Sailrich Limited Personal Information Collection Statement ("PICS") and Privacy Policy Statement ("PPS", collectively, "Privacy Policy")
Sailrich International Limited ("us", "we", "our", or "Sailrich") usually only collects business data, business contact information, and "personal data" (as defined under the Personal Data (Privacy) Ordinance (Cap 486) ("PDPO") for the main purposes of (a) fulfilling our obligations under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap 615 of the Laws of Hong Kong) ("AMLO"); and (b) operating our money services pursuant to our money service operator ("MSO") licence obtained under the AMLO.
Where we collect personal data, this Privacy Policy aims to give you information on how we collect, use, process and disclose your personal data when you use any of our services, including but not limited to money remittance and money changing services (collectively, "Sailrich Services").
Depending on the Sailrich Service selected by you, you, as the user, may enter into one or more agreements (collectively, the "Agreements") with us and/or our affiliates providing those Sailrich Services. Those agreements may contain additional terms regarding privacy and our use of information about you. By using Sailrich Services and providing your personal data, you are deemed to have given your consent for us to collect, use, process and disclose your personal data in accordance with this Privacy Policy.
Unless otherwise indicated or the context requires otherwise, reference to "you" or "your" are intended to refer to a user of Sailrich Services ("User"), and reference to "Sailrich", "we", "us" or "our" in this Notice and the Agreements include relevant companies of the Sailrich group of companies ("Sailrich Group") that are involved in providing the Sailrich Services (each an "Affiliate").
We are committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements of the PDPO with respect to the management of personal data. We are equally committed to ensuring that all our employees and agents uphold these obligations.
We collect and use personal data about you, including when you interact with us, register for an Sailrich account, use the Sailrich Services to make, receive or arrange for the receipt of payments, conduct financial transactions, or otherwise visit or use Sailrich Services.
The personal data we may collect (about you and your legal representative, owner, directors, partners, committee members, your ultimately beneficial owner) includes but is not limited to:
1.1 basic personal details, including and without limitation to first and last name, date and place of birth, identification numbers, and (if applicable) copies of personal identification documents;
1.2 contact information (including address, phone number, email, or other information that permits us to contact you);
1.3 account information;
1.4 registration details;
1.5 financial information and tax identification information;
1.6 transaction details (order number, trading time, transaction amount, etc.);
1.7 technical information;
1.8 information about the device you use to interact with us, and
1.9 information from your visits to our websites or mobile applications.
We collect personal data about you in connection with the Sailrich Services. For example, we collect your personal data when you browse our website, enquire about or register to use any of the Sailrich Services, sign a contract with us, provide your personal data during the merchant on-boarding process, log into your Sailrich account to use the Sailrich Services on our site; or when you communicate with us via e-mail, phone, SMS, or any other electronic means.
We also receive personal data about you from other sources, including without limitation:
2.1 merchants and other third parties, including those who support the ability to make payments and conduct transactions through Sailrich Services;
2.2 Sailrich’s Affiliates;
2.3 suppliers providing services on our behalf;
2.4 banks and other payment institutions that we cooperate with to provide you with the Sailrich Services; and
2.5 publicly available sources.
We combine information of you from various sources, including the information you have provided to us.
Please refer to the sections on "How do we use your personal data?" and "What is our legal basis for using your personal data?" in this Privacy Policy for more details.
We use the information we collect to operate our business, and provide you with Sailrich Services. Examples of how we may use your personal data include the following:
3.1 verifying your identity, including during account creation and payment password reset processes;
3.2 verifying your eligibility as a User of Sailrich Services;
3.3 processing, maintaining and managing your registration as a User;
3.4 providing you with Sailrich Services and related User services, including operating the Sailrich Services and enabling transactions, customizing your user experience, enabling the receipt of balance top-ups, financing proceeds and third-party payments, facilitating the settlement of payment for goods and services and providing other fund settlement services, handling foreign exchange conversions, charge-backs, sending notices about transactions, and responding to your queries, feedback, claims or disputes;
3.5 contacting you in relation to our provision of Sailrich Services, contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about Sailrich Services or other related products and services, collecting feedback from you and your staff / representatives about our products and services and using such feedback to improve our business and/or customize products and services; sending you information about products and services,including for promotional purposes; and contacting you for legal purposes;
3.6 assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and otherwise protecting the integrity of our platform;
3.7 managing our risk, performing creditworthiness and solvency checks on Users, or detecting, investigating, preventing or remediating violations of your agreements with us or any of our applicable policies, industry standards, guidelines, laws and regulations, etc.;
3.8 making disclosures as may be required by any rules, law or regulation, regulatory authorities, government official or other third party, including any card association or other payment network. Such disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement applicable to us or any Affiliates (including "know your customer", anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes);
3.9 making disclosures to third parties including relevant regulators to prevent any harm or financial loss, to report suspected illegal activity or to establish, exercise, or defend claims or potential claims on behalf of ourselves or our Affiliates;
3.10 improving and optimizing the Sailrich Services;
3.11 managing our business including to protect Users, prevent harm, fraud or theft to ourselves or others, maintain the security of our products, and protect our rights or property and those of others;
3.12 making disclosures as may be required by our contract with third parties including but not limited to financial institutions and payment service providers that we partner with in order to provide Sailrich Services to you. These third parties may use your personal data to (a) fulfil their customer/transaction due diligence, control and risk management requirements, (b) fulfil its know-your customer and like obligations, (c) enable the provision, improvement, development, and monitoring of its services and products, enhance efficiency of operational and other support functions, for statistical or analytical purposes or manage customer service queries in an efficient and timely manner, (d) conduct tax reporting, (e) comply with any law, regulation, court order or other binding obligation of a competent authority, (f) provide you with Sailrich Services, amongst others; and
3.13 for business purposes (including business transfer and assignment); and
3.14 comply with applicable laws, or in other ways for which we will notify you at the time your personal data is collected (to the extent permissible by applicable law).
