Last updated: 31-10-2018

Privacy Policy

  1. FinFabrik is committed to ensuring that all personal data collected and processed, whether or not through FinFabrik’s applications, including but not limited to BrokerFabrik, CryptoFabrik and CrossPool and its websites, including but not limited to this website and other websites operated by FinFabrik (“Applications”), are handled and used in accordance with the relevant provisions of the Personal Data (Privacy) Ordinance and the General Data Protection Regulation.
  2. The Applications are not intended for children and we do not knowingly collect data relating to children.

CONTACT DETAILS
  1. If you have any questions about this Privacy Policy or our Privacy Practices, please contact us at [privacy@finfabrik.com].

CHANGING OUR POLICY
  1. We may change this Privacy Policy from time to time. If we make any changes, we will revise the “Last Updated” date at the top of this Privacy Policy.  If there are material changes to this Privacy Policy, we will endeavour to notify you more directly by email or means of a notice on the home page prior to the change becoming effective.  Whether or not a change is material will be solely determined by us.
  2. We encourage you to review our Privacy Policy whenever you access the Applications to stay informed of our privacy practices and the ways you can help to protect your privacy.
  3. If you disagree with any changes to this Privacy Policy and do not wish for your personal data to be subject to the revised Privacy Policy, you will need to deactivate your account with us and stop using the Applications.  Your use of the Applications after the posting of such change will constitute your consent to such changes.

THIRD-PARTY LINKS
  1. The Applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Applications, we encourage you to read the privacy policy of every website you visit.

PERSONAL DATA COLLECTED AND HELD
  1. In order to provide better services to you, we may collect personal data, or personal information, from you when you attend our functions, use our services, register with us or communicate with us. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
  2. The typical types of information held by FinFabrik are basic contact details (such as name, job title, company name, address, email, telephone and fax numbers), a record of our contact with you and your areas of interest (such as sectors, events and publications).
  3. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
  4. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

MAIN PURPOSES OF COLLECTING AND KEEPING PERSONAL DATA
  1. The main purposes for which personal data are kept and used by FinFabrik include:
    a. to provide services or information to facilitate companies to set up or expand their business operations;
    b. to mail communications, publications and invitations, as selected or requested by you, or as we may consider to be relevant to you;
    c. to measure the success of specific campaigns and for general market research;
    d. for registration for events;
    e. to process transactions (your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested);
    f. to verify your identity and obtain additional information when your account transacts in fiat currencies for ‘know-your-client’ purposes;
    g. for recruitment; and
    h. for billing and invoicing of products and services
  1. You may choose not to receive (‘opt-out’ of) any or all marketing messages from FinFabrik at any time. You may do this by [logging into the Applications and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you] or by contacting us at [privacy@finfabrik.com].

THIRD-PARTY MARKETING
  1. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

PRIVACY OF PERSONAL DATA
  1. Our website uses cookies to help us gauge what information is most useful to which users and such like. Cookies, however, keep the identity of our individual website users anonymous. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
  1. In addition, our websites use Google Analytics, a service which transfers website traffic data to Google servers in the United States.  Google Analytics uses cookies to help our websites analyse how users use our websites.  By using our websites, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out herein.  You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.  For more information about this feature, you can read Google’s dedicated page available here.
  1. The data collected will be kept in confidence and will only be used for the purposes for which we collected it. FinFabrik will not divulge or sell your personal data to external parties for their own purpose.
  1. Notwithstanding the above paragraph, FinFabrik may release your information without your knowledge or consent, where there is required or permitted by law, when we believe such release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety.
  1. Where we use agents, contractors and personnel who provide services to FinFabrik (for example, to those agencies engaged by FinFabrik to administer the distribution of materials), we may transfer your personal data to them.
  1. We may also collect data for quantitative analysis, marketing, advertising, development, data analysis, cross device capabilities or other uses. Such data will be anonymised before processing and will not affect your use of FinFabrik products in any way.

SECURITY AND RETENTION OF PERSONAL DATA
  1. Only authorised personnel will have access to, custody of and the means of using the personal data FinFabrik collects from you. FinFabrik is sensitive to your rights and promotes a privacy-aware culture that respects you and your rights.
  1. We will use reasonable endeavours to procure any third parties who are engaged by FinFabrik, and who will, in the due course of their engagement, have access to any of the personal data that FinFabrik has access to, to be bound by the same terms as FinFabrik, as is set out here.
  1. Data captured on-line or via the Applications are retained on FinFabrik’s server. Storage on our server is protected in accordance with the requirements of the Government of the Hong Kong Special Administrative Region, which protects against unauthorised or accidental access, processing, erasure or other use.
  1. FinFabrik retains personal data so long as the data are still required for the purposes mentioned above.

ACCESS TO AND CORRECTION OF PERSONAL DATA
  1. An individual may request access to his personal data held by FinFabrik pursuant to the Personal Data (Privacy) Ordinance. A charge may be imposed to cover the cost of photocopying personal data at the rate as approved by the Secretary for Financial Services and the Treasury. In addition, an individual may also request for correction of his personal data held by FinFabrik if he considers the data to be inaccurate.
  1. Data correction or request for data access may be made in writing by post to FinFabrik’s registered address at Room 05, 14/F, 135 Bonham Strand Trade Centre, 135 Bonham Strand, Sheung Wan, Hong Kong, or by email at [privacy@finfabrik.com].

