1000X Limited, a Company registered at Office 5, 8th Floor, Mega Cube, 8 Wang Kwong Road, Kowloon Bay, Kowloon, Hong Kong S.A.R., is the data controller for personal information collected according to this Policy and in connection with the provision of our services.
Personal information that we collect and process
The types of personal information that we collect will vary significantly depending on numerous factors, including but not limited to the regulatory requirements and enabling our services to perform correctly.
Generally, the personal information that we are collect and process can be grouped into the following categories:
Essential information.Which may include your contact details (e.g., Title, name, known name, physical address, postal address, email address, facsimile number, telephone number, mobile phone number), your KYC (know-your-customer) records (e.g., Date of Birth, Country of Residence, Tax Residence, Nationality, Citizen ID, Social Security Number, any meaningful financial information) which may include sensitive information (such as your bio-authentications, criminal records, sanctions, embargoes) where applicable. This type of information is essential for you to use our services, or we are required to comply with applicable law to collect and retain.
Non-essential information.This type of information might be your service records or your usage of our services.
We will collect your personal information only, whether essential or non-essential, where we are legally permitted to do so, and only to the extent it is appropriate and necessary for one or more of the purposes described in the following section.
Justification for collecting your information
We handle and process your information for one or more of the following purposes:
Comply with regulations or regulatory bodies.We must collect your information to comply with regulations and/or regulatory bodies, especially the AML (Anti-Money Laundering) laws, and regulations.
Enable our services to function correctly. At the minimum level, our services require you to share information with us so our services can perform correctly. This justification is designed to prevent any exploitation of our services and can identify you accurately when using our services. Without this information, we cannot serve you our services.
Business Administration.To facilitate the effective management and administration of our business, including in relation to matters such as business planning, budgeting, and forecasting in relation to our offering, we have to use your personal information in some circumstances.
Service Development.In relation to us and future offerings of our services.
Service Marketing.To promote our services and future offerings.
Client Relationship Management.To manage, maintain, and develop our relationship with our clients.
Important Notice: We may use your personal information to conduct various checks to ensure that we comply with all applicable legal and regulatory requirements before we formally accept you (or your business) as a client and from time to time after you (or your business) is accepted as our client. For example, we might check your name against official records published by authorities that prevent us from doing business by law.
In handling and processing personal information for the aforementioned purposes, we rely on the following:
Contractual Necessity. We have to use your personal information for our business or services to perform correctly and can provide services to you.
Legitimate Business Interest. Where it necessitates, the handling and processing of your personal information are essential in order to meet our requirement to operate, manage, and develop our business.
Legal and Regulatory Requirement.Where it necessitates, the handling and processing of your personal information are essential in order to comply with applicable laws or regulations.
Consent Where it necessitates (such as no other legal or legitimate interest grounds for us to consider), the handling and processing of your personal information are based exclusively on your consent. Where we rely on your consent to handle and process your personal information, you can expect us to explain what you are being asked to agree to, and you may withdraw your consent at any time.
Obtaining your personal information
We endeavor to collect your personal information directly from you wherever possible. However, the context in which we handle and process your personal information can often result in us collecting your personal information indirectly from third-party sources. Additionally, there may be situations where we are required to seek your personal information from independent sources. For example, when we are using your personal information to check with local authorities to validate your identity and background.
Sources from which we may obtain your personal information can be described as follows:
Local Authorities.These can be in the form of, but are not limited to, local or federal government announcements, databases, official registers of companies or businesses, background checks, sanctions, or embargoes lists.
Publicly available information such as websites, registers, and databases, including official databases from the authorities.This also includes providers of that information that might be aggregated or combined the data into any usable forms. Providers of background check and business risk screening services, such as operators of fraud and financial crime databases, credit checks, and operators of sanctions/embargoes databases.
Those who have referred you to us, such as your business contact or another entity.
Your lawyer, accountant, tax advisor, wealth manager, and other such advisorswho provide your personal information to us on your behalf.
