EXIO Limited (“EXIO”) provides an online trading platform through its website https://www.ex.io and mobile application(s) to be launched from time to time (collectively known as the “Platform”) on which EXIO provide its products and services.
EXIO and its affiliates (hereinafter referred to as “EXIO Group”, “we” “us” or “our“) are committed to protecting the privacy, confidentiality, and security of the personal data held by the Platform complying with the requirements of applicable personal data protection law of 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, EXIO Group is equally committed to ensuring that all its employees and agents uphold these obligations.
This Privacy Policy (“Privacy Policy“) describes:
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 us is accurate. We will use your personal data which we may from time to time collect in accordance with this Privacy Policy.
We reserve the right from time to time to revise this Privacy Policy. Where any changes to this Privacy Policy are material, we will notify you using the contact details which you have provided us and by updating and issuing the new version on its website. We have the right to decide whether or not to notify you by using the contact details you have provided to us. 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 Platform or your continued relationship with us shall be deemed to be acceptance of and consent to this updated Privacy Policy, as amended from time to time.
We 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 us with personal data (or relevant personal data relating to persons appointed by you to act on your behalf), we 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 we use your personal data, please contact us through the communication channels set out in the “Contact EXIO” 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 EXIO Group as explained below:
| Investors | When you apply, subscribe and register for our products and services or make enquiries to us, 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 EXIO website or mobile application(s). We may also collect other personal data you provide as set out in sections of the EXIO website or mobile application(s) 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 us: 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 us. |
| Visitors of EXIO website or mobile application(s) (whether an investor, job applicant or other third party) | When you visit the EXIO website or mobile application(s), we will record each of your visit 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 EXIO 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 EXIO 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 our products and services and other information you provide to us. |
Use of personal data
From time to time, where personal data is provided to us, we may use the personal data as explained below and such personal data may be transferred to a place outside Hong Kong:
| 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 our products and services; • administer your accounts and providing you with our products and services; • register you for investor-related events, activities and materials; • design, install and use software apps of Group 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 our products or services; • provide you with information regarding the market insights in connection with our products or services; • provide you with the online services available at the EXIO website and/or through other telecommunication channels; • compile general statistics in relation to the number of visitors to EXIO website and the usage of EXIO 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 our products or services; • use the information that EXIO 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 EXIO Group, to comply with legal requirements, to carry out obligations arising from the contracts entered between you and us, 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 data for other purposes, unless otherwise permitted by applicable laws.
Other Uses
We may be required to retain, process and/or disclose your personal data to agents, contractors or other third-party service providers, to which we do not assume any liability for any loss or damage that you may sustain, in order to:
How do we use cookies
If you access our information or services through the EXIO website, you should be aware that cookies are used. Cookies are data files stored on your browsers. The EXIO 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 EXIO website, and facilitate your browsing. The cookies used in connection with the EXIO 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 EXIO website. For detailed information on how we use cookies and the purposes for which cookies are used, please refer to our cookie policy at Appendix I.
Third party websites
The EXIO website may from time to time contain linkages to other websites. These other websites are independent from the EXIO website. We have 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 us and we have no control over the personal data submitted by you, if any, to other websites which are operated by the relevant third parties. This Privacy Policy applies only to the personal data we collect and does not apply to services provided any third parties or their rules governing the use of information.
Transfer of personal data
For one or more of the purposes specified above, we 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 us in Hong Kong, Singapore or elsewhere, and other third parties as notified at the time of collection.
We 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.
We 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 us 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 we continue to develop our business, we may reorganise our 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 our business or a similar service under either this Privacy Policy or a different privacy policy which will be notified to you. Such third party may be located, and use of your personal data may be made in connection with such acquisition or reorganization, outside your country of location (i.e. Hong Kong or Singapore).
Protection of personal data
All personal data provided to us 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 our 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 we are to engage any data processor.
Nevertheless, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to the EXIO website. Once your personal data is received, we 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, we 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 us, you may opt out of receiving direct marketing or promotional communications by contacting us by one of the communication channels set out in “Contact EXIO” 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.
We will take reasonable steps to ensure the accuracy of your personal data held by us. If we become aware that the personal data is inaccurate, we 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, we 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 us 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 us to inform you of the type of personal data held by us.
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 us by post or by email following the details set out in the “Contact EXIO” section below.
In accordance with the terms of applicable law, we have the right to charge a reasonable fee for the processing of any data access request.
Termination or cancellation
Should your relationship with us be cancelled or terminated at any time, we shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that we 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 our rights, property or safety, or the rights, property or safety of our 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 EX.IO
If you have any questions or concerns about this Privacy Policy or how EXIO Group processes your personal data, or if you would like to make a request for access or update of your personal data, please contact our Data Protection Officer by post or by email at:
Address:
Room 3501 , 35/F, West Tower, Shun Tak Centre 168-200 Connaught Road Central, Hong Kong
Email: cs@ex.io
APPENDIX I
Cookie Policy
This is the Cookie Policy for EXIO Limited (and its affiliates, hereinafter referred to as “EXIO Group”, “we” “us” or “our“), accessible from https://www.ex.io.
What Are Cookies
As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to the user’s computer, to improve user experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored, however this may downgrade or ‘break’ certain elements of the site’s functionality.
How We Use Cookies
We use cookies for a variety of reasons detailed below. In most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that users leave on all cookies if users are not sure whether or not they are needed, in case the cookies are used to provide a service that the user shall need.
Disabling Cookies
Users can prevent the setting of cookies by adjusting the settings on their browser (more information is available in the “Help” / “Settings” section on the user’s browser). Be aware that disabling cookies will affect the functionality of this and many other websites that the user visits. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that users do not disable cookies.
How Long the Cookies Will Stay on Users’ Browsing Device
The length of time a cookie will stay on the user’s browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on the user’s device until the user closes the browser. Persistent cookies stay on the user’s browsing device until they expire or are deleted.
The Cookies We Set
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by the users which amount to a request for services, such as setting the users’ privacy preferences, logging in or filling in forms. Users can set their browser to block or alert them about these cookies, but some parts of the site will not work as a result. These cookies do not store any personally identifiable information.
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how users move around the site. All information these cookies collect is aggregated and therefore anonymised.
Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages.
Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of the users’ interests and show users relevant advertisements on other sites. They do not store directly personal information but are based on uniquely identifying the user’s browser and internet device.
The information we obtain from our use of cookies will not usually contain personal data of the users. Although we may obtain information about the users’ computer or other electronic devices such as the users’ IP address, their browser and/or other internet log information, this will not usually identify the users personally. In certain circumstances, where the user voluntarily provides it (e.g. by completing an online form) or where the users subscribe to our services through the website we may collect personal information about the users.
Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. Third party cookies such as Google Analytics may collect information such as your IP address, device type and operating system, referring URLs, location and pages visited so that we can continue to produce engaging content. These third-party service providers are responsible for the cookies they set on this site. If the user would like to opt-out of all other types of technologies we employ on this site, users may do so by changing their browser settings to block, delete or disable these technologies as their browser or device permits.
We also use social media buttons and/or plugins on this site that allow users to connect with their social network in various ways. For these to work the following social media sites including without limitation; Youtube, LinkedIn, Twitter, Facebook, Medium, will set cookies through our site which may be used to enhance the user’s profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Please see below a list of the more commonly used browser types with hyperlinks showing how to adapt their cookie settings accordingly:
This cookie policy is written in an English version and a Chinese version. In the event of any conflict between the two versions, the English version shall take precedence.
More Information
If you are not sure whether such cookies are required or not, it is usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.
For more information, users can contact us through email at: cs@ex.io.