Privacy Policy

Collection of Information

CAPITAL EXCHANGE respects your privacy and is committed to maintaining the confidentiality and security of the Personal Data of its existing, prospective and former customers and beneficiaries (“Data Subjects” or “you”). This Privacy Policy informs you about how we process Personal Data, how we look after it and tells you about your rights with respect to your Personal Data.  CAPITAL EXCHANGE encourages you to review this Privacy Policy and become familiar with it.  

You are entitled to object to CAPITAL EXCHANGE’s processing of your Personal Data in certain circumstances, for example, if you no longer want to be contacted by us for marketing purposes. To exercise this right, or for more information, please contact us using the details below.  

Personal Data processed by CAPITAL EXCHANGE  

What does Personal Data mean?  

Personal Data means any information relating to an identified or identifiable individual directly or indirectly, such as name, address, telephone number and e-mail address.  

CAPITAL EXCHANGE collects Personal Data from Data Subjects mainly through its branches, CAPITAL EXCHANGE’s websites, and third parties or publicly available sources.  For more information on these sources of Personal Data, please refer to the sections below.  

Where CAPITAL EXCHANGE needs to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that Personal Data, CAPITAL EXCHANGE may not be able to fulfil our contractual obligations (e.g. a money remittance) and we may have to cancel the services you requested.  

Personal Data collected by CAPITAL EXCHANGE

To provide the services requested by CAPITAL EXCHANGE customers, CAPITAL EXCHANGE collects the following Personal Data through its branches:  

• Full Name (sender and recipient of the transaction)
• Address (sender and recipient of the transaction)
• Nationality (sender and recipient of the transaction)
• Telephone, including mobile (sender and recipient of the transaction)
• Relationship between sender and recipient of the transaction
• E-mail
• Age
• Gender
• Birth Place
• Labour details
• Origin of the financial resources
• Financial background
• Identification document (e.g. National ID, Driving License, Passport)
• Bank Statements
• Transaction amounts
• Bank account details
• Credit / Debit card numbers
• Marketing & other Contact Preferences

As a financial institution, CAPITAL EXCHANGE has certain obligations with regards to identity verification, fraud prevention and other similar security purposes.  To ensure compliance with those obligations, certain of the Personal Data described above may be collected from, or verified against, third party sources such as government agencies and consumer reporting agencies.  For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.  

Personal Data collected by CAPITAL EXCHANGE through Social Media  

CAPITAL EXCHANGE may process anonymized data derived from Data Subjects’ publicly available social media resources for statistical purposes.  Although anonymized may be derived from your Personal Data, it is not considered Personal Data in law as this data will not directly or indirectly reveal your identity.  We may also process Personal Data derived from publicly available social media resources that Data Subjects make available when interacting with us including:  Facebook, Twitter, YouTube, LinkedIn, Instagram, Google+, Pinterest, Weibo and WeChat.  Such Personal Data may include but is not limited to:  

• Public Social Media Profile Name
• E-mail
• Mobile number
• Region
• CAPITAL EXCHANGE related posts (e.g. Mentions & Hashtags)
• Complaints/queries. 

 

Purpose of Data Processing  

CAPITAL EXCHANGE generally uses Personal Data from Data Subjects for providing a service.  This may include the following:  

• Authorising and processing Data Subjects’ transactions, including remittance, foreign exchange and payments.
• Monitoring and improving our services including websites/mobile apps and its content.
• Sending information to Data Subjects about CAPITAL EXCHANGE products and services.
• Customer care initiatives to improve CAPITAL EXCHANGE services.
• Meeting legal, regulatory, self-regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies.  For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
• Maintaining business and transaction records for reasonable periods, and generally managing and administering CAPITAL EXCHANGE business.
• Meeting insurance, audit and processing requirements.
• Otherwise as permitted or required by law.

