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Welcome to Key to Prop!

The Key to Prop (also referred to as the “Company” provides you (“you” or the “Member”) with a limited permission to use the services (the “Services”) offered by the Company subject to, among others, to the Privacy Policy contained herein (the “Policy”).

This Privacy Policy, together with our Terms of Business, outlines how we manage the personal data supplied to us by any of our clients and potential clients (“client”, “you”, “your”) or collected by us through your use of our services (“Personal Data”). By using our website, applying for an account with us, using our services or supplying to us your Personal Data, you indicate that you understand how we collect, store, use or share your Personal Data. If you don’t agree with this Privacy Policy, you shouldn’t use our website or access our services or provide any of your Personal Data to us.

LEGISLATION GOVERNING DATA PROTECTION

Data Protection is a fundamental component of today’s society and the development of good data protection practices contributes to fostering public trust. Though we are living in an era of rapid technological and social change, we must ensure that our privacy rights and entitlements are properly protected. Please find below the applicable link:

https://www.pcpd.org.hk/english/data_privacy_law/ordinance_at_a_Glance/ordinance.html

TYPES OF PERSONAL DATA THAT WE MAY COLLECT

We currently collect and process the following Personal Data either partially or as a whole:

  • Personal identifiers such as your name, address, IP-address, date of birth, contact information (email and phone numbers), details about your profession and occupation;
  • Your usernames and passwords, security questions and answers;
  • Financial information such as your bank account or credit card details, information relating to your source of income, source of wealth, details about your assets;
  • Information about your trading and investment experience;
  • Other information we consider necessary to perform our legal and contractual obligations.

To comply with the anti-money laundering legislation, we are required to verify your identity and conduct background checks. For that purpose, we will ask you to submit to us your identification documents such as:

  • Passport, national identity card, driving license photocard, residence permit;
  • Utility bills, bank statements;
  • Other documents we consider necessary to perform our legal and contractual obligations.

We keep records of your trading behavior, including a record of products you trade and their performance, historical data about your trades and investments and your investment preferences.

HOW WE COLLECT YOUR PERSONAL DATA

Most of your Personal Data is provided to us directly by you through your use of our services, particularly through:

  • Our website;
  • Account opening and sign up applications;
  • Our customer service communication (via online platforms, email, phone or otherwise);
  • Our market surveys or special offers.

We will keep record of any telephone (or other transmission media) communications with you and such records will be our sole property. The telephone communications (or other transmission media) may be recorded without the preliminary notice or use of a warning tone.

We may collect your Personal Data through third parties, particularly through our ‘refer a friend’ scheme, introducing affiliates etc.

HOW WE PROCESS YOUR PERSONAL DATA

We may process your Personal Data only if such processing is necessary, i.e has one or more valid lawful bases (the “Lawful Basis”), for any of the purposes listed below:

  • To verify your identity and set you up as our client (Lawful Basis: your consent for us to process your Personal Data or the processing is necessary to comply with our legal obligations);
  • To carry out our obligations arising from the agreement between you and us (Lawful Basis: your consent for us to process your Personal Data or the processing is necessary for the performance of our contract with you):
  • To provide you with the services available on our platform;
  • To process your withdrawals;
  • To deal with your requests and /or complaints.
  • To prevent and detect potentially illegal activities (Lawful Basis: processing of your Personal Data is necessary to comply with our legal obligations or necessary for our legitimate interests):
    • To prevent and detect money-laundering, financing of terrorism, fraud and other illegal activities or abuse of our services;
    • To enforce our Terms of Business and other contracts as may be relevant;
    • To comply with any applicable laws and regulations in any jurisdiction we operate in.
  • To protect our legitimate interests (Lawful Basis: processing of the Personal Data is necessary for the performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests):
    • To carry out our record-keeping, operational and compliance procedures;
    • To ensure the security of our website, the platform and any applications we may use;
    • To protect our property and rights or the legitimate interests of a third party, provided that such interests are not overridden by your interests or fundamental rights and freedom.
  • For business promotion and marketing purposes (Lawful Basis: your consent for us to process your Personal Data or the processing is necessary for our legitimate interests):
    • To keep you updated of the latest developments about our services;
    • To conduct market surveys and promotional activities, to create statistics and product analysis;
    • To personalise and foster the quality of our services and enhance client experience.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your Personal Data for the purposes listed in this Privacy Policy to the following categories of recipients:

