PRIVACY POLICY

The current privacy policy depicts your privacy rights in terms of gathering, using, storing, sharing, and protecting your personal data. You agree to this privacy policy by registering, accessing, or using DNBC Financial Hong Kong Limited’s products, services, solutions, features, and technologies. If you do not agree, you should stop accessing this site or DNBC Financial Hong Kong Limited Services immediately and refrain from further access and use of them.

Herein the following definitions will apply:

“You”, “Your”, “Yours” refers to any user of the DNBC Financial Hong Kong Limited Site, DNBC Financial Hong Kong Limited Account, or DNBC Financial Hong Kong Limited Services.

“We”, “Our” and “Us” refers to DNBC Financial Hong Kong Limited.

“DNBC” means the business name of DNBC Financial Hong Kong Limited, a legal entity registered in Hong Kong with MSO License number 22-10-03118 issued by the Hong Kong Customs and Excise Department. DNBC’s place of business is at Flat A&B, 18/F Wing Hing Commercial Building No. 139 Wing Lok Street, Sheung Wan, Hong Kong. Any references to DNBC shall refer to DNBC Financial Hong Kong Limited.

“The Site” refers to the DNBC Site (https://www.dnbcgroup.com/en-hk or www.dnbcnet.com ), including all its content.

“DNBC Account” means a personal or business account of Clients opened with DNBC.

“DNBC Services” means access to a DNBC Account allowing you to open an individual or business account and make payments inside DNBC or payouts from it, pay bills, exchange currency, and obtain any other services provided by DNBC.

DNBCnet means internet-based software app, API, and other software and technologies allowing obtaining DNBC Services.

“Data Processing” means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

ROLES AND RESPONSIBILITIES

You should be aware that by providing you with DNBC Services we act as a data controller and you may act as a data subject or as a joint data controller as a case may be. The terms “personal data”, “data subject”, “data controller” and “data processor” are used in the meaning given by Hong Kong’s Personal Data Protection Ordinance (PDPO).

By opening the DNBC account for you, we collect your personal data, so in this case, we act as data controller, and you act as a data subject, therefore we are subject to respective rights and obligations under applicable data protection laws.

In some cases, when you are a business, you transfer to us the personal data of your clients or the personal data of your officers. Insofar as you and we jointly determine to process personal data for the purposes of our cooperation we and you are joint data controllers and bear several liabilities for data protection infringements. You shall warrant that you have appropriate legal grounds to collect, process, and transfer to third parties the personal data of your clients or officers. In more detail, your and our obligations and responsibilities will be allocated in the data protection agreement with you.

PRINCIPLES OF PERSONAL

We processed your personal data in accordance with valid legal acts and the following principles:

DATA PROCESSING

• personal data with respect to you is processed in a lawful, honest and transparent way;
• personal data is collected for specified, clearly defined and legitimate purposes and shall not be further processed in a way incompatible with those purposes;
• personal data must be adequate, appropriate and only which is necessary for the purposes for which it is processed;
• personal data must be accurate and, if necessary, updated; all reasonable steps must be taken to ensure that personal data which is not accurate in relation to the purposes for which it is processed shall be immediately erased or corrected;
• personal data shall be kept in such a way that your identity can be determined for no longer than is necessary for the purposes for which personal data is processed;
• personal data shall be managed by applying appropriate technical or organizational measures in such a way as to ensure the proper security of personal data, including protection from unauthorized processing or processing of unauthorized data, and against accidental loss, destruction or damage.

WHAT DATA WE COLLECT

In case you access your DNBC Account, use DNBC Site, or use any of the DNBC Services, the following type of personal data might be gathered:

• Personal information, used for opening a DNBC account, managing and administering DNBC Services:
  • First and last name
  • Date, country and place of birth
  • Nationality
  • Gender
  • Names, roles, and contact details of your officers, power of attorney, in case you are opening the business account.
• Contact details, used to maintain permanent communication with you, to send you legal and information notices:
  • First and last name
  • Residential address
  • Telephone number
  • Email address
• Information used for carrying out the Know Your Client (KYC) procedure and anti-money laundering (AML) checks:
  • Personal code
  • Date of birth
  • Age (year of birth)
  • Passport or other government-issued identity document
  • Your photograph
  • Documents establishing your source of funds
  • Results of KYC checks, including information collected by our service providers
  • Video identification data

When you are an entity, we collect personal code, identity card, surname, address, nationality, name, photograph, signature, number of shares held, voting rights or share capital part, data about the beneficiary of funds of the ultimate beneficial owners (natural persons who directly or indirectly own or control an entity).

• Information generated or collected in the course of providing DNBC Services, which DNBC uses to develop and improve its services.
  • Signature
  • Correspondence with DNBC and support data (telephone, chat conversations and email)
  • Your transaction data
  • DNBC site activities
• Financial information including your full bank account number and/or credit card number, IBAN number (used for payments to you and full use of DNBC Service);
• Device data (such as a type of device, operating system, IP-addresses and advertising ID’s, your location, web and mobile network data), сookies and usage data on how you use our products and services. It is used for accepting you as a customer of DNBC Account, to safeguard you from scam, fraud, and misuse of any private data you might share, to improve our services. For more details about cookies please see our Cookie Policy below.

