TNG (Asia) Limited Privacy Policy Statement

TNG (Asia) Limited and its affiliates (hereinafter referred to as “TNG”, “we”, “us” or “our”) undertake to fully meet the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of the Hong Kong. In doing so, we will ensure our staff comply to the strictest standards of security and confidentiality in respect of all personal information and data submitted by you via our products, services and website.

To protect your privacy, we are committed to safeguard your personal information (or “personal data”) to maintain customer trust.

When we collect personal data from individuals, we will provide them with a Data Collection Statement ("DCS") on or before the collection in an appropriate format and manner (e.g. in the same paper form or web page that collects the personal data for reference).

This Privacy Policy Statement (the “Policy”) describes how TNG collect, use and share information about you and the choices that you can make about the way your information is collected, used, shared and transferred.

Services covered by this Privacy Policy

This Policy applies to the provisions of all services available from TNG. We strongly recommend you to read this Policy before using any service related to our services. By using our services, you are agreeing in advance to the current and future terms of this Policy. This Policy is applicable to both registered and non-registered users, and the provisions herein may be updated, revised, varied and/or amended from time to time as TNG deems necessary.

Information we collected

Personal Data

Personal data is information and/or data that identifies you as an individual, such as your name, date of birth, age, gender, nationality, mailing or home address, email address, mobile number, photo, employment information, income level, pre-paid card, credit card, bank account, etc. We occasionally collect additional personal information from you to facilitate a transaction and to comply with all applicable anti-money laundering and counter-terrorist financing laws, regulations and our internal policies.

You are not obliged to provide the information requested, however, we may not be able to render certain services in the event that you fail to do so.

Device and Connection Information

We automatically collect device information when you install, access and use our services. This includes your mobile carrier, mobile device model, operation system, browser type and version and IP address.

Transaction Pattern

We collect your transaction pattern and behaviour, financial background and demographic data, products and other service portfolio information.

Usage and Log Information

We collect service-related, diagnostic, and performance information. This includes information about your activity, log files, diagnostic, crash, website, and performance logs and reports.

Cookies

We use cookies to operate and provide our services, to remember your choices, such as your language preferences, and to customize our services for you. Cookies are small data files which are placed on your device when you visit certain parts of our website or click on our online advertisements. Cookies and similar technologies are used to identify your device for the following purposes:

1. Strictly necessary cookies. These essential cookies are set throughout our website and are required for the operation of our website to:
   • allow our web server to determine whether the cookies setting on your web browser has been enabled or disabled. This allows us to know whether data can be collected from your web browser;
   • temporarily allow you to carry information between pages of our website to avoid having to re-enter that information;
   • temporarily identify your device after you have logged in to a secure page on our website so that our web server can maintain a dialogue with your web browser in order for you to carry out certain activities.
2. Analytical/performance cookies. These are used to help us improve our website by:
   • tracking your visits to our website and recognising your web browser when you are a repeat visitor so that we can gather statistics on new and repeat visitors to evaluate site effectiveness.
3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to:
   • personalise our content for you and remember your preferences (for example, your choice of language and region);
   • store your login and other preferences so you do not have to re-enter that information when you return to the website.
4. Targeting / advertising cookies. These cookies record your visit to our website, your response to our online advertisements, track the pages you have visited and the website links you have followed. We use this information to:
   • make our website more relevant to your interests;
   • provide online advertisements or offers on our website or third-party websites which are most likely to interest you;
   • evaluate the effectiveness of our online marketing and advertising programs.

The above cookies may be placed on your device by us or by third parties on our behalf (for example, advertising networks and providers of external services like web traffic analysis services). No personally identifiable information about you is collected or shared with third parties as a result of this research.

Status Information

We collect information about your online and status message changes on our services, such as whether you are online (your “online status”), when you last used our services (your “last seen status”), and when you last updated your status message.

How we use

Our primary purpose in collecting personal information is to provide you with a safe and efficient experience and to provide you with services and features that better meet your needs or requests.

We collect your information for the following purposes:

• To verify your identity;
• To process your application for any service;
• To communicate with you;
• To facilitate the daily operation of the services provided to you;
• To conduct customer due diligence as required by law and regulations;
• To provide you with marketing and promotional materials for your enjoyment of benefits;
• To compile and analyse aggregate statistics about the users’ use of our website and service for our internal use;
• To handle and investigate complaints;
• To facilitate TNG’s use of your personal data for purposes relating to the provision of services offered by TNG and/or our merchants, and marketing services, special events and/or promotions of TNG and/or our merchants;
• To meet our obligations, requirements or arrangements in connection with any law, regulation, judgement, court order, sanctions regime, within or outside Hong Kong, existing currently and in the future, and to comply with any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies or associations of financial services provided within or outside Hong Kong (the “Authorities”); and
• To assist in prevention, detection and investigation of crime and suspicious transactions

How we collect information

We collect data when you provide information to us or through the use of web technology.

