Terms and Conditions Privacy PolicyThis Privacy Policy applies to all online services provided by Forthright Financial Holdings Company Limited ("Forthright Financial Holdings") and is the generally applicable privacy policy of Forthright Financial Holdings. If you use the related services provided by Forthright Financial Holdings, it means that you agreed with our content in this policy. Some specific services may have other privacy guidelines/statements in addition to this Privacy Policy, if there is any inconsistency between this Privacy Policy and the privacy guidelines/statements of specific services, the specific privacy guidelines/statements shall prevail.
If you have any questions, please contact our data protection officer:
Forthright Financial Holdings Company Limited
Unit 3306, 33/F, Cosco Tower, Grand Millennium Plaza, 183 Queen's Road Central, Hong Kong
You will find details of the following in this Privacy Policy:
- The Information We Collect
- How We Use the Information We Collect
- Information Security
- How We Use Information
- How to Manage Your Own Information
- Protection of minors
- Information We May Send to You
- How We Use Cookies and Relevant Technologies
- Information Security
- Amendments
- Application Scope
- Others
Forthright Financial Holdings is committed to protecting the privacy of information we maintain about you. Please read this Privacy Policy carefully before using our website.
Forthright Financial Holdings highly values the user information security and privacy protection, also promised to strictly follow the laws and regulations to provide you with more secure and reliable services.
1. The Information We Collect
We only collect information that is necessary for functionality of the product and operation of the business.
1. Information that you will provide to us when you use our services
You will provide us your information when you use the service, which including but not limited to the information you provided when you register an account, or the information you uploaded during the use of our services.
2. Information we may collect when you use our services
When you use our services, we may automatically collect and store your information, which including but not limited to:
- Device information;
- Software information;
- Service Logs;
- Communication Logs;
- Location data, etc.
3. We may collect your information in other valid ways, such as from the sharing by other users, and third-party information providers.
4. In addition, we may collect and use your information without asking for your consent first in accordance with relevant laws and regulations and national standards:
- If such information is directly related to national interests such as national security and national defense, or it is directly related to major public interests such as public safety, public health, and public knowledge;
- If such information is directly related to a criminal investigation, prosecution, trial or execution of judgments;
- If the collection and use of such information is for the purpose of protecting important interests of yours or of other individuals, such as life, property, and reputation, and it’s hard to obtain your consent;
- If such information has been disclosed to the public by yourself;
- If such information is collected from public information, such as legal news reports, government information disclosure, etc.;
- If such information is necessary for entering into and/or performance of a contract to which you are a party;
- If such information is necessary for maintenance of the safe and stable operation of the products or services provided, such as discovering malfunctions and/or troubleshooting products or services;
- If such information is necessary for legitimate news reporting;
- If such information is necessary for conducting statistical or academic research which is for public interest, and when the results of academic research or description are provided externally, the personal information contained is de-identified.
- Other circumstances as stipulated by laws and regulations
We appreciate your understanding that the functions and Service we provide to you are constantly updating and developing. If we need to collect your information in other ways which are not covered by the paragraphs above, we will notify and obtain your consent about the type, the scope and the purpose of the information collected by means of page prompts, interactive processes, website announcements or other ways.
Please note that in the event that we need to obtain your personal information from a third party, and our use of such personal information from a third party is beyond the authorization you gave to the third party, we will obtain your consent before using your personal information.In addition, we will strictly follow the laws and regulations, and require the validity of the provision of your information by such third parties to us.
2. How We Use the Information We Collect
We may use the information we collect for the following purpose. If we use your information for purposes other than the following, we will explain to you again and ask for your consent.
1. To provide services to you.
2. To know how you get in and use the services, to better cater your customized needs.
3. Product development and optimization.
4.For identity verification, customer service, safety precautions, anti-unlawful actions, storage and backup, and other purposes to ensure the safety of our product and services.
5.To recommend ads, news etc. that you may be interested in to you.
6.To evaluate and improve the effect of promotions in our services.
7.To manage software.
8.To invite your participation in survey activities about our product and services.
9.Other uses authorized by you.
In addition, we may apply the information collected from one service to other services. Meanwhile, to ensure the safety of our services, and to help us further understand the performance of our applications, we may record relevant information, for example, the frequency of your usage, crash logs information, overall usage, performance data and source of application etc. We will not link the information we store within the mobile analytics software to personally identifiable information you submit within the mobile application.
3. Information We Share
To share your personal information with a third partyWe keep your information strictly confidential. Under certain conditions, we can share your information with third party, which include our cooperating agency and other partners. Before providing the information to the third party, we will evaluate the legitimacy, necessity, and legality of the third party’s collection of information. If it meets these purposes, we will sign relevant legal documents with the third party and require the third party to use your personal information in compliance with laws and regulations and try to require third-party to take protective measures for your information.
1. Some of the services and/or product features we provide may be provided by our partners or jointly provided by us and partners. Only by sharing your information with third parties for the purpose of providing the services you need.
2. We may cooperate with partners to carry out related activities. Sharing information generated during the activities are necessary to complete the activities, so that you can participate in the activities and our partners can contact you in time to issue prizes.