 

Personal Data Sharing  

To carry out the processing activities established in this Privacy Policy, CAPITAL EXCHANGE may disclose Personal Data relating to its Data Subjects to:  

• Third Party service providers (Data Processors):  CAPITAL EXCHANGE may share Personal Data with Data Processors including affiliates of CAPITAL EXCHANGE performing services on CAPITAL EXCHANGE behalf, for example: information technology, data hosting, marketing, customer care, fraud prevention, etc. CAPITAL EXCHANGE takes steps to ensure that Personal Data that is processed by Data Processors is protected and not used or disclosed for purposes other than as directed by CAPITAL EXCHANGE.
• Third Party Data Users:  CAPITAL EXCHANGE may share Personal Data with third parties acting independently from CAPITAL EXCHANGE as may be required in connection with the services provided to Data Subjects, for example:  any intermediary banks or other financial institutions involved in the transaction of CAPITAL EXCHANGE services.
• Successors:  if CAPITAL EXCHANGE is purchased by/sold to a third party, Personal Data held by CAPITAL EXCHANGE will be transferred to the successor entity.
• Relevant Authorities:  CAPITAL EXCHANGE may disclose Data Subjects’ Personal Data as necessary to meet legal and regulatory requirements.  This may include disclosure of Personal Data to government authorities, for example, in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations.

 

Cross Border Personal Data Transfers  

In connection with providing services to its customers, CAPITAL EXCHANGE may transfer Personal Data to destinations outside Hong Kong.  When transferring Personal Data outside Hong Kong, CAPITAL EXCHANGE ensures that security measures and appropriate safeguards are put in place to protect the Personal Data and to ensure that all transfers comply with applicable data protection law.  For example, for transfers of Personal Data between CAPITAL EXCHANGE group companies.  

Data Subject’s Rights

Data Subjects have certain rights with respect to their Personal Data.  These are:  

• To be informed:  Data Subjects have the right to receive certain information about how their Personal Data is processed. Therefore, we are providing you with this Privacy Policy.
• Access:   Data Subjects have the right to access and receive a copy of their Personal Data.
• Correct:   Data Subjects have the right to correct their Personal Data when inaccurate.

Data Subjects are also entitled to lodge a complaint with a regulatory authority, in the jurisdiction where they live or work or where they consider CAPITAL EXCHANGE is processing their Personal Data unlawfully.  We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance.  For more information on your rights, please contact us using the details below.  

CAPITAL EXCHANGE Contact  

If you wish to exercise any of your rights, or if you have any queries or suggestions about this Privacy Policy, you can contact CAPITAL EXCHANGE at info@capitalexchange.hk.  

Marketing Communications  

CAPITAL EXCHANGE employs a strict policy against sending communications if you opted-out from them.  Please note that CAPITAL EXCHANGE will continue to send administrative communications (i.e. Transaction Notifications) when you opt out from Marketing/Customer Care communications. CAPITAL EXCHANGE may also contact Data Subjects in response to their inquiries, to provide services at the Data Subjects’ request and to manage their requirements.  

You may want to discontinue receiving marketing information from CAPITAL EXCHANGE.  While this may mean that you will not receive product or service information of interest to you, CAPITAL EXCHANGE respects your wishes not to be informed directly of these promotions or product introductions.  

You may inform CAPITAL EXCHANGE at any time that you want to opt-out of these communications by following the opt-out links on any marketing message sent to you or by contacting us.  

Third Party Websites  

CAPITAL EXCHANGE websites and emails may contain links to various other websites.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy policies.  When you leave our website, we encourage you to read the privacy policy of every website you visit.  

Security Measures to protect Personal Data  

CAPITAL EXCHANGE takes all reasonable steps to ensure that all Personal Data collected through its branches and websites is treated securely and in accordance with this Privacy Policy and strict data protection standards.  

Retention of Personal Data  

In general, the period for which CAPITAL EXCHANGE retains Data Subjects’ Personal Data is aligned with CAPITAL EXCHANGE’s data retention obligations under anti-money laundering laws, i.e. five years.  In all cases, CAPITAL EXCHANGE only retains Personal Data for as long as is necessary for the purposes described in this Privacy Policy. When determining the appropriate retention periods, CAPITAL EXCHANGE will consider different factors, including: contractual obligations and rights; our legal obligations (for example, anti-money laundering laws); statute of limitations under applicable law; potential disputes; guidelines issued by relevant data protection authorities; and CAPITAL EXCHANGE’s legitimate business interests. CAPITAL EXCHANGE securely erases Personal Data once it is no longer needed.  

Changes to this Privacy Policy  

CAPITAL EXCHANGE reviews and updates this Privacy Policy from time to time.  We encourage Data Subjects to periodically review this Privacy Policy to make sure they are aware of the latest version.  If we make any material changes, we will bring this to your attention.