Information Sharing with others
We might share your information with others only if and to the extent it is appropriate and/or necessary to do so for one or more of the following purposes:
Authorities, including authorities' personnel, where and when required by law or regulations.
Those who support our business operations. For example, data center operators, IT service providers, administrative support service providers, insurers, accountants, consultants, auditors, etc.
Providers of background check and business risk screening services, such as operators of fraud and financial crime databases and operators of sanctions/embargoes databases.
Those who provide ancillary services for us.
Government departments and agencies, police, regulators, courts, tribunals, and other like authorities with whom we are legally obliged to share your personal information or with whom we decided to cooperate voluntarily (but only to the extent we are legally permitted to do so).
Important Notice: Please note that where we share your personal information with the authorities, we may, depending on the circumstances, be forbidden from advising you of the fact that your personal information was disclosed to or requested by the authorities (e.g., when doing so is illegal or might affect an on-going investigation).
Handling your personal information
We take information security very seriously; hence, we use a broad range of tools and techniques to protect your personal information. We also continuously monitor access and detect any incidents that might adversely affect the information that we hold. For example, unauthorized access or inappropriate disclosure of information, accidental change, or loss, whether external or internal factors cause them. These tools and techniques that we are using will be regularly reviewed and changed as deemed necessary and appropriate.
In any operation regarding your personal information, our employees, personnel, representatives/agents, and data recipients have been instructed to maintain the confidentiality and security of your personal information according to the measures determined by us.
We will keep and safeguard your personal data for the necessary duration in accordance with applicable laws or regulations and contractual necessity. Your personal data will be deleted, destroyed, or made anonymous after there has been no necessity to be kept or at the end of the aforementioned duration or period. Typically, we will retain your personal data for as long as you are a client of our services and no less than 7 years following full redemption from us.
In the absence of any legal or regulatory specification of record-keeping requirement which applies, we may retain your personal information for at least 7 years as a general practice for financial service providers around the globe. We may retain your personal information longer if we consider it necessary to protect ourselves from any legal claim or dispute that may arise in connection with the services we have provided to you.
Your rights in respect of your personal information
You may exercise your rights pursuant to any applicable laws, readily available policies, or to be implemented or amended in the future, and criteria determined by us. These include the following:
The right to ask us to confirm whether or not we handle and process any personal information about you.
The right to ask us to provide you with copies of your personal information we hold.
The right to ask us to correct any inaccuracy or incompleteness of your personal information we hold.
The right to ask us to stop handling and processing your personal information or not begin the handling and processing of your personal information.
The right to ask us not to subject you to automated decision-making that uses your personal information.
The right to ask us to erase your personal information.
The right to object to us using your personal information for direct marketing purposes.
The right to lodge a complaint to relevant competent authorities if you deem that your personal information collection, handling, and processing by us violates or does not comply with applicable laws and/or regulations.
Important Note: The rights you have in respect of your personal information are not absolute and are subject to a range of legal conditions and exemptions. We may not comply with your request if such request fall under the legal requirement or exemption applies by applicable laws and/or regulations. In some circumstances, if permissible by law, we may charge you a processing fee to process your request. Ultimately, exercising certain rights may result in us not being able to provide relevant services to you or even your account closure.
Reaching us regarding your personal information.
In any case, regarding to your personal information, you can contact our data protection officer, who is in charge of this matter, at [email protected].Furthermore, if you have a complaint regarding how we handle and process your personal information, please contact our compliance officer in the first instance at [email protected].
We will endeavor to respond to your request, query, or complaint you may have in respect of your personal information with satisfaction. However, if you are dissatisfied with our response and wish to make a formal complaint or want to learn more about your rights, please contact the Office of the Privacy Commissioner for Personal Data, Hong Kong, where we are incorporated.
Room 1303, 13/F, Dah Sing Financial Centre,
248 Queen's Road East,