Also, pay attention to the fact we may acquire information related to you provided by third parties like services for person verification, marketing agencies, your publicly available profile information (LinkedIn, Facebook, Twitter, Google Accounts), information related to payments to or from your accounts with us, provided by payment processing services, banks, card schemes, and other financial services firms, information from fraud prevention agencies.

We do not collect any extra data but only that information that is necessary for the purpose of providing DNBC Services to you.

Please be aware that the list of information types mentioned above is not exhaustive. Additional information about you might be gathered in some other way, for instance by contacting our Customer Support hotline or taking part in surveys, etc.

SENSITIVE PERSONAL DATA

When required by AML legislation we may collect biometric information (such as facial photographs or fingerprints) of their clients for identification purposes. Such information is defined by Hong Kong’s Personal Data Protection Ordinance (PDPO) as sensitive information and can be processed only if the law requires this or the data subject has given express consent. Clients who refuse to provide such information cannot obtain DNBC Services in full. Clients may contact DNBC support to obtain information on what services may be used without providing biometrics.

We do not intentionally collect any other sensitive personal data, such as religious beliefs, health information, racial or ethnic origin, etc. Nevertheless, there might be cases when information or documents that the data subject submits to us contain sensitive information or we can obtain it in the course of providing our services (e.g. during KYC procedure or information that follows from payment transactions of certain types). To allow us to process your sensitive personal data you will be requested to provide explicit consent by means of DNBC Account functionality or by e-mail. In some cases, we may be required to process such data for reasons of substantial public interest, on the basis of Hong Kong or local law.

HOW WE USE YOUR DATA

The main goal of gathering and processing your personal data is to deliver an effective, scalable, smooth, and personalized DNBC experience. Hence, personal data we collect might be used to:

• Ensure maximum DNBC Account user experience;
• Process transactions and issue relevant notifications in the most comprehensive manner;
• Settle disputes, levy charges, and resolve occurring problems;
• Prevent clients from becoming a subject to illegal activities and potential fraud;
• Improve quality of services, solutions, and incentives DNBC offers on a daily basis;
• Being able to contact you in case of emergency via one of the means available;
• Make sure the information you provide is accurate, in case discrepancies occur;
• send personalized offers of services and products, in accordance with the rules as they are described in part “Legitimate interest” of the section “Legal basis for processing” of this Privacy Policy;
• carry out regulatory checks and meet our obligations to our regulators;
• prevent and detect fraud, money laundering and other crime (such as terrorist financing and offenses involving identity theft);
• develop new services based on the collected information.

Your personal data is not used for any additional purposes not mentioned in this Privacy Policy or the contract with DNBC.

AUTOMATED DECISION-MAKING

In some cases, we may make automated decisions regarding you using your information. When you instruct us to make a payment from your account or to request payment into your account from a bank or other payment services provider, our systems (or systems provided to us by our suppliers) make an automated check for authorization and automated checks to detect an unusual transaction pattern or location of your transaction and help us to fight fraud. You are entitled to contest automated decision-making by contacting us.

HOW WE PROTECT YOUR DATA

We warrant and represent that DNBC has implemented the technical and organizational security measures and technological development to ensure an appropriate level of security of personal data. Your data is protected by the means of physical, technical, and administrative resources to lower the risks of loss, misusage, unauthorized entry, disclosure, or alteration by a third party. To keep your data safe we apply:

• Firewall and data encryption protection
• Physical authorization control system
• Surveillance facilities, video/CCTV monitor, and alarm system
• Securing decentralized data processing equipment and personal computers
• User identification and authentication procedures
• Tunneling, logging, transport security
• Audit trails and documentation
• Backup procedures,

And many more things.

As DNBC is PCI DSS V3.2.1 certified, we maintain all required technology, methods, and business processes to protect cardholder data, and also use such technology and methods as regards the security of your personal data.

We monitor our systems 24×7 and our staff is always ready to respond to your notifications and queries within a short time.

DNBC respects your privacy and your personal data and warrants that:

• Your data will not be disclosed to advertisers or any unauthorized third parties except as provided by this Privacy Policy;
• We keep your data and any information provided by you in confidence in accordance with the terms and conditions set in a separate agreement with DNBC;
• We will use your data only as described in this Privacy Policy;
• We will maintain appropriate administrative, technical and organizational measures to protect your personal data;
• We will notify you promptly of any suspected or actual breach of the security of your data;
• We will assist you in ensuring compliance with your duties under Hong Kong’s Personal Data Protection Ordinance (PDPO)
• We impose on our sub-contractors the same data protection obligations as set out in the contract with you.

We will notify you of any personal data breaches (including any unauthorized or accidental access) without undue delay after becoming aware of a personal data breach.

We will notify you of personal data breaches where the breach is likely to create significant risks to your rights and freedoms (including any unauthorized or accidental access) without undue delay after becoming aware of personal data breach.

