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Privacy Policy


This Privacy Policy explains how Amber Technologies Limited and its affiliates and subsidiaries (“Amber”) collects, uses, discloses, and protects user information obtained through the website (“Site”), mobile applications(“App”), or any other related services provided by Amber (collectively, “Services”). The terms “we,” “us,” and “our” refer to Amber. When we ask for certain personal information from users, it is because we are required by law to collect, use or disclose this information or it is relevant for specified purposes. Any non-required information you provide to us is done so voluntarily. You decided whether to provide us with these non-required information; you may not be able to access or utilize all of our Services if you choose not to.


By using the Site or App, you consent to the data practices described in this Privacy Policy. On occasion, Amber may revise this Privacy Policy to reflect changes in law or our personal data collection and use practices. If material changes are made to this Privacy Policy, the changes will be announced by posting on the Site or App. We will ask for your consent before using your information for any purpose that is not covered in this Privacy Policy.


The latest privacy policy has incorporated elements from the Personal Data (Privacy) Ordinance (”PDPO”) as we act in accordance with its personal information processing rules within Hong Kong.


INFORMATION WE COLLECT

We want you to understand the types of information we collect when you register for and use Amber’s Services


When you open an account to use our Services, you provide us with your personal information to enable us to assess your application and comply with the relevant laws and regulations. The information that we may collect from you is as follows:


  • Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bill, photographs, phone number, home address, and/or email.

  • Formal Identification Information: Government-issued identity document such as passport, driver license, national identity card, state ID card, passport number, driver license details, national identity card details, visa information and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.

  • Institutional Information: Employer identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation) and/or personal identification information for all material beneficial owners.

  • Financial Information: Bank account information, payment card primary account number (“PAN”), transaction history and/or trading data.

  • Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount and/or timestamp.

  • Correspondence: Survey responses, information provided to our support team, trading team, sales team and/or user research team.

We may collect and store certain information automatically when you use our Services. Examples include the internet protocol (the “IP”) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, log in details, the full URL clickstream to, through and from the Site or APP or Services, cookie Identifier and your activity on our Site or APP or Services, including the pages you visited, the searches you made and, if relevant, the services your purchase. 


We obtain information about you in a number of ways through your use of our Services, including through any of our Site, APP or Services, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of ongoing support service communications. We also receive information about you from third parties such as your payment providers and through publicly available sources. For example:


  • The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details.

  • Your business partners may provide us with your name and address, as well as financial information.

  • Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website or APP.

  • Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided to us.


WHY DO WE COLLECT THIS INFORMATION


To provide and maintain our services


We use the information collected to deliver our Services and verify user identity.


We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with Services without data like identification, contact information and transaction-related information.


To protect our clients


We use the information collected to protect our platform, users’ accounts and archives.


We use IP addresses and cookie data to protect against automated abuse such as spam, phishing and Distributed Denial of Service (DDoS) attacks.


We analyse trading activity with the goal of detecting suspicious behavior early to prevent potential fraud and loss of funds to bad actors.


To comply with legal and regulatory requirements


Respect for the privacy and security of data you store with Amber and complying with laws and regulations, we will not disclose or provide any personal information to third party sources without review from our legal case team and/or prior consent from the user.


To measure site performance


We actively measure and analyse data to understand how our Services are used. This review activity is conducted by our operations team to continually improve our platform’s performance and to resolve issues with the user experience.


We continuously monitor our systems’ activity information and communications with users to look for and quickly fix problems.


To communicate with you


We use personal information collected, like an email address to interact with users directly when providing customer support on a ticket or to keep you informed on logins, transactions, and security. Without processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions and inquiries. All direct communications are kept confidential and reviewed internally for accuracy.


To enforce our Terms of Service and other agreements


It is very important for us and our customers that we continually review, investigate and prevent any potentially prohibited or illegal activities that violate our Terms of Service. For the benefit of our entire user base, we carefully enforce our agreements with third parties and actively investigate violations of our posted Terms of Service. Amber reserves the right to terminate the provision of service to any user found engaging in activities that violate our Terms of Service.

