Privacy at a glance
- We collect information to open and run your account, keep it secure and meet the law, including anti-money-laundering rules.
- We never sell your personal information.
- We share it only with partners who help us provide the service, and with authorities when the law requires it.
- You can ask to see or correct your information at any time.
Who is responsible for your information
[Harbour & Hills legal entity name] ("we", "us") is the data user responsible for your personal data under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong. Where a licensed partner provides part of the service, that partner may also be responsible for the data it handles. Our Licences & disclosures page lists these partners.
What we collect
Information you give us
- Identity: name, date of birth, nationality, identity document details and images, and a selfie for our liveness check.
- Contact: email address, phone number and home address.
- Financial: source of funds, purpose of your account, tax residency, and details of the people and accounts you send money to.
- Communications: messages you send us and support conversations.
Information we collect when you use H Individual
- Transactions: what you send, receive, convert and spend, when and with whom.
- Device and usage: device type, operating system, app version, IP address, approximate location and how you use our app and website.
- Security: login history, and device signals we use to detect fraud.
Information from others
- Identity-verification, sanctions-screening and fraud-prevention providers.
- Banks, wallets and payment partners involved in your transfers.
- Public sources and official registers.
Why we use your information
- To provide your account: opening it, holding balances, making transfers and conversions, and giving you support.
- To meet our legal duties: verifying your identity, screening against sanctions lists, monitoring transactions and reporting suspicious activity, as anti-money-laundering laws require.
- To keep you safe: detecting and preventing fraud, account takeover and misuse.
- To improve H Individual: understanding how our products are used so we can fix problems and make them better.
- To tell you about our services: only where you've agreed, and you can opt out at any time.
We will tell you before we use your information for any purpose not listed here.
Sending data outside Hong Kong
Cross-border payments mean some of your information must go to other countries, for example to the bank receiving your money. Some of our service providers also store data outside Hong Kong, including in [list regions, e.g. Singapore, the EU, the US]. When we transfer data, we use contracts and other safeguards to protect it to a standard similar to Hong Kong law.
How long we keep it
We keep your information while your account is open. After it closes, we keep records for at least [six years / five years], because anti-money-laundering laws require it, and then delete or anonymise them. We may keep information longer if a legal claim or investigation needs it.
How we protect it
We encrypt data in transit and at rest, limit staff access to what each role needs, log access to sensitive data, and test our systems regularly. No system is perfectly secure, so please help by keeping your login details private. If a breach could put you at real risk, we'll tell you and the Privacy Commissioner as the law requires.
Your rights
- Access: ask for a copy of the personal data we hold about you.
- Correction: ask us to correct information that is wrong.
- Marketing: tell us to stop using your information for direct marketing.
- Questions and complaints: ask how we handle your data, or complain about it.
To make a request, contact our Data Protection Officer (details below). We'll respond within 40 days. We may charge a reasonable fee for access requests, as the law allows. If you're not happy with our response, you can contact the Office of the Privacy Commissioner for Personal Data, Hong Kong.
Marketing
We'll only send you marketing about H Individual if you've agreed to it. You can opt out at any time in Settings, by using the unsubscribe link in any email, or by contacting us. We'll still send you messages we need to, such as security alerts and changes to our terms.
Children
H Individual is only for people aged 18 or over. We don't knowingly collect information about children. If you think a child has given us their information, please contact us.
Changes to this policy
We may update this policy. If we make an important change, we'll tell you by email or in the app before it takes effect. The date at the top shows when it was last updated.
Contact us
Data Protection Officer, [Harbour & Hills legal entity]
Email: [privacy email]
Post: [postal address]
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