This Privacy Statement explains and describes our practices for collecting, using, maintaining, protecting, and disclosing personal information that we may receive or that you may provide when you visit our websites. If you have additional questions regarding the processing of your personal information or information security, please contact us at [email protected]
Our Group Personal Data Policy applies to all companies within the Binery Group worldwide. In this Privacy Statement, ‘Binery refers to Binery Limited, Binery Group, and any Binery company whose websites link to this Privacy Statement. Every Binery company must respect privacy and protect personal information that is entrusted to it. This Privacy Statement explains how Binery collects, uses, maintains, protects, and discloses personal information from our websites, mobile applications or as part of our services. Please note that depending on the nature of the services we provide to you, this Privacy Statement will be supplemented with specific privacy policies and notices as required by applicable laws. Other Binery companies may have their own privacy statements, although their practices are always governed by the Group Personal Data Policy. If you are interested in the practices of a particular Binery company, please check the “privacy” link on that Binery company’s website or contact us at [email protected]
Types of Personal Information collected
This Privacy Statement explains our practices with regard to “Personal Information” collected by Binery for its business purposes. Personal Information include any information that can be used (directly or indirectly) to identify, locate or contact you from that information alone or in combination with other information we process or can reasonably access. We may collect the following types of Personal Information:
- Your personal identification information (which may include your name and passport information, your IP address, politically exposed person (PEP) status, personal data available in the public domain, details of your financial information, sources of wealth and your assets and such other information as may be necessary for Binery to provide its services and to complete its client due diligence process and discharge its AML/CFT obligations)
- “Contact Information” that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
- “Relationship Information” that helps us do business with you, such as the types of products and services that we provide to you or that may interest you, information on your company’s size, geographic locations, creditworthiness and demographics.
- “Transaction Information” about how you interact with Binery, including purchases, inquiries, customer account information, and information about how you use the Binery websites and applications.
- If you apply for a position with us we may collect information relating to your past employment, professional qualifications and education, your nationality and immigration/residential status, opinions from third parties about you (such as references) and other details about you which may be gathered during the recruitment process. We may also review publically available information about you on your social media accounts.
Methods of Collecting Personal Information
In the majority of cases, we collect Personal Information directly from you or from third parties. For example, we may collection your Personal Information from your authorised representatives and advisor(s), your employer, our corporate clients where we are providing services to them, our service providers of referees, in the case of prospective employees. We may ask you for Personal Information (including Contact Information and Relationship Information) when you interact with us, such as registering on our websites, mobile applications, signing up to receive a newsletter, or making a purchase. We may collect additional Relationship Information from third party search information suppliers who can help us better understand our customers.
We collect Transaction Information when you purchase services or products from Binery. We also collect Transaction Information when you visit our website, use our applications or contact us, such as for customer service purposes.
Use of Personal Information
Binery may use your Personal Information to:
- Fulfil your requests for services or products and for related activities, such as service and product delivery, customer service, account management, support and training and to provide other services related to your relationship with Binery;
- Provide our corporate clients with services or products and for related activities, such service and product delivery, customer service, account management, support and training and to provide other services related to their relationship with Binery;
- Provide you with marketing communications and offers for services and products from Binery and in some cases, our partners, including offers targeted based on your interests, business characteristics and location, in each case, subject to your consent where required under applicable law;
- Comply with laws, regulations, and guidelines applicable to us and/or other members of the Binery Group;
- Administer surveys, market research, and promotional events;
- Determine if you are eligible for certain products, services, or offers;
- Provide you with additional information that may be of interest, such as Binery news and announcements and technical service bulletins;
- Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfilment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, business continuity and complaint, claim or litigation management; and
- consider job applicants for employment.
We may not always rely on consent as a legal basis for processing your Personal Information although we will seek your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
If you Fail to Provide Personal Information
Where we need to collect Personal Information by applicable law or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with goods or services). In those circumstances, we may have to cancel a product or services you have with us. We will seek to notify you if this is the case at the relevant time.
How and why we share your information
We share Personal Information within Binery’s network. Binery may include disclosures or transfers to third party agents, suppliers or contractors, in connection with the processing of your Personal Information for the purposes described in this Privacy Statement. For example, we may disclose or transfer your Personal Information to third party agents who provide administrative, storage, information technology, security, communication, compliance, payment and other data processing services. Where necessary, Binery will endeavour to take reasonable steps to ensure that data processing agreements are entered into with such third party agents, suppliers or contractors to ensure that they process your Personal Information, on our behalf, with the same level of security and confidentiality as applied by Binery.
We may also provide your Personal Information to other parties to the extent required or provided by law, regulation or court order, for example if we are under a duty to disclose your Personal Information in order to comply with any legal or regulatory obligation such as our AML/CFT obligations or if we have agreed to assist with any tax or other regulatory filing requirements.
We may disclose your Personal Information for the purposes of seeking references and confirmation of the details which you have provided should you apply for a position with us.
Binery may furthermore disclose or transfer Personal Information when we received your consent to do so or for one of the other purposes described in this Privacy Statement.
