Privacy Policy for BefuBefa

1. INTRODUCTION

This privacy policy ("Privacy Policy") governs the collection, processing, sharing and use of your data in relation to your use of the platform, website, the applications and/or services operated by BefuBefa (collectively, the “Services”). In this Privacy Policy, "we", "our" and "us" refers to BefuBefa, together with our parent and affiliates, and "you" refers to the user of the Services.

We will use and process your data in accordance with the provisions of this Privacy Policy and applicable laws. By continuing to use the Services or to access our platform, website or web contents, you are deemed to have accepted the terms of this Privacy Policy, and to expressly acknowledge and, where required, consent to our processing of your data for the purposes outlined in, or otherwise in accordance with, this Privacy Policy. If you do not agree with the terms of this Privacy Policy, we may not be able to make the Services available to you.

For the purpose of this Privacy Policy,“data”means all and any data we collect,use and process during your use of the Services.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy shall be incorporated into and form part of the [BefuBefa] that you have agreed to in order to use the Services. To the extent there is any inconsistency between this Privacy Policy and the [BefuBefa] or any other privacy statement or information collection statement you have consented to, this Privacy Policy shall prevail.

Please also note that this Privacy Policy does not apply to: (i) information collected by third-party service providers (including any third-party websites) that you may access through the Services; or (ii) information collected by other companies and organisations who advertise their services via our Services.

3. CONSENTS FROM CONNECTED PERSONS

To the extent that you provide data relating to any other person, including: (1) officers, directors, staff, employees, partners, agents or other representatives of any company or business you represent; and (2) your customers (each a “Connected Person”), you agree and acknowledge that you have notified the Connected Persons of this Privacy Policy and obtained their express consents to the use, retention and transfer of their data in accordance with this Privacy Policy (including any amendments or revisions thereto). You further agree and acknowledge that we are not responsible for any loss incurred due to or in relation to the failure of you to obtain such consent from any Connected Person.

4. CHANGES TO THIS PRIVACY POLICY

We may from time to time amend, supplement, revise, alter or add specific instructions, policies and terms to this Privacy Policy. All such amendments, superminent, revisions, alterations or additions shall form part of this Privacy Policy.

Your use of the Services indicates your acceptance of the current version of this Privacy Policy, which may be amended from time to time. You can determine when this Privacy Policy was last revised by referring to "Last Modified" at the top of this Privacy Policy.

If we consider any changes to this Privacy Policy to be reasonably material, we will notify you prior to the change becoming effective. Notice of any change to this Privacy Policy will be posted via our Services, sent via direct communications to you or through other channels. If you do not agree to these changes, you should stop using our Services. By continuing to use our Services after any changes to this Privacy Policy, you are deemed to have accepted to the revised Privacy Policy.

5. COLLECTION OF DATA

The types of data we collect may include, but is not limited to:

(a) contact information: such as your (or Connected Persons’) legal name, business name, contact information, mailing address, email address, region of residence and telephone and mobile phone number;

(b) business information: such as your (or Connected Persons’) business registration number, business registration type, business licence, business registration certificate, registered address, business address, legal representative details, taxpayer identification number, VAT number, VAT certificate, registration region, date of registration and validity of registration;

(c) sales information: such as your (or Connected Persons’) resell permit, third-party sales website screenshots, sales platform details;

(d) bank account Information: such as your (or Connected Persons’) list of bank accounts owned and list of beneficiary bank accounts (including bank code, secondary bank code, bank region, bank account type, bank name, account number, etc.);

(e) transaction information: such as transaction date, transaction ID, transaction type, destination bank account (including bank name, bank code, secondary bank code, bank region, bank account type, bank account number, etc.), destination currency and transaction purpose; and

(f) know your client (KYC) information: such as KYC status and date of last KYC.

6. ACCURACY OF DATA

You are responsible for ensuring all data you provide is accurate and complete. Please see “Right to Access and Correction of Data” section for information about how you may access and correct your data.

7. PURPOSES OF USE OF DATA

You consent to our collection, holding, use and processing of your (and/or the Connected Person's) data for the following purposes and within the period necessary to achieve such purposes:

(a) to provide the Services to you;

(b) for customer onboarding and conducting screening, KYC or due diligence checks on you, your business and Connected Persons;

(c) to execute transactions for you, including billing and payment processing purposes;

(d) for administration and management of those services and goods which you have registered for and subscribed to, including the renewal of service contracts;

(e) to provide you with account registration, account setup and customer service and for verification of your identity, security, fraud-detection, archival and backup purposes in connection with the provision of the Services;

(f) for business planning and to develop and improve our Services, respond to customer queries and preferences, including through customer surveys, language and location customisation, personalised help and instructions, or other responses to your usage of the Services;

(g) to analyse, verify and enforce contractual rights, and/or to check your credit, payment and/or status in relation to supply of Services to you;

(h) to enable the daily operation of your account and/or to collect amounts outstanding in your account with us, including through the use of debt collection agents;

(i) to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services;

(j) to meet disclosure obligations and other requirements imposed by or for the purposes of any laws, regulations, rules, codes of practice or guidelines (whether applicable in or outside Hong Kong) binding on us and/or our affiliates anywhere in the world, including to make disclosure to any legal, regulatory, governmental, tax, law enforcement or other authorities (whether in or outside Hong Kong);

(k) to exercise our rights where it is necessary to do so, for example to detect, prevent, investigate and respond to security incidents or breaches, data scraping, fraud, abuse, intellectual property infringement claims, financial crimes and other potential breaches of applicable law;

(l) to maintain and develop our business systems and infrastructure, including to test and upgrade these systems, software verification or administering software upgrades;

(m) any other purposes as may be agreed to between you and us, including the purposes set out in any application or terms and conditions for the supply of specific Services; and

(n) to fulfill any other purposes directly related to (a) to (m) above.

8. DISCLOSURE AND SHARING OF DATA

All data held by us is kept strictly confidential but we may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide and transfer such information to the following parties (whether in Hong Kong or overseas):

(a) our subsidiaries, holding companies, associated companies and or affiliates of, or companies controlled by, or under common control with us;

(b) any person or company who is acting for or on behalf of us, or jointly with us, in respect of the purpose or a directly related purpose for which the data was provided;

(c) our business partners, agents, contractors, suppliers, service providers and other service providers engaged by us to assist with providing the Services, including service providers for purposes such as hosting or operating our Services, payment and transaction processing, rewards, vouchers and commercial goods delivery (where applicable), cloud services, e-mail communication, research, survey, marketing and data analysis services;

(d) any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureaux, or collection agencies, security agencies, necessary to establish and support the payment of any Services being requested;

(e) any law enforcement agencies, regulatory authorities, government departments and related organizations, courts and tribunals, as required or authorised by applicable laws;

(f) any proposed or actual participant, assignee or transferee of all or any part of our operation or business;

(g) any organisations who manage our business and corporate strategies (and for such purposes), including those involved in a transfer or sale of all or part of our assets or business and those involved in managing our corporate risk and funding functions;

(h) any other person or entity who is under a duty of confidentiality to us and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information.