We share your personal data to operate and manage our business for the purposes indicated under "How do we use your personal data?" and "What is our legal basis for using your personal data?". For example, we may share your personal data with:
4.1 Sailrich’s Affiliates;
4.2 third parties that we work with in order to facilitate the provision of Sailrich Services, including:
(a) any agent, contractor or third party service provider that we work with in providing Sailrich Services. For example, we work with third parties to help us with fraud prevention, anti-money laundering checks, credit checking, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts and payment extension services, or to provide trade financing services and money services;
(b) financial institutions, card associations, payment networks or acquiring institutions, and others, including but not limited to those involved in processing payments and conducting transactions through Sailrich Services; and
(c) law enforcement agencies, insurers, government and regulatory authorities or any other organisations to which Sailrich, or any Affiliate or third party service provider, is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement; and
(d) our own and others’ professional advisors (e.g., lawyers, accountants, auditors, and trustees).
These third parties may provide your personal data to their affiliates in EEA, the US, Singapore and China, their agents, service providers, sub-contractors, auditors, professional advisers, financial intermediaries, trade repositories, and financial market infrastructure entities and their operators, insurers and insurance brokers, governments, regulators, investigative, supervisory or judicial authorities, courts of competent jurisdictions, amongst others.
Please refer to the section on "How do we store and protect your personal data?" for information on how we keep your personal data secure when sharing it with others.
We will keep your personal data in accordance with our policies and for as long as it is necessary to provide you with the Sailrich Services or fulfilment of the purpose(s) for which your personal data have been collected. In addition, we may retain your personal data for a longer period (including after you are no longer a User) if it is necessary to do so in order to comply with laws and regulations applicable to us.
We use a variety of security measures and technologies designed to help protect your personal data from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws and regulations. You are responsible for maintaining the security of your account information (username, password, etc.) for Sailrich Services in your possession or control.
Despite us taking all reasonable measures to ensure that your personal data is protected, please understand that the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal data transmitted through any online means, therefore, any transmission remains at your own risk.
The Sailrich Services and our website may provide links to other websites and services (including other online merchant sites) for your convenience and information. These services and websites may operate independently from us. Linked services and websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for these websites’ or services content, any use of these services or websites by you, or the privacy practices of the operators of these services or websites.
We may change, amend or revise this Privacy Policy from time to time. We will notify you of any substantive or material change in this Privacy Policy by updating the web page where the Privacy Policy is posted, sending push notifications, e-mails or letters, by phone or by publishing announcements on our website www.sailrich.com.
You can review this Privacy Policy at the home page of our website www.sailrich.com.
Please note that we use your personal data on bases set out below:
8.1 For the performance of any contracts to which you are a party.
8.2 To comply with legal and regulatory obligations.
8.3 For legitimate business purposes aligned with the section on "How do we use your personal data?". We, however, do not proceed if we think your interests or fundamental rights and freedoms relating to your personal data may be prejudiced.
8.4 To help us operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised, and to make your experience with us efficient and effective.
Your personal data may be transferred to EEA, the US, Singapore and China. We will, however, comply with our legal and regulatory obligations in doing so, including but not limited to having a lawful basis for transferring your personal data and putting appropriate safeguards in place to ensure an adequate level of protection for your personal data. We will also ensure that the recipient in another country protects your personal data at a standard of protection comparable to protection under applicable laws.
If you would like further information about our practice to transfer your personal data outside Hong Kong, you can contact us as set out in the Contact us section below.
Subject to applicable data protection and privacy laws and regulations, you may:
10.1 ask us about the processing of your personal data, including request to access, obtain a copy of, or correct your personal data by completing the applicable form available at https://www.pcpd.org.hk/english/resources_centre/publications/forms/forms.html;
10.2 in case of sensitive personal data and/or in certain circumstances as determined by us on a case-by-case basis, request to delete, or refuse to share or transfer such information;
10.3 in certain circumstances as determined by us on a case-by-case basis, request the restriction of the processing of your personal data or object to that processing;
10.4 withdraw your consent to the processing of your personal data (where Sailrich is processing your personal data based on your consent) by written notice to us;
10.5 request receipt or transmission to another organisation, in a machine-readable form, of the personal data that you have provided to Sailrich where we are using your personal data based on consent or performance of a contract; and
10.6 complain to the relevant supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal data.
Where you are given the option to share your personal data with us, you can always choose not to do so. If we have requested your consent to process your personal data and you later choose to withdraw it, we will respect that choice subject to our legal obligations.
However, choosing not to share your personal data with us or withdrawing your consent to our use of it could mean that you are unable to use Sailrich Services and products offered by us. After you have chosen to withdraw your consent, Sailrich may be able to continue to process your personal data to the extent required or otherwise permitted by applicable data protection and privacy laws or regulations.
If you would like to exercise your rights, contact us using the details set out in the Contact us section below.
If you have questions, requests about the privacy of your personal data or wish to access or correct your personal data, please contact us by email via mgt@sailrich.com.