Cookie, Google Analytics, and other Data Collection Technologies
When you visit our website or use our mobile applications, we collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.
For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.
We collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. We may also collect information about the website you were visiting before you came to Binery and the website you visit after you leave our site.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.
In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Statement applies to the information when we associate it with your Personal Information.
One of the third party vendor used by Binery is Google Analytics. For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/.
For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
Your Rights and Privacy Choices
You have the following rights in respect of the Personal Information about you that we process:
- the right to access Personal Information
- the right to rectify Personal Information
- the right to restrict the use of Personal Information
- the right to request that Personal Information is erased
- the right to object to processing of Personal Information
- the right to withdraw consent to process your Personal Information at any time.
In addition you may have the right to make a complaint with the local supervisory authority with respect to the way Binery is processing your Personal Information or the way Binery is handling your rights.
You can always limit the information you provide to Binery. You can also limit the communications that Binery sends to you. To opt-out of commercial or marketing emails, simply click the link labelled “unsubscribe” at the bottom of any email we send you.
Please note that even if you opt-out of promotional emails, we may still need to contact you with important Transaction Information about the services or products we are providing or will provide to you or the organisation you work for. For example, even if you opt-out of emails, we may still send you activity confirmations and account statements.
If you have any questions about your rights, choices or if you need any assistance with opting-out, please contact us via email to [email protected]. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
Rights Applicable to EU Users
If you are a visitor from the European Economic Area (EEA), your rights under General Data Protection Regulation (GDPR) in relation to your personal data are subject to the protections offered by EU law and briefly summarized below:-
You have the right to know whether the Company processes your personal data, and if we do, you have the right to request a copy of the personal information the Company is/ are processing about you, which the Company will provide back to you in electronic form. For your own privacy and security, in our discretion the Company may require you to prove your identity before providing the requested information. If you require multiple copies of your personal data, the Company may charge a reasonable administration fee.
You have the right to have incomplete or inaccurate personal information that the Company processes about you rectified. Note that you can always make certain adjustments to certain personal information by contacting the Compliance Officer of the Company, whose contact details are set out under Paragraph 15. entitled “Enquiries” below.
You have the right to request the Company to delete personal information that the Company processes about you, except the Company is not obligated to do so if the Company needs to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that the Company no longer needs to process such data for a particular purpose. However, this will not affect the lawfulness of any processing carried out before your request and that the Company may not be able to provide certain products or services to you.
You have the right to obtain personal information the Company holds about you, in a structured, electronic format, and to transmit such data to another data controller. Please note that this right only applies to automated information which you initially provided consent for us to use (such as for direct marketing communications) or where we used the information to perform a contract with you.
If you have consented to the Company’s processing of your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages that you receive from the Company.
To exercise any of these rights, please contact us at the address in the How to Contact Us section below. Please take note that if you are not subject to EU law, these right do not apply to you
Security of your information
Binery has implemented an information security program that contains administrative, technical, and physical controls that are designed to safeguard your Personal Information. For example, we use industry-standard encryption technology to secure sensitive Personal Information when it is being collected and transmitted over the internet as well as firewalls, site monitoring and intrusion detection software.
Please note that you should also take steps to protect yourself and your Personal Information, especially online. When you register at Binery websites, choose a strong password, and do not use the same password that you use on other sites. Do not share your password with anyone else. Binery will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the website and close your browser window when you have finished your work. This is to ensure that others cannot access your Personal Information and correspondence if others have access to your computer
Third Party Privacy
This Privacy Statement only addresses the use and disclosure of information by Binery. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. Our affiliates, suppliers and business partners have their own privacy policies too. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.
Forums, Community, Reviews and other Public Areas
For Job Applicants
If you have applied for employment with Binery, the Personal Information submitted with your job application may be added to our Talent Community and used for recruitment and other customary human resources purposes. You have the right to withdraw from us.
Change of Purpose
We will only use Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use any Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process Personal Information without your knowledge or consent, in compliance with the above, where this is required or permitted by law.
Changes to this Statement
From time to time, we may update this Privacy Statement to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Statement. Additionally, if the changes will materially affect the way we use or disclose previously-collected Personal Information, we will notify you about the change by sending a notice to the primary email address associated with your account.
We will only retain Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for Personal Information, we will consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Personal Information, the purposes for which we process Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You have the right to request access to, correction or erasure of Personal Information that we hold about you. All requests will be reviewed and processed in accordance with applicable law.
If you would like to access, correct, or erase your Personal Information or if you have any questions, comments or complaints (e.g. if you believe that Binery has not handled your Personal Information properly or that it has breached its privacy obligations), please contact Binery’s Office of Privacy & Data Governance in the following ways:
Email address: [email protected]
Postal address: 3/F, Winbase Centre, 208 – 220 Queens Road Central, Central, Hong Kong
The Privacy Officer will investigate any complaint and notify the individual within reasonable timeframe of the outcome of the investigation.
Please note this updated version of our privacy statement does not substantively change the way we treat Personal Information in comparison to the previous version of the privacy statement available historically on our websites.