YOUR LEGAL RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION
  1. You have the right to:
    a. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    b. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    c. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    d. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    e. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    I. If you want us to establish the data’s accuracy.
    II. Where our use of the data is unlawful but you do not want us to erase it.
    III. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    IV. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    g. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Privacy policy 1.    FinFabrik is committed to ensuring that allpersonal data collected and processed, whether or not through[MC1] [IW2] FinFabrik’s applications,including but not limited to BrokerFabrik, CryptoFabrik and CrossPool and itswebsites, including but not limited to this website [MC3] [IW4] andother websites operated by FinFabrik (“Applications”), are handled and used in accordance with the relevant provisions of the PersonalData (Privacy) Ordinance and the General Data Protection Regulation. 2.    The Applications are not intended for childrenand we do not knowingly collect data relating to children. contactdetails 3.    If you have any questions about this PrivacyPolicy or our Privacy Practices, please contact us at [privacy@finfabrik.com]. Changing our Policy
4.    Wemay change this Privacy Policy from time to time. If we make any changes, wewill revise the “Last Updated” date at the top of this Privacy Policy.  If there are material changes to this PrivacyPolicy, we will endeavour to notify you more directly by email or means of anotice on the home page prior to the change becoming effective.  Whether or not a change is material will besolely determined by us. 5.    We encourage you to review our Privacy Policy whenever you access the Applicationsto stay informed of our privacy practices and the ways you can help to protectyour privacy. 6.    Ifyou disagree with any changes to this Privacy Policy and do not wish for your personaldata to be subject to the revised Privacy Policy, you will need to deactivateyour account with us and stop using the Applications.  Your use of the Applications after the postingof such change will constitute your consent to such changes. Third-PartyLinks 7.    The Applications may include links tothird-party websites, plug-ins and applications. Clicking on those links orenabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party websites and are not responsiblefor their privacy statements. When you leave our Applications, we encourage youto read the privacy policy of every website you visit. 
PERSONAL DATA COLLECTED AND HELD 8.    In order to provide better services to you, wemay collect personal data, or personal information, from you when you attendour functions, use our services, register with us or communicate with us. Personaldata, or personal information, means any information about an individual fromwhich that person can be identified. It does not include data where theidentity has been removed (anonymous data). 9.    The typical types of information held by FinFabrikare basic contact details (such as name, job title, company name, address,email, telephone and fax numbers), a record of our contact with you and yourareas of interest (such as sectors, events and publications). 10. Wherewe need to collect personal data by law, or under the terms of a contract wehave with you, and you fail to provide that data when requested, we may not beable to perform the contract we have or are trying to enter into with you (forexample, to provide you with goods or services). In this case, we may have tocancel a product or service you have with us but we will notify you if this isthe case at the time. 11. Itis important that the personal data we hold about you is accurate and current. Pleasekeep us informed if your personal data changes during your relationship withus. 
MAIN PURPOSES OF COLLECTING AND KEEPING PERSONAL DATA 12. Themain purposes for which personal data are kept and used by FinFabrik include: a.     toprovide services or information to facilitate companies to set up or expandtheir business operations; b.     tomail communications, publications and invitations, as selected or requested by you,or as we may consider to be relevant to you; c.      tomeasure the success of specific campaigns and for general market research; d.     forregistration for events; e.     toprocess transactions (yourinformation, whether public or private, will not be sold, exchanged,transferred, or given to any other company for any reason whatsoever, withoutyour consent, other than for the express purpose of delivering the purchasedproduct or service requested); f.      to verify your identity and obtainadditional information when your account transacts in fiat currencies for ‘know-your-client’purposes; g.     forrecruitment; and h.    for billing and invoicing of products andservices  You may choose not to receive (‘opt-out’ of) anyor all marketing messages from FinFabrik at any time. You may do this by[logging into the Applications and checking or unchecking relevant boxes toadjust your marketing preferences or by following the opt-out links on anymarketing message sent to you] or by contacting us at [privacy@finfabrik.com]. [MC1]Questions:do we refer also personal data collected through personal meetings, contacts,emails, events? [IW2][GPS: Weare not sure under what circumstances you would physically collect personaldata.  As owners of personal data need toprovide consent to your use and collection of the data, if you are collectingpersonal data under any agreement, it should include language specifying suchconsent.  This can be done by annexingthis Privacy Policy.] [MC3]Doesthat cover sitelet that branches out from main website www.finfabrik.com, that are owned/operatedby FF, or we should list each individual website here?Example, crosspool.io    [IW4][GPS: Wehave added language to state that this statement covers all websites operatedby FinFabrik.  However, as this statementis a generic form, we recommend it to be repeated on each separate website.]
PRIVACY OF PERSONAL DATA 1.    Our website uses cookies to help us gauge whatinformation is most useful to which users and such like. Cookies, however, keepthe identity of our individual website users anonymous. If you disable orrefuse cookies, please note that some parts of this website may becomeinaccessible or not function properly. 2.    In addition, our websites use Google Analytics,a service which transfers website traffic data to Google servers in the UnitedStates.  Google Analytics uses cookies tohelp our websites analyse how users use our websites.  By using our websites, you consent to theprocessing of data about you by Google in the manner described in Google’sPrivacy Policy and for the purposes set out herein.  You can opt out of Google Analytics if youdisable or refuse the cookie, disable JavaScript, or use the opt-out serviceprovided by Google.  For more informationabout this feature, you can read Google’s dedicated page available here.

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