DAU Card
INTRODUCTION
1.1 Thank you for choosing the DAU Cards provided by Golden Fame Technology Limited (a company incorporated in Hong Kong with company number 76516750) (“GFTL”) and/or its affiliates (hereinafter also referred to as “I”, “me”, “my”, “we”, “us” and “our”). Capitalised terms used but not defined herein shall have the same meanings as ascribed to them in the Terms & Conditions of Use of the DAU Cards and words denoting singular shall include the plural, and vice versa.
1.2 By accessing/using the DAU Cards and/or the Services, you consent to the policies and practices set out in this privacy policy (the “Privacy Policy”) and you represent and warrant that you have the valid consent and authority from the Relevant Person(s) (defined below) for us to collect, use, disclose, process and store the Personal Data as described herein. This Privacy Policy describes how we may collect, use, disclose, process and store the Personal Data when you access or use the DAU Cards and/or the Services.
1.3 You agree that we may amend this Privacy Policy at any time by posting the amended version the Interface. Your use or continued use of the DAU Cards and/or any of the Services after such amendment shall be deemed as your acceptance and agreement to the same.
2. WHAT PERSONAL DATA WE COLLECT
2.1 We may from time to time collect, process, and store certain personally identifiable information that can be used to contact or identify you and where applicable, your shareholders, beneficial owners, directors, officers, authorised signatories, employees, representatives, guarantee/security providers and other natural persons related to you (“Relevant Persons”) via your use of the Services or where you have given your consent (“Personal Data”). Such Personal Data may include contact details, information and data generated in the ordinary course of your relationship with us, information and data collected when you or a Relevant Person participates in events organised by us and information from cookies on our website at https://goldenfame.tech (the “Site”) or the use of any information technology applications. The Personal Data that you may provide to us during the onboarding process may also include, without limitation:
(a) full legal name (including former name, and names in English and Chinese, if applicable);
(b) identification document type (e.g. Passport);
(c) identification document number (e.g. Passport No.);
(d) gender;
(e) date of birth;
(f) place of birth;
(g) nationality;
(h) residential address;
(i) country/state of residence;
(j) total net wealth (approximately in USD);
(k) purpose of account opening;
(l) initial and ongoing sources of wealth or income;
(m) nature and details of the business/occupation/employment;
(n) level of activity anticipated;
(o) source of funds/ assets to be used in the relationship;
(p) contact phone number;
(q) email address;
(r) your transaction history and spending pattern;
(s) bank account information;
(t) digital and intangible asset account details;
(u) your location data; and
(v) additional Personal Data or documentation at the discretion of our compliance team.
3. HOW WE USE THE PERSONAL DATA
3.1 We may use the Personal Data for the following purposes:
(a) to make decisions relating to the provision or continued provision of the Services to you;
(b) to administer, operate, deliver, improve, and personalise the Services;
(c) to process your payments and transactions, and to provide you with statements, invoices, receipts and other related information in relation to the Services;
(d) to monitor and record the usage of the Services and communications with you and/or the Relevant Persons (including for investigation and fraud prevention purposes)
(e) to detect, prevent and address technical issues;
(f) for risk assessment and data analysis (including data processing, anti-money laundering and credit analyses), internal management and to carry out internal/external audits;
(g) to communicate with you, your affiliates and/or your representatives in relation to events, the DAU Cards, the Services and other products or services offered by us or our affiliates, unless you have opted not to receive such information;
(h) to conduct market research, surveys, promotions and contests, and to analyse your preferences, interests and behaviour in relation to the DAU Cards and/or the Services;
(i) to fulfil any applicable legal, regulatory and compliance requirements (including anti-money laundering and tax obligations applicable to us);
(j) to enforce or defend our rights or property, our affiliates and other users of the DAU Cards; and
(k) carry out any other purpose(s) described to you at the time the data was collected.
3.2 For avoidance of doubt, we will not sell the Personal Data whether in part or in whole to anyone.
4. SHARING OF THE PERSONAL DATA
4.1 We may share the Personal Data with the following persons for the purposes stated above:
(a) our third-party service providers who help us provide, operate, maintain, secure and improve the DAU Cards and/or the Services;
(b) any person or entity that is part of us and our affiliates who is under a duty of confidentiality to the disclosing entity;
(c) our professional advisors and their affiliates;
(d) any person or entity that we engage or participate in for the purposes of marketing, advertising, or promoting the DAU Cards and/or the Services, such as social media platforms, online platforms, or third party websites;
(e) any person to whom we are under an obligation or otherwise to make disclosure pursuant to legal process or pursuant to any foreign or domestic legal, tax, and/or regulatory obligation or request;
(f) any person or entity that you authorise or consent to receive the Personal Data, such as your authorised representatives, agents, advisors, or beneficiaries; and
(g) any actual or proposed assignee or business transferee of us and/or its affiliates.
4.2 We may also share aggregated or anonymised Personal Data with the above persons to help administer, operate, deliver and improve the Services.
5. TRANSFER OF THE PERSONAL DATA
5.1 Information, including the Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Please note that we may transfer information, including Personal Data, outside your jurisdiction and process it there. Your consent to this Privacy Policy and your submission of such information represents your agreement to that transfer.
5.2 We will take reasonable measures to ensure that the Personal Data is treated securely and in accordance herewith and no transfer of the Personal Data will take place to an organisation or a country unless there are adequate controls in place.
6. RETENTION OF THE PERSONAL DATA
We will retain the Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use the Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. By accessing/using the DAU Cards and/or the Services, you consent to us retaining the Personal Data.
7. MARKETING COMMUNICATIONS
7.1 We may communicate news, promotions, and information relating to the DAU Cards and/or the Services. We may share Personal Data with our affiliates to send marketing communications.