  • Members of Key to Prop group of companies (included and not limited to subsidiaries, holdings) and any of their employees and contractors who need to know this information so they can provide you with the services you require. All such persons are required to follow this Privacy Policy and our security procedures when handling your Personal Data;
  • Third party service providers so that they can support our products and services, such as the website and platform maintenance services, collecting client feedback, marketing and advertising services, data analytics and search engine services. Our third-party service providers are permitted to use your Personal Data only for the purpose of providing services to us and may not otherwise share or use your Personal Data;
  • Fraud prevention and credit reference agencies. We may share your Personal Data with our third-party service providers to conduct anti-money laundering, fraud, sanctions, credit risk and customer due diligence checks, credit reference checks and fraud prevention checks;
  • Introducers, advisers and agents, if they directed you to us;
  • Courts, regulators and law enforcement agencies. We will share your Personal Data when we believe it is required to comply with applicable legal or regulatory obligations and to respond to requests from government authorities, including law enforcement or financial regulators. This may include authorities outside your country of residence;
  • Other third parties. We may share your Personal Data in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock;
  • Any third parties where the disclosure is required to enforce our Terms of Business or other contracts as may be relevant;
  • Anyone authorised by you.

HOW WE STORE YOUR PERSONAL DATA

We use appropriate technical and organisational measures to protect your Personal Data. In particular, we:

  • Hold Personal Data in secure storage facilities and where the information is held electronically, on secure servers;
  • Use other safeguards such as firewalls, authentication systems (e.g., passwords) and access control mechanisms to control unauthorised access to systems and data;
  • Regularly review our Personal Data collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems;
  • Restrict access to Personal Data to our employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations;
  • Provide regular training to our employees on Personal Data protection.

INTERNATIONAL DATA TRANSFERS

We may transfer your Personal Data to a third party within the Key to Prop or associates in any country for further processing in accordance with the purposes set out in this Privacy Policy. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means in accordance with Data Protection act and local regulations. These include putting in place data transfer agreements for transfers of Personal Data between our group companies, which require all group companies to protect Personal Data. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

By using our website, applying for an account with us, using our services or supplying to us your Personal Data, you indicate that you agree to your Personal Data being transferred, stored and processed in this way.

INFORMATION RETENTION

Your Personal Data will be retained for as long as required to fulfil the purposes for which we collected it, including any legal, regulatory, business or reporting requirements. When deciding the length of the retention period we take into consideration applicable law, regulation, our agreement with you, and the expectations and requirements. Most typically, your Personal Data will be retained for 7 years after your cease being our client.

When we consider that your Personal Data is no longer needed, we will then dispose it by securely destroying our records.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Subject to certain legal conditions, you have certain rights in relation to your Personal Data which include:

  • Right of access. You have the right to ask us for copies of your Personal Data;
  • Right to rectification. You have the right to ask us to rectify any inaccurate and/or complete any incomplete Personal Data. We will then correct out records and notify any third parties to whom such personal information may have been transmitted as described above;
  • Right to erasure. You also have the right to ask us to delete your Personal Data in certain circumstance unless we are required to hold it for legal or regulatory reasons or our own internal compliance requirements. If we have shared your Personal Data with third parties, we will let them know about the erasure where possible;
  • Right to restriction of processing. You have the right to ask us to restrict processing your Personal Data in certain circumstances. Please note you may not be able to benefit from certain service features for which the processing of your Personal Data is essential;
  • Right to object to processing. You have the the right to object to the processing of your Personal Data in certain circumstances;
  • Right to portability. You have a right in certain circumstance to obtain the Personal Data you have provided to us (in a structured machine-readable form) and to reuse it elsewhere or ask us to transfer it to a third party of your choice.

If you wish to exercise any of these rights, please contact us by email at support@keytoprop.com.

We will generally respond to any requests within twenty-eight days of receipt. We will not usually charge you a fee for a request. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

HOW TO COMPLAIN

If you have any concerns about our use of your Personal Data, you can make a complaint to us at:

Email: complaints@keytoprop.com