This notice shall stipulate:

a) our purposes for personal data collection;

b) the important controls we employ for protecting your personal data;

c) the classes of persons we can transfer personal data to; d) the data access and correction right of customers; e) our notice for data transfer; f) use of personal data in direct marketing; g) retention of personal data; and h) withdrawal of your consent.

6. DATA COLLECTION AND PURPOSES OF DATA COLLECTION

a) From time to time, it may be necessary for you to supply us your personal data in connection with the opening or continuation of accounts with us and the usage of our facilities and services.

b) We may also collect personal data in the ordinary course of the continuing our business relationship, for example, when you use any of our other services through the Platform.

c) Failure to supply such personal data may result in our inability to open or continue accounts or establish or continue facilities or provide services to you.

d) We, or authorized third parties, may use your personal data for any one of the following purposes:

I. conducting checks at the time of your application for our products;

II. maintaining our credit assessments;

III. ensuring your ongoing credit worthiness;

IV. designing services or related products for your use;

V. marketing services, promotional materials, or other services or products for which we may or may not be remunerated; VI. determining the amount of indebtedness owed to or by you;

VII. enforcement of your obligations, including, without limitation, the collection of amounts outstanding from you; VIII. complying with the obligations, requirements or arrangements for disclosing and using data that apply to us including:

i. any law binding or applying to us;

ii. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that apply to us; or

iii. any applicable contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies, associations of financial services providers, that is assumed by or imposed on us by reason of our financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant authority, self-regulatory or industry body, or association.

IV. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within our corporate group, subsidiaries, or affiliates, and any other use of data and information in accordance with any group-wide programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;

X. sending you important messages or responding to your orders and questions; and

XI. towards any other purpose of use for which we have obtained your consent, express or implied.

e) We may conduct direct marketing to promote the following classes of services, products and subjects:

I. services and products related to our site and/or our licensed counterparties (including marketing programs we are a part of);

II. reward, loyalty or privileges programs, promotional offers and related services; and

III. invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.

f) Before we use your personal data to conduct direct marketing, we will obtain your explicit consent to do so. We may conduct direct marketing via email, direct mail, telephone and other means of communication or send e-newsletters to you. If you no longer wish to receive the marketing materials, please contact us (Please see Section 15 for our contact information) and we will cease to do so without charge.

7. WHAT KIND OF PERSONAL DATA DO WE COLLECT AND USE?

The types of personal data that we collect and use depend on the product or service you avail with us. It includes, but is not limited to:

I. Data collected directly from you. This may be done through this Site, our mobile app, over the phone, by email, or in person when you meet our staff or representatives. The data collected may include, but is not limited to:

1. your contact information, including your (first and last) name, (billing and/or delivery) address, birthdate, email address and telephone number;

2. other information required to be able to process your order or to provide you with the service requested, including information concerning the products you have ordered or the service we are providing to you, and banking and/or credit card details;

3. if you have created an online profile or account, the preferences and interests stored in such profile or account (please see below for further information concerning the profiles); and

4. if you have contacted us, the details of this contact and the contact history.

II. Data collected by automated means. Various technologies may be used on our website and our mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. Examples of such technologies include:

1. Click-stream data. A visit to our site results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on our behalf. This data can include, in particular, the following: – the visitor’s IP address – the date and time of the visit – the referral URL (the site from which the visitor has come) – the pages visited on our website – information about the browser used (browser type and version, operating system, etc.).

2. Cookies. A number of places on our Site and our mobile and web-based applications make use of cookies. These are essentially small text files that are stored on your computer’s hard drive or your user device by your web browser. We can use cookies to identify the owner of a user account. In other words, cookies help to make our website or our (mobile and web-based) applications more user-friendly, more effective and more secure. By default, web browsers enable the use of cookies but this function can also be disabled. However, disabling the use of cookies will result in some services not being available to you. It is also possible to manually delete cookies after their use via the web browser. More information may be available from your web browser provider.

3. Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or our (mobile) applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.

