Privacy Policy

Last updated 2020-10-13 

Thank you for showing your interest in CENTRALEX and visiting www.centralex.com (“Site”). We hereby request that you read this Privacy Policy (“Policy”) before providing us with any personal information about yourself or any other person, if you do not agree with this Privacy Policy or any updates made to this Policy please do not use the CENTRALEX Site and Services. 

This Privacy Policy explains the way in which Centralex Holdings Ltd. (“CENTRALEX”) also referred to as “us”, “we” and “our” in this agreement, collects, maintains, uses and transfers customer personal information and data when using our Site and any of our products, services or applications (“Services”). Our policy is set to comply fully with the Personal Data (Privacy) Ordinance (Cap. 486 Laws of Hong Kong) (“the said Ordinance”). The said Ordinance regulates the collection and use of personal information in Hong Kong. Personal information and data is any information relating to any living individual from which it is possible to identify that individual.  When dealing with personal information and data we will ensure compliance of the Six Data Protection Principles (“DPPs”) which represent the core of the said ordinance. References in this agreement to “you” or “your” are to the individual who enters into the agreement with CENTRALEX. 

Changes to this Privacy Policy may take place from time to time, when material changes are made an announcement will take place and the updated Privacy Policy will be available on the site.  

The accuracy of the personal information and data which we hold relating to you is important, and therefore request that you keep us informed of any changes. 

CENTRALEX’S Site and Services are not intended for any individual below the age of 18, and we will never knowingly collect any data relating to minors.  

By using our Site and its Services you agree that you have read, understood and accepted our Privacy Policy. 

Privacy Commitment 

Our commitment to comply with the Personal Data (Privacy) Ordinance is premised on the following principles: 

  1. We collect only necessary personal information and data from customers for the provision of services and products. 
  1. Personal information and data will only be used for the purposes specified and not for other purposes except with the consent of our customers. 
  1. We will not disclose personal information and data to any external organizations unless we, (i) have the consent of our customers or (ii) are required to by law, but we will only do so under proper authority. 
  1. All practicable steps will be taken to ensure customers’ personal information and data is kept secure, confidential and accurate. Such data will not be retained longer than necessary. 
  1. Only authorized personal can access or process the personal information and data of customers. 
  1. Customers have the right to access or correct their personal information and data.  

What information and data do we collect about you 

Personal information, or data, which we collect refers to any information which can be used to identify a person. We collect, use, store and transfer the following personal information and data: 

Identity Information: (i) full same [first, middle and last name], (ii) title, (iii) date of birth, (iv) visual face image [Selfie], (v) username, and (vi) government issued Identity document, and/or Passport 

Contact information: (i) telephone number, (ii) email Address, (iii) home address [proof of physical address], and (iv) billing address. 

Profile information: (i) username and password, (ii) requests for services made by you, (iii) any interaction or communication between you and CENTRALEX, and (iv) profile personal preferences. 

Usage information: (i) we collect any information relating to how you use our Site and Services. 

Technical information: (i) personal IP address, (ii) geolocation data, (iii) browser type, (iv) session and persistent cookie preferences, (v) date and time access, and (vi) operating systems and platform; 

Transactional information: (i) details relating to any transactions which took place using any of CENTRALEX’S Services, and (ii) details regarding payments made or received by you. 

Communication information: (i) details relating to your preferences regarding any marketing information received from us and your direct communication preferences. 

In order for you to proceed with your account registration and to allow you to begin to utilize our Services , you will need to provide specific consent for the requested formal identity information (which includes consent for the “visual face image”)  to undergo identity verification and screening for Anti-Money Laundering (AML), Fraud, Counter Terrorist Financing (CTF) and Know Your Customer (KYC) compliance. This verification and screening process will be conducted by our approved 3rd party. If you refuse to provide consent you be not be able to complete your account registration, therefore the account will be closed, and you will not be able to use any of CENTRALEX’S Services. 

CENTRALEX does not collect or request any special categories of personal information or data including race or ethnicity, trade union membership, political opinion, beliefs, sexual orientation or any information relating to your health. 

All additional non-required information which you provide to us will be done so voluntarily. 

Failure to provide any of the required information may lead to us not being able to engage in any further dealings, at which point you will be notified of this and we may be required to close your account. 

How do we collect your personal information and data 

CENTRALEX uses three (3) main channels in order to collect your personal information and data, these channels are: 

  1. Direct interactions 
  • account creation and registration; 
  • making use of any of our Services; 
  • communicate with us or providing feedback; 
  • consent for marketing material to be distributed to you; 
  • applying for a product or service; and 
  • subscribe to our publications. 