7.2 We will only send you such marketing communications with your consent. By not notifying us through the Interface that you object to us using Personal Data for marketing, you explicitly consent to us using the Personal Data for marketing purposes.
8. COOKIE USAGE
8.1 While you access the Site, we may use the industry practice of placing a small amount of data that will be saved by your browser (“Cookies”). This information can be placed on your computer or other devices used to visit the Site. This information helps us recognise you as a customer, collect information about your use of the Services to better customise our services and better your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.
8.2 Most browsers are setup to accept Cookies automatically. Some Cookies expire when you finalise the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of the Services or your user experience.
8.3 Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. We do not respond to browser do not track signals.
9. INFORMATION SECURITY
9.1 We endeavour to protect ourselves and you from unauthorised access, alteration, disclosure, or destruction of the Personal Data we collect and store. We take various measures to ensure information security and we will periodically review our Personal Data collection, storage, and processing practices.
9.2 The security of your data is important to us, but you understand and acknowledge that no method of transmission over the Internet, or method of electronic storage is fully secure. While we strive to use commercially acceptable means to protect the Personal Data, we cannot guarantee its absolute security.
10. LINKS TO OTHER SITES
Our Site and Interface may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. You understand that we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
11. INTERACTION WITH OTHER USERS
You understand you are solely responsible for your interactions with other Users. We reserve the right, but have no obligation, to monitor disputes between you and other Users.
12. CONTACTING US
12.1 If you have any questions about this Privacy Policy or the use of the Personal Data, please contact us through the Interface with the subject “PRIVACY QUESTION”.
12.2 If you wish to know what Personal Data we retain and if you wish to have such Personal Data updated, corrected or deleted from our systems, please contact us through the Interface with the subject “DATA INQUIRY”. We will do our best to do so as soon as possible with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes.
12.3 If you wish to withdraw your consent, please contact us through the Interface with the subject “DATA INQUIRY”. Where you or a Relevant Person withdraws your/its/their consent or fails to supply relevant information or data required for us to provide the DAU Cards and/or the Services to you, we may be unable to provide or continue to provide DAU Cards and/or the Services to you.
12.4 In response to data access, correction, deletion or data portability request, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee especially if the request is repetitive or onerous.
13. LANGUAGE
If this Agreement is translated into any other language from English, the English language version shall prevail to the extent of any inconsistency.
14. SPECIFIC RIGHTS UNDER DIFFERENT JURISDICTIONS
(A) EUROPEAN ECONOMIC AREA
14.1 If you are a resident of the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process the Personal Data because:
(a) we need to use the Personal Data to contract with you or to perform our obligations thereunder;
(b) you have given us consent to do so;
(c) the processing is in our legitimate interests or necessary to comply with our legal obligations;
(d) to comply with all Applicable Laws.
14.2 If you are a resident of the EEA, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of the Personal Data. Please see Section 12 (Contacting Us) above.
14.3 In certain circumstances, you have the following data protection rights:
(a) the right to access, update or to delete the information we have on you;
(b) the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
(c) the right to object. You have the right to object to our processing of your personal information;
(d) the right of restriction. You have the right to request us to restrict the processing of your personal information;
(e) the right to data portability. You have the right to be provided with a copy of the information we have on you;
(f) the right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
(B) CERTAIN STATES IN THE UNITED STATES OF AMERICA
14.4 Under the laws of the states of California, Colorado, Connecticut, Utah and Virginia (the “Applicable States”), you may have rights to ask us to:
(a) provide access to certain information we hold about you, in some cases in a portable format, if technically feasible;
(b) update or correct your information;
(c) delete certain information we hold about you;
(d) opt in to or opt out of use of certain sensitive information we hold about you.
14.5 You may also have the right to designate an authorised agent to help you exercise these rights. To ensure the security of your account, we will generally ask you to verify your, or your authorised agent’s, request using the contact information you have already provided.
14.6 If you would like to exercise any of these rights, or appeal a decision made relating to your rights, please see Section 12 (Contacting Us) above.
14.7 We do not sell any personal information to anyone.
14.8 We will not discriminate against any exercising their rights under the privacy laws of California or other Applicable States.
14.9 Below are the additional disclosures required by the California Consumer Privacy Act and the California Privacy Rights Act (together, the “CCPA”), effective as of January 1, 2023. The personal information that we may collect, or may have collected from consumers in the preceding twelve months, fall into the following categories established by the CCPA, depending on how you engage with us:
(a) identifiers, such as your name, email, address, phone numbers, or IP address;
(b) personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code;
(c) characteristics of protected classifications under California or US federal law, such as age or gender, for example if we conduct user surveys or analysis;
(d) commercial information, such as purchase activity;
(e) internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details;
(f) geolocation information, such as the location of your device or computer determined from your IP address or mobile device’s GPS depending on your device settings;
(g) audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise;
(h) professional or employment-related information, for example information you may provide about your business; and
(i) inference data, such as information about your preferences.
14.10 The personal information that we may have disclosed about consumers for a business purpose in the preceding twelve months fall into the following categories established by the CCPA, depending on how you engage with us:
(a) identifiers, such as your name, email, address, phone numbers, or IP address;
(b) personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code;
(c) characteristics of protected classifications under California or US federal law, such as age or gender, for example if we conduct user surveys or analysis;
(d) commercial information, such as purchase activity;
(e) internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details;
(f) geolocation information, such as the location of your device or computer, for example if you enable location services to enhance your experience through applications we offer;
(g) audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise;
(h) professional or employment-related information, for example information you may provide about your business; and
(i) inference data, such as information about your preferences.
14.11 The categories of information that we collect and disclose for a business purpose include “sensitive personal information” as defined under the CCPA. We do not use or disclose sensitive personal information for any purpose not expressly permitted by the CCPA.
Last Updated: 30 August 2024