Effective Date: 29 May 2023

HashKey Privacy Policy

HashKey Digital Asset Group Limited and its affiliates (hereinafter referred to as “HashKey”, "we" "us" or "our") is committed to protecting the privacy, confidentiality, and security of the personal data held by HashKey complying with the requirements of applicable personal data protection laws including the Personal Data Protection Act 2012 of Singapore ("PDPA") and the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”) with respect to the collection, use and management of personal data. In doing so, HashKey is equally committed to ensuring that all its employees and agents uphold these obligations.

This Privacy Policy ("Privacy Policy") describes:

·         the personal data which HashKey will collect or process,

·         how personal data will be used, shared and protected, and

·         your rights in relation to personal data, including the right to make data access and correction requests.

Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by HashKey is accurate. HashKey will use your personal data which HashKey may from time to time collect in accordance with this Privacy Policy.

HashKey reserves the right from time to time to revise this Privacy Policy. Where any changes to this Privacy Policy are material, HashKey will notify you using the contact details which you have provided HashKey and by updating and issuing the new version on the HashKey website. HashKey has the right to decide whether or not to notify you by using the contact details you have provided to HashKey. You are advised to check the Privacy Policy periodically and pay attention to its revision. After the publication of the new version of this Privacy Policy, your continued use of the HashKey website or your continued relationship with HashKey shall be deemed to be acceptance of and consent to this updated Privacy Policy, as amended from time to time.

HashKey will take reasonable and practicable steps to ensure the security of your personal data and to avoid unauthorised or accidental access, erasure or use for other purposes. This includes physical, technical, and procedural security methods, where appropriate, to ensure that your personal data may only be accessed by authorised personnel.

Please note that if you do not provide HashKey with personal data (or relevant personal data relating to persons appointed by you to act on your behalf), HashKey may not be able to provide the information, products or services you have asked for or process your requests, applications, subscriptions or registrations, as applicable.

If you have any questions about this Privacy Policy or how HashKey uses your personal data, please contact HashKey through the communication channels set out in the "Contact HashKey" section below.

Collection of personal data

Personal data may be collected from you on a voluntary basis for particular purposes or services. Your personal data are collected and held by HashKey as explained below:

Investors

When you apply, subscribe and register for HashKey products and services or make enquiries to HashKey, we will collect personal information about you so that we can process your application, subscription and registration including but not limited to your name, telephone number, mobile phone number, address, email address, facsimile number, gender, date of birth, age, job title, interests and other information you provide via the HashKey website or any other means.

We may also collect other personal data you provide as set out in sections of the HashKey website which invite you to provide personal data.

Job applicants

We will collect information including but not limited to the below to process your job application with HashKey:

·         your personal details, including your name, telephone number, mobile phone number, address, email address, facsimile number and language proficiency;

·         your education background, including your level of education and field of study;

·         personal data contained in your resume attached to your application, transcript or reference letter; and

·         other personal data you provide in the job application process with HashKey.

Visitors of HashKey's website (whether an investor, job applicant or other third party)

When you visit the HashKey website, we will record each of your visits and will automatically collect the following information:

·         technical information, including the Internet protocol (“IP”) address used to connect your computer to the Internet, your login information, browser type and version, geographical location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform; and

·         information about your visit, including the full Uniform Resource Locators ("URL"), clickstream to, through and from the HashKey website (including date and time), products you viewed, searched for, filtered or purchased, the hyperlinks you have clicked, site usage including page viewed and page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the HashKey website.

We may also collect your personal data including but not limited to your name, telephone number, mobile phone number, address, email address, facsimile number, gender, date of birth, nationality, job title, interests, subscription details of HashKey products and services and other information you provide to HashKey.

Use of personal data

From time to time, where personal data is provided to HashKey, HashKey may use the personal data as explained below and such personal data may be transferred to a place outside Hong Kong or Singapore:

Investors

For the purpose of providing products and services to you, we will use the information that we have collected about you to:

·      process your applications, subscriptions and registration for HashKey products and services;

·      administer your accounts and providing you with HashKey products and services;

·      register you for investor-related events, activities and materials;

·      design, install and use software apps of HashKey from relevant app stores;

·      respond to and process your enquiries and taking further actions or do follow-ups as required;

·      market and promote existing and future HashKey products or services;

·      provide you with information regarding the market insights in connection with HashKey products or services;

·      provide you with the online services available at the HashKey website and/or through other telecommunication channels;

·      compile general statistics in relation to the number of visitors to HashKey website and the usage of HashKey website;

·      conduct research, survey and/or analysis from time to time to better understand your needs, preferences, interests, experiences and/or habits;

·      use your personal data for AI analytics;

·      design new and/or enhance existing services, products, activities, and/or other events relating to HashKey products or services;

·      use the information that HashKey website collects about you to improve your experience while using our services; and

·      for other purposes directly relating to any of the above.

Job applicants

For the processing of your job application and administration of our recruitment database, we will use the information that we have collected about you to:

·       evaluate and process job applications;

·       keep job application records;

·       assess suitability of candidates for job positions;

·       communicate with you in the course of your employment and performing human resource management functions and activities;

·       communicate with you on other opportunities; and

·       comply with our legal obligations.

Other third parties

For the purpose directly related to the function or activity of HashKey, to comply with legal requirements, to carry out obligations arising from the contracts entered between you and HashKey, any other applicable purposes as set out in this "Use of personal data" section, and/or any other purpose notified to you at the time of collection of the personal data.

We will obtain your consent before using your personal date for other purposes, unless otherwise permitted by applicable law.

Other Uses

HashKey may be required to retain, process and/or disclose your personal data to agents, contractors or other third-party service providers, to which HashKey does not assume any liability for any loss or damage that you may sustain, in order to:

1)    comply with a court order, subpoena or other legal process (whether in Hong Kong, Singapore or elsewhere);

2)    comply with applicable laws and regulations;

3)    comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong, Singapore or elsewhere);

4)    provide to the third-party database for submitting behaviors concerning anti-money laundering, terrorism financing, and evading trade and economic sanctions;

5)    provide to a third party which provide services (such as legal, financial, management, operation, market surveillance, analytic or technical services) or is associated or acting as a nominee to HashKey;

6)    provide to any third party to whom HashKey’s businesses or any part of HashKey’s businesses will be sold, assigned or transferred to, if applicable; or

7)    HashKey may need to retain, process and/or disclose your personal data in order to enforce any agreement with you, protect HashKey’s rights, property or safety, or the rights, property or safety of HashKey’s employees.

How does HashKey use cookies

If you access HashKey’s information or services through the HashKey website, you should be aware that cookies are used. Cookies are data files stored on your browsers. The HashKey website automatically installs and uses cookies on your browsers when you access it, which are used to store your preferences, enhance the function of the HashKey website, and facilitate your browsing. The cookies used in connection with the HashKey website do not contain personal data. You may refuse to accept cookies on your browsers by modifying the settings in your browsers or internet security software. However, if you do so you may not be able to utilise or activate certain functions available on the HashKey website. For detailed information on how HashKey uses cookies and the purposes for which cookies are used, please refer to our cookie policy at https://www.hashkey.com/en/cookies-policy.

Third party websites

The HashKey website may from time to time contain linkages to other websites. These other websites are independent from the HashKey website. HashKey has no control or management over the contents of such other websites or their privacy policies or compliance with the law. You should be fully aware that the provisions of such linkages do not constitute an endorsement, approval, or any form of association by or with HashKey and HashKey has no control over the personal data submitted by you, if any, to other websites.

Transfer of personal data

For one or more of the purposes specified above, HashKey may transfer your personal data to any agents, contractors or other third-party service providers who provide administrative, telecommunications, computer, payment, debt collection, data processing, data storage, data analytics or other services to HashKey in Hong Kong, Singapore or elsewhere, and other third parties as notified at the time of collection.

HashKey may share your personal data within its group of companies for providing the products and services sought by you for the same purpose or directly related to the purposes at the time of collection.

HashKey will adopt contractual and/or other means to ensure the agents, contractors or other third-party data processors who process personal data on behalf of HashKey will take all reasonable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and(ii) ensure that personal data will not be kept longer than necessary.

Corporate reorganisation

As HashKey continues to develop its business, it may reorganise its business structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate HashKey’s business or a similar service under either this Privacy Policy or a different privacy policy which will be notified to you. Such a third party may be located, and use of your personal data may be made in connection with such acquisition or reorganisation outside your country of location (i.e. Hong Kong or Singapore).

Protection of personal data

All personal data provided to HashKey will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorised access or disclosure, accidental loss, alteration or destruction.

In addition, we will adopt contractual or other means to prevent any personal data transferred to HashKey's data processors (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use, if HashKey is to engage any data processor.

Nevertheless, the transmission of information via the internet is not completely secure. Although HashKey will do its best to protect your personal data, HashKey cannot guarantee the security of data transmitted to the HashKey website. Once your personal data is received, HashKey will use strict procedures and security features to try to prevent unauthorized access.

Notice on direct marketing

Where you have given consent and have not subsequently opted out, HashKey may from time to time use your personal data (including your name and contact details) to send you direct marketing or promotional communications such as emails containing news, promotions, events and marketing offers. The dispatch of such direct marketing communications may be undertaken by third-party service providers.

If you do not wish to receive further direct marketing or promotional materials from HashKey, you may opt out of receiving direct marketing or promotional communications by contacting HashKey by one of the communication channels set out in "Contact HashKey" section below.

Retention of personal data

We aim to retain your personal data no longer than is necessary for the fulfilment of the purposes of collection unless a longer retention period is required or permitted by applicable laws, rules and regulations.

HashKey will take reasonable steps to ensure the accuracy of your personal data held by HashKey. If HashKey becomes aware that the personal data is inaccurate, HashKey will not use such data and will notify any third party to which such personal data has been transferred regarding the same.

For personal data for recruitment purposes, HashKey will retain such data of unsuccessful job applicant, for a period not longer than two years from the date of rejecting the applicant, unless there is subsisting reason that obliges HashKey to retain the data for a longer period, such as for compliance with applicable laws, rules and regulations; or you have given prescribed consent for the data to be retained beyond the prescribed period.

Access and correction of personal data

Under applicable law, you may have the right to request for access to your personal data, to obtain a copy of the personal data, to correct any personal data that is inaccurate and to delete or cease the collection, processing or use of any personal data. You may request HashKey to inform you of the type of personal data held by HashKey.

Request for access and correction of personal data or for information regarding policies and practices and kinds of data held by us should be addressed in writing and sent to HashKey by post or by email following the details set out in the "Contact HashKey" section below.

In accordance with the terms of applicable law, HashKey has the right to charge a reasonable fee for the processing of any data access request.

Termination or cancellation

Should your relationship with HashKey be cancelled or terminated at any time, HashKey shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that HashKey may keep copies of the data as is reasonably required for reasonable purposes, such reasonable purposes shall include keeping of records, use in relation to any actual or potential dispute, complying with applicable laws and regulations, and protecting HashKey’s rights, property or safety, or the rights, property or safety of HashKey’s employees and agents.

Language

If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

Contact HashKey

If you have any questions or concerns about this Privacy Policy or how HashKey processes your personal data, or if you would like to make a request for access or update of your personal data, please contact HashKey's Data Protection Officer by post or by email at:

Address:

Singapore:

3 Church Street

Samsung Hub #28-06

Singapore 049483

Hong Kong:

14th Floor, Three Exchange Square

8 Connaught Place, Central

Hong Kong

Email:

In respect of requests pertaining to HashKey PRO - customersupport@hashkey.com.

In respect of all other requests - media@hashkey.com

Privacy policy for Japan residents

If you are a Japan resident, you can learn more about how we use your information and your privacy rights by reviewing our Japan Privacy Policy.