3. If you are complained by others or have complainant to others, we will provide your identity information and other information related to the complaint to the relevant supervisory authority for the purpose of resolving the complaint, unless it is expressly prohibited by laws and regulations.
4. As to comply with the laws, implement or apply our terms of use and other agreements, or to prevent fraud and other illegal activities and reduce credit risks, we exchange information with other companies and organizations.
5. According to laws and regulations, requirements of authorities, or to protect the legal rights and interests of us and our customers in accordance with the laws, or with your express consent.
6. According to the terms and conditions in relevant services agreements we signed with you.
7. Other agreements between you and us regarding information sharing.
Transfer
We will not transfer your information unless:
1. You have expressed contented to such transfer;
2. Such transferring of your information is part of and resulted from mergers, split-off, acquisitions or asset transfer;
3. Such transfer is required by law or governmental authority.
Publicly Disclosure
We will not publicly disclose your personal information. If public disclosure is necessary, we will inform you of the purpose of public disclosure, the type of information disclosed, and the sensitive information that may be involved, also obtain your express consent in advance.
4. Information We Store
1. The personal information collected by us in Hong Kong will be stored domestically in accordance with applicable laws and regulations. In the event any of the information needs to be transferred offshore, we will take effective measures such as signing additional agreements, on-site verification to ensure the offshore institutions keep your personal information confidential.
2. In general, we only store your information for the minimum period that is required to meet the collection purposes. However, we may change the retention period for the following purposes:
- To comply with the relevant laws and regulations;
- To comply with court decisions, rulings or requirements of other legal procedures;
- To comply with the requirements of government agencies;
- Reasonable and necessary purposes to implement relevant service agreements or this Privacy Policy, or to protect public interest and to protect personal safety and property and other legitimate rights and interests of our clients, ourselves, our affiliates, our users, or employees.
5. How to Manage Your Own Information
1. To facilitate your access, amendment or deletion of the information provided by you during your use of our service, and make sure your right to withdraw your authorization for disclosure/use of information and cancel the account, we have included settings in our product that allow you to access and amend your information or cancel your account. You may also contact our customer services for help.
2. If you find that our collection or use of your information is in breach of law or our agreements with you, you can contact our online customer services or call our customer services hotlines to ask for deletion of such information.
3. If you find that your personal information collected and stored by us is incorrect, you can request timely correction by contacting our customer service department.
6. Protection of Minors
We attach great importance to the protection of personal information of minors. In accordance with the relevant laws and regulations, if you are a minor under 18 years old, you would be required to obtain your parents or legal guardian's consent prior to using our service. You need to use our Service under your parents' or legal guardian guidance. We only disclose or use minor’s information when it is permitted by law, expressly consented by the parents or legal guardians, or necessary for protection of the minor’s interest. If you are the parent or the guardian of a minor and have queries about your minors' personal information, please contact our customer services.
7. Information We May Send to You
1. When you use our services, we may send emails, text messages, or push notifications to you. You may follow the relevant notice to unsubscribe on the device.
2. We may send you announcements related to service if necessary (for example, the suspension of certain service due to system maintenance). You may not be able to cancel these non-promotional service-related announcements.
8. How We Use Cookies and Relevant Technologies
1. A Cookie is in the format of txt that enables a website server to store data on your device or to read data from your device. When users
2. We only use Cookies to notify us when you sign into our services so that we can authenticate your identity to ensure the security of your account. And we will not collect or track your any information and behavior.
3. You can manage Cookies in the content settings as your preference, most browsers give you the ability to manage Cookie features. At the same time, you can enable the “Do Not Track” (“DNT”) feature so that you will not be tracked by cookies.
9. Information Security
Under the existing technology, we take all reasonable security measures to protect your information against loss, improper use, unauthorized access or disclosure.
1. We will establish a specialized management, process and organization system to ensure information security.
2. We will work within the reasonable security standards and use a variety of security measures to protect the security of information.
3. We will set up the emergency response plan. In the event of a breach of security incident of personal information, we will activate an emergency response plan to prevent the expansion of such a security incident and inform you in the form of push notifications, public announcements, etc.
4. When you use related services, please take good care of your account number and password. We will use your account number and password to identify you. Once you leak your account number and its password, you may lose your information and may have unfavorable legal consequences for you. If you find that your account number and its password have been or will be leaked for any reason, you should contact us immediately so that we can take appropriate measures in time to prevent or reduce related losses.
10. Amendments
According to the requirements of laws and regulations and the changes of the service, or in some other necessary situations, may update and revise this Privacy Policy from time to time. We will notify you by reminding you at a prominent place on the web page before the changes take effect or by some other appropriate ways to receive notifications.
Under such circumstances, if you continue to use our services, you will be deemed to have agreed to be bound by the updated policy.
11. Application Scope
All services of Forthright Financial Holdings are subject to this Privacy Policy, however, some services have their own specific privacy guidelines/statements. Some specific privacy guidelines/statements describe how we process your information in the service more specifically. If this Privacy Policy is inconsistent with the guidelines/statements of a particular service, the privacy policy of that particular service shall prevail.
12. Others
If you have any questions, advice or suggestions, please contact Customer Service of Forthright Financial Holdings.
