Privacy Policy

Diginex Solutions Limited, and from time to time, its affiliates, and subsidiaries (together the "Group") (and each
being "Diginex", "we", "us" or "member of the Group" for the purposes of this Privacy Policy Statement as
appropriate) recognize their responsibilities in relation to the collection, holding, processing, use and/or transfer
of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). 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 Statement.

We regularly review this Privacy Policy Statement and may from time to time revise it or add specific instructions,
policies, and terms. Where any changes to this Privacy Policy Statement are material, we will notify you using the
contact details you have provided us with and, where required by the PDPO, give you the opportunity to opt out
of these changes by means notified to you at that time. Otherwise, in relation to personal data supplied to us
through the Diginex website or otherwise, continued use by you of the Diginex website or your continued
relationship with us shall be deemed to be your acceptance of and consent to this Privacy Policy Statement, as
amended from time to time.

If you have any questions about this Privacy Policy Statement or how we use your personal data, please contact
us through one of the communication channels set out in the "Contact Us" section below.

We will take all practicable steps to ensure the security of the personal data and to avoid unauthorized or
accidental access, erasure, or other use. This includes physical, technical, and procedural security methods,
where appropriate, to ensure that the personal data may only be accessed by authorized personnel.

Please note that if you do not provide us with your 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, and may not be able to
perform or discharge the Regulatory Functions (defined below).


From time to time we may collect your personal data including but not limited to your name, mailing address, telephone number, email address, date of birth and login name for the following purposes:
1. to process your applications, subscriptions and registration for our products and services;
2. to provide you with our products and services and administer your account in relation to such products and services;
3. to conduct research and statistical analysis;4. to process your application for employment or engagement within Diginex to assess your suitability as a candidate for such position and to conduct reference checks with your previous employers; and5. other purposes directly relating to any of the above.

Direct marketing
Where you have given your consent and have not subsequently opted out, we may also use your name, mailing address, telephone number and email address to send promotional materials to you and conduct direct marketing activities in relation to Diginex financial services and information services, and financial services and information services offered by other members of the Group. If you do not wish to receive any promotional and direct marketing materials from us or do not wish to receive particular types of promotional and direct marketing materials or do not wish to receive such materials through any particular means of communication, please contact us through one of the communication channels set out in the "Contact Us" section below. To ensure that your request can be processed quickly please provide your full name, email address, log in name and details of the product and/or service you have subscribed.

Identity Card Number

We may also collect your identity card number and process this as required under applicable law or regulation, as required by any regulator having authority over us and, subject to the PDPO, for the purpose of identifying you where it is reasonable for your identity card number to be used for this purpose.

Data Storage and Processing

We use Secure Microsoft Azure cloud storage through our strategic partnership with Microsoft. The cloud servers are located in Hong Kong which is where all user data is stored. Additionally, we use Amazon Web Services (AWS) for some infrastructure components. Our AWS services are located on Singapore and do not store any user data.

Only a very small number of individuals in the company are licensed and granted access to production systems for the purpose of maintenance and security testing. These individuals sit in our enterprise architecture and security team.

Transfers of personal data for direct marketing purposes
Except to the extent, you have already opted out we may transfer your name, mailing address, telephone number and email address to other members of the Group for the purpose of enabling those members of the Group to send promotional materials to you and conduct direct marketing activities in relation to their financial services and information services.

Other transfers of your personal data

For one or more of the purposes specified above, your personal data may be:
1. transferred to other members of the Group and made available to appropriate persons in the Group, in Hong Kong or elsewhere and in this regard, you consent to the transfer of your data outside of Hong Kong;
2. supplied to any agent, contractor or third party who provides administrative, telecommunications, computer, payment, debt collection, data processing or other services to Diginex and/or any of other member of the Group in Hong Kong or elsewhere; and
3. other parties as notified to you at the time of collection.

How we use cookies

If you access our information or services through the Diginex website, you should be aware that cookies are used. Cookies are data files stored on your browser. The Diginex website automatically installs and uses cookies on your browser when you access it. Two kinds of cookies are used on the Diginex website:

Session Cookies:
temporary cookies that only remain in your browser until the time you leave the Diginex website, which are used to obtain and store configuration information and administer the Diginex website, including carrying information from one page to another as you browse the site so as to, for example, avoid you having to re-enter information on each page that you visit. Session cookies are also used to compile anonymous statistics about the use of the Diginex website.

Persistent Cookies:
cookies that remain in your browser for a longer period of time for the purpose of compiling anonymous statistics about the use of the Diginex website or to track and record user preferences. The cookies used in connection with the Diginex website do not contain personal data. You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software. However, if you do so you may not be able to utilize or activate certain functions available on the Diginex website.

Compliance with laws and regulations
Diginex and other members of the Group may be required to retain, process and/or disclose your personal data in order to comply with applicable laws and regulations or in order to comply with a court order, subpoena, or other legal process (whether in Hong Kong or elsewhere), or to comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong or elsewhere). Diginex and other members of the Group may need to disclose your personal data in order to enforce any agreement with you, protect our rights, property or safety, or the rights, property, or safety of our employees, or to perform or discharge our proper business functions.

Corporate reorganization

As we continue to develop our business, we may reorganize our group 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 Statement or a different privacy policy statement which will be notified to you. Such a third party may be located, and use of your personal data may be made, outside of Hong Kong in connection with such acquisition or reorganization.

Access and correction of personal data
Under the PDPO, you have the right to ascertain whether we hold your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request us to inform you of the type of personal data held by us. All data access requests shall be made using the form prescribed by the Privacy Commissioner for Personal Data ("Privacy Commissioner") which may be found on the official website of the Office of the Privacy Commissioner or via this link

Requests 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 by post to us (see the "Contact Us" section below). A reasonable fee may be charged to offset our administrative and actual costs incurred in complying with your data access requests.

Termination or cancellation

Should your account or 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 your data as is reasonably required for archival purposes, for use in relation to any actual or potential dispute, for the purpose of compliance with applicable laws and regulations and for the purpose of enforcing any agreement we have with you, for protecting our rights, property or safety, or the rights, property or safety of our employees, and for performing or discharging our functions, obligations and responsibilities.

Contact us
By Post:
Personal Data Privacy Officer
Diginex Solutions Limited
5/F Two ChinaChem Central,
26 Des Voeux Road Central,
Hong Kong

By Email:

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Privacy Policy