Disclosure or Transfer of Data

We agree to take all practicable steps to keep all your personal data confidential and/or undisclosed, subject to the provisions in this section. Generally speaking, we will only disclose and/or transfer your personal information to our personnel and staff for the purpose of providing services to you. However, we may disclose and/or transfer such information to third parties under the following circumstances:

• Where the information is disclosed and/or transferred to any third party who have been duly authorized by us to use such information under a duty of confidentiality;
• Where the information is disclosed and/or transferred to any TNG agents, affiliates or associates who have been duly authorized by us to use such information;
• Where TNG needs to protect and defend our rights and property;
• Where TNG considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on TNG and/or our merchants;
• Where TNG deems necessary to do so in order to maintain and improve the services; and
• Personal data collected may be transferred, stored and processed in any country in which TNG operate. You are deemed to have agreed to, consented to and authorized us to disclose and/or transfer your personal information under the circumstances stated above.

For the purposes set out above, we may provide your personal information to the following parties or any of them:

• any agents, contractors, sub-contractors or associates of the TNG (including their employees, officers, agents, contractors, service providers and professional advisers);
• any third party service providers who provide services to us or any affiliate of our parent company, TNG FinTech Group Inc., in connection with the operation or maintenance of our business (including their employees and officers);
• any Authorities;
• any persons under a duty of confidentiality to us or any affiliate of TNG FinTech Group Inc. which have undertaken to keep such data confidential;
• any credit reference agencies;
• any affiliate of TNG FinTech Group Inc.;
• third party financial institutions, insurers, credit card companies, securities and investment services providers;
• third party reward, loyalty, co-branding and privileges programme providers;
• co-branding partners of ours or any affiliate of TNG FinTech Group Inc. (the names of such co-branding partners will be provided during the application process for the relevant products and services, as the case may be); and
• charitable or non-profit making organisations.

Access and correct your information

You may access your personal information that we have collected and correct factual errors in your personal information by sending us a request that credibly shows error. You also have the rights to ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us.

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections. We reserve the right to charge you a reasonable fee for complying with any request for access to your data.

Security

We will always strive to ensure that your personal data will be protected against unauthorized access and have implemented appropriate electronic and managerial measures in order to safeguard, protect and secure your personal information.

All personal information provided by you are only accessible by the authorized personnel of TNG or our authorized third parties, and such personnel shall be instructed to observe the terms of this Policy when accessing such data. You may rest assured that your personal information will only be kept for as long as is necessary to fulfill the purpose for which it is collected.

You should safeguard your username and password and keep them secret and confidential. Never write them down. We will never ask you for your password given that you should be the only person who knows it.

When choosing your username and password, do not use easily identifiable information such as your birthday, telephone number or a recognisable part of your name.

If you think your username or password has been disclosed to another person, is lost or stolen or an unauthorised transaction has been conducted, you are responsible for informing us immediately.

We may use third party payment gateway service providers to facilitate electronic transactions. Regarding sensitive information provided by you, such as pre-paid card or credit card number for completing any electronic transactions, the web browser and third-party payment gateway communicate such information using secure socket layer technology (SSL).

No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information against unauthorized access, we cannot guarantee its absolute security.

Retention of Personal Data

Once we obtained your personal data, it will be maintained securely in our system. The personal information and other data will be retained by us after deactivation of the relevant service within a certain period subject to the law requirement.

Contact us

All requests regarding access to or correction of your personal information should be made in writing to:

The Data Protection Officer
TNG (Asia) Limited
c/o 21/F, Olympia Plaza
255 King’s Road
North Point
Hong Kong

If you have questions regarding this Policy, please contact our Customer Service at +852 3951-6268 or email us at data_privacy@tng.asia.

Changes in this Policy

We reserve the right to update, revise, modify or amend this Policy in the following manner at any time as we deem necessary and you are strongly recommended to review this Policy frequently. Any update, revise, modify or amend this policy, we will post latest version to our website: https://www.tngwallet.hk/en/privacy and/or other places we deem appropriate.

Updated on 1 August 2019 in Hong Kong.