 

  1. Automated collection 
  • technical information will be collected from automatically you when you visit or interact on our Site; 
  • transactional information will also be collected automatically from you when using our Services and perform transactions via the Centralex Exchange. 

 

  1. Third party information 
  • during the identity verification process conducted by our approved 3rd party your information will be screened against information listed on other databasesas per our AML, CTF and KYC guidelines. 

Purpose of personal information and data collection and use 

We collect your personal information for rendering a better service experience to you. Your information is collected when your register on our site, place an order, subscribe to our newsletter or fill out a form. When ordering or registering on our Site, as appropriate, you will be required to enter certain information, but not limited to the following: name, Email address, mailing address or phone number. You may however visit our site anonymously. 

We do not sell, trade or otherwise transfer your personal information to outside parties. This does not include our trusted and approved 3rd parties who assist us in operating our website, conducting our business, assist us in providing our services to you, so long as parties agree to keep this information strictly confidential. In certain instances, we may also release your information when we believe release is appropriately required to comply with applicable laws, enforce our Site policies, to protect ours and the rights of others, property, or safety.  

We may also use any of the information we collect from you in the following ways: 

  • We use your personal information in order to ensure adherence to applicable laws and regulations, while enabling us to address any requests made by appropriate government authorities and law enforcement agencies; 
  • we use your information and data to onboard you as a new client and process your account application and registration; 
  • it is extremely important for us and our customers that we continuously monitor and investigate in order to prevent all potentially prohibited and illegal activities which violate our User Agreement; 
  • with the information which we collect and process from you, we continuously monitor activities to ensure any fraudulent or illegal activities are reported; 
  • we use your verification information in order to identify you and provide you with a personalised experience; 
  • we use your information in order to communicate directly with you in order to keep you up to date regarding all account related information, services which we provide and to address all queries submitted to us by you; 
  • we actively monitor your data to better understand how you use our Site and Services, which is in turn used to improve our Site and service performance; 
  • help us administrate our website our Site and protect our business; and  
  • with the use of your selected communication preferences we are able to offer you a personalised marketing experience. 

Disclosure 

We use the aid of our trusted and approved 3rd parties and sub-contractors in order to provide you with the requested Services and complete related tasks, you hereby agree that we may share your personal information and data with our approved 3rd parties. The protection and security of your personal information and data is a major priority for us, therefore when we engage with our 3rd parties we ensure that they respect your personal information and data by keeping it strictly confidential, so that it will only be used for the intended processing purposes. 

Your personal information and data may be shared with the following external entities: our (i) approved 3rd party service providers who assist us with our onboarding procedure and conduct AML, CTF and fraud prevention screening activities as well as identity verification procedures, any (ii) applicable regulatory and law enforcement agencies when required, and (iii) entities who assist us with our customer service facilities. 

Protection of personal data 

CENTRALEX takes the security of your personal data seriously. Therefore, we implement a variety of security measures to maintain the safety of your personal information. We also offer the use of a secure server. All provided sensitive information is transmitted via a Secure Socket Layer (SSL) technology and then encrypted into our Database to be accessed only by those who are authorised with special access rights to our systems and are required to keep the information confidential. We use cookies to help us remember as well as to process the items in your trades and understand as well as save your preferences for future visits. 

Please note that there is no 100% guarantee for the security of any information which is transmitted over the internet or stored via electronic methods. We therefore request that if you may suspect that your information may be at risk please contact our customer services immediately.  

Accuracy of personal data 

CENTRALEX will ensure accuracy of all personal data using generally accepted practices and guidelines. We would request the provision of relevant verification documents such as, government issued Identity card/Passport/Proof of address (utility bills and bank statements). 

We also ask that you keep us informed of any changes which may have taken place to your personal information and data, enabling us to maintain as accurate records as possible. 

Access and correction of personal data 

Under and in accordance with the terms of the said Ordinance, any customer has the right to check and correct his/her personal data held by CENTRALEX.  

In accordance with the terms of the said Ordinance, CENTRALEX has the right to charge a reasonable fee for the processing of any data. 

Retention of personal data 

All personal data will be kept in accordance to the guidance set out by the Ordinance. Personal data will only be retained as long as necessary to fulfil its original purpose for which the data was collected.  

We will only retain your personal information and data for extended periods if we are required to do so by law. 

CONTACT US 

All enquiries and requests regarding CENTRALEX’s compliance with its obligations under the said Ordinance should be in writing to the following contact details: 

Email: [email protected]