4. Web analytics. Web analytics is the term given to a method for collecting and assessing the behavior of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of clickstream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. This means that when you visit our website or use any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies

8. IMPORTANT CONTROLS EMPLOYED BY TRILLIONS FOR PROTECTION OF PERSONAL DATA

a) Personal data in our possession and under our control shall be kept confidential and private. We shall take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal data. We shall store all the personal data you provide on our secure servers.

b) Physical copies of your personal data are under lock-and-key with logged access.

c) Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. Any losses or unauthorized access of personal data will be handled in compliance with the The Personal Data (Privacy) Ordinance (Cap. 486) and its guidelines. We will make arrangements to notify the relevant internal & external stakeholders. We will make periodic updates to notify on the actions and remedies taken with the final solution to be shared on a fair and equitable basis. The final handling decision lies with us, based on legal and regulatory priorities firstly followed by its social responsibility.

9. CLASSES OF PERSONS WE CAN TRANSFER PERSONAL DATA

Trillions may provide such personal data for the purposes set out in Section 6 to third parties, including but not limited to:

a) Our related companies globally;

b) any agent, contractor or third-party service provider who provides administrative, telecommunications, computer, payment, debt collection or other services to Trillions in connection with its business;

c) any other person or entity within our corporate group on a need-to-know basis;

d) any person or entity to whom we are legally obliged or otherwise required to make disclosure under the requirements of any law binding on or applying to us or our corporate group, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies, associations of financial services providers with which we or our corporate group is expected to comply, or any disclosure pursuant to any contractual or other commitment of our corporate group with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies, associations of financial services providers, all of which may be existing currently and in the future applying to itself or its subsidiaries; or

e) any other person or entity (including its associated companies or affiliates) who had established or proposes to establish any business relationship with it or recipient of the data. In all instances we shall ensure that our contracts with such third parties will include the necessary provisions to safeguard the personal data that is being transferred to them to a standard of protection that is comparable to The Personal Data (Privacy) Ordinance (Cap. 486) and this Privacy Notice.

10. ACCESS TO AND CORRECTION OF PERSONAL DATA

You have the right:

a) to check whether we hold your personal data;

b) to access and correct your personal data;

c) to request that we correct any of your personal data that may be inaccurate; and

d) to inquire about our policies and practices in relation to personal data and to be informed of the kind of personal data held by us.

The above requests can be addressed as follows: Attention to:

a) The Data Protection Officer (Please see Section 14 for our contact information).

b) We may require you to verify your identity before we provide you access to your personal data.

c) We may charge you a fee to process your request to access your personal data.

11. DATA TRANSFER

Your personal data may be transferred, used, shared or otherwise processed by third parties outside of Hong Kong, provided always that such transfer, use, sharing and/or processing shall only be for the purposes for which you have provided your consent and/or in compliance with the applicable laws and/or in accordance with the manner of collection, use, sharing and/or processing as described in this Privacy Notice. In all instances we shall ensure that our contracts with such third parties will include the necessary provisions to safeguard the personal data that is being transferred to them to a standard of protection that is comparable to The Personal Data (Privacy) Ordinance (Cap. 486) and this Privacy Notice.

12. RETENTION OF PERSONAL DATA

We retain your personal data for the period necessary to carry out the purposes outlined in this Privacy Notice, unless a longer period is required or permitted by law

13. WITHDRAWAL OF CONSENT

You may, at any time, withdraw your consent for our collection, use, or disclosure of your personal data for any purpose by contacting our Data Protection Officer (Please see Section 14 for our contact information). However, withdrawing your consent may result in our inability to open or continue accounts or establish or continue facilities or provide certain services to you.

14. CONTACT US

Address: Trillions Pte. Ltd
Shop S38 2/F Commercial Podium Sincere House
83 Argyle Street Mong Kok Kowloon
Attention to: Data Protection Officer
Email: support@shoottechs.com

Nothing in this Privacy Notice shall limit your rights under applicable laws.