HOW DO WE USE YOUR PERSONAL INFORMATION

We only use your personal and sensitive information for the reason we collect it as set out above and for the purpose(s) for which it was collected, or as otherwise permitted by law.


HOW DO WE DISCLOSE YOUR PERSONAL INFORMATION


We disclose your personal information:


  • for the primary purpose for which it was collected.

  • for the purposes that a reasonable person will consider appropriate in the circumstances.

  • where you have consented.

  • for direct marketing by us where consent has been given but giving you the opportunity to opt out of such direct marketing. We include our contact details in direct marketing.

  • to any members of us, which means that any of our affiliates and subsidiaries may receive such information.

  • to any of our service providers and business partners, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, research or other services.

  • where permitted under the PDPO or other applicable law.


If we disclose your personal information to service providers and business partners, in order to perform the services requested by the client, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations.


We require that service providers and business partners who process personal information to acknowledge the confidentiality of this information, undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Policy.


We do not disclose your personal information for any secondary purposes unless your consent has been given or if so permitted or required under the PDPO or other applicable laws and regulations.


We will not sell or license any personal information that we collect from you without your explicit consent. We will share your information with the following service providers and business partners:


  • With third party identity verification services in order to prevent fraud. This allows us to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used in connection with the provision of identity verification and fraud prevention services. We use Jumio Corporation to verify your identify by determining whether a selfie you take matches the photo in your government issued identity document. You agree that we and Jumio Corporation may use the collected information for identity verification services and purposes. The information collected from your photo may include biometric data. Jumio Corporation’s Privacy Policy, available at https://www.jumio.com/legal-information/privacy-policy/jumio-corp-privacy-policy-for-online-services/,  describes its collection and use of personal information.

  • For the purpose of providing notification services to update you on your transaction and our business information, we will share your information with JPush Android SDK  commissioned by us via embedding JPush Android SDK code, plug-ins, SDKs, etc. to collect and use your information in accordance with its privacy policy. You agree that we and JPush Android SDK may use the collected information subject to laws and regulations. JPush Android SDK’s Privacy Policy, available at https://www.jiguang.cn/en/license/privacy, describes it collection and use of personal information. 


HOW DO WE PROTECT YOUR PERSONAL INFORMATION


We have implemented a number of security measures to ensure that your information is not lost, abused, or altered. Our data security measures include, but are not limited to: PCI Scanning, Secured Sockets Layered encryption technology, pseudonymization, internal data access restrictions, and strict physical access controls to buildings & files. Please note that it is impossible to guarantee 100% secure transmission of data over the Internet nor method of electronic storage. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.


If you suspect that your personal information has been compromised, especially account and/or password information, please lock your account and contact customer service immediately.


WITHDRAWAL OF CONSENT


Upon reasonable notice being given by you of your withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of your personal information, we will inform you of the likely consequences of withdrawing your consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal information unless it is required or authorized under applicable laws.


ACCESS, ACCURACY AND CORRECTION OF YOUR PERSONAL INFORMATION


We rely on you to ensure that your profile and contact information is accurate. Please let us know of any changes to your personal information. You may update the accuracy or completeness of such information, and request that corrections be made to it. Please send all your inquiries, requests and notifications to servicese@ambergroup.io.


USE OF COOKIES


A number of places on our Site make use of cookies. These are essentially small text files that are stored on your computer's hard drive or your user device by your web browser. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Cookies help to make our Site more user-friendly, more effective and more secure. By default, web browsers enable the use of cookies but this function can also be disabled. However, this will result in some services not being available. It is also possible to manually delete cookies after their use via the web browser. More information may be available from your web browser provider.


TRANSFER OF PERSONAL INFORMATION OUTSIDE OF HONG KONG


We will ensure that any transfers of personal information to a territory outside of Hong Kong will be in accordance with the PDPO so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPO.


LINKS TO OTHER WEBSITES


If you follow a link from our Site, APP, or Services to another site or service, this Privacy Policy will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy policies appearing on those sites or services.


DATA PROTECTION OFFICER


If you have concerns or further queries about how we are handling your personal information, or any problem or complaint about such matters, please contact our Data Protection Officer at sc@ambergroup.io.