We are not obliged to give the notification to you if at least of the following conditions is fulfilled:

• We have ensured and implemented the appropriate technical and organizational security measures, for example, encryption of personal data or other measures rendering the personal data unintelligible to any person who is not authorized to access it and such measures were applied to the personal data affected by the personal data breach;
• We keep your data and any information provided by you in confidence in accordance with the terms and conditions set in a separate agreement with DNBC;
• We have taken subsequent measures which ensure that the high risk to the rights and freedoms of the data subject(s) is no longer likely to materialize;
• Giving the notification to you would involve disproportionate effort. In such a case, public communication or other chosen measures whereby you were informed in an equally effective manner may be applied by us instead of giving a notification to you.

We immediately inform you if, in our opinion, you infringe PDPO protection provisions. You shall ensure the security of the data you transfer to DNBC. You assume full liability for failures to meet the PDPO in cases when it is envisaged by this Privacy Policy or PDPO.

HOW WE SHARE YOUR DATA

DNBC warrants that it will not disclose your personal data to any unauthorized third party.

DNBC may share your data with DNBC’s contractors who may use such information only for the limited purpose of providing services to you and who are obligated to keep the information confidential, including without limitation:

• Card schemes, banks and payment service providers – to make you able to obtain acquiring services, money transfers and other payment services;
• Suppliers related to financial services or operations (e.g. KYC and sanctions screening, credit checking, card supply) – to provide you high-quality service, fight fraud and comply with requirements of law.
• Suppliers of analytic services – to monitor, evaluate, and improve DNBC Account.
• Information generated or collected in the course of providing DNBC Services, which DNBC uses to develop and improve its services.
• It services suppliers (e.g. disaster recovery services, website hosting, data and applications hosting, software application provision, and maintenance) – to ensure uninterrupted operation of the DNBC Account.
• Communications services suppliers – to communicate with you and provide you with up-to-date information on the usage of the DNBC Account, e.g. by SMS or e-mails.
• Customer support services – to operate our payment services platform and provide administration and customer support.

To ensure the payment process runs smoothly, some of your personal information may be shared with a company or entity you cooperate with inside DNBC. Your registration date, number of payments you have issued/received via DNBC, info whether you have authorized control over a bank account – all that information might be shown to DNBC users you work with at the moment.

We may also transfer your personal data to our professional advisers (such as lawyers, accountants, auditors, consultants, and management consultants), who are under a professional obligation to maintain the confidentiality and security of personal data.

Your personal information may be shared with third parties if so required by applicable laws, regulations, and instructions we must obey or in response to valid court orders or requirements of other government bodies.

In addition, we may convert your personal information into anonymous or aggregated form, in which case it will cease to be personal data.

CROSS-BORDER TRANSFER

For the purpose of providing you with DNBC Services we can engage third-party service providers outside Hong Kong. In such cases, personal data may be transferred outside Hong Kong. Data protection laws of third countries may be different from Hong Kong data protection laws and not guarantee adequate levels of security. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that personal data remains protected.

We use Hong Kong commission-approved standard contractual clauses as a legal mechanism for data transfers from Hong Kong. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. DNBC does not participate in privacy shields at this time. Nevertheless, we rely on the Hong Kong privacy shield to transfer personal information to some of our third-party service providers, who are certified to receive such information under the privacy shield program.

When you act as a joint data controller, you shall inform your clients about the risks of cross-border transfers and obtain their consent for that.

COOKIE POLICY

When you visit DNBC’s Site or DNBC Account, a small Cookie file might be placed on your computer or mobile device. We will analyze data from the Cookies and use it to improve the quality of our services, track your activities with DNBC, and keep your account safe. Any personal information that we collect and store through the use of cookies is first obtained through notice and consent. We obtain your consent by providing you with transparent notice of the use of the cookies and, to the extent described herein, providing you with the opportunity to make a choice to disable these cookies, except the session cookies. We offer certain site features, services, applications, and tools that are available only through the use of cookies. You are always free to block, delete, or disable cookies in your browser, installed application, or device so permits. However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features, services, applications, or tools.

What is the cookie?

A cookie is a small text file stored in a computer’s web browser memory.

There are three main types of cookies:

Session cookies – they help you not have to re-enter information and stay logged in each time you change web–pages. Session cookies are deleted automatically after you leave the site or when you close your browser.

Persistent cookies – they help us to recognize you each time you return to the DNBC Site and remember your preferences for viewing the site. Such cookies are stored on your computer until deleted by you or automatically after its expiration.

Third-party cookies – are the persistent cookies placed not by DNBC which help to gather browsing activity across numerous websites and during several sessions. Such cookies are stored on your computer until deleted by you or automatically after its expiration.

You can find out more at https://www.aboutcookies.org/

How do we use cookies?

We use cookies for the following purposes:

Authentication: When you log into DNBC Site or DNBC Account, we use cookies to remember you so you don’t have to log in each time you leave the main page and navigate throughout the DNBC Site.

Fraud prevention: With the help of cookies, we can obtain information about the security of your computer and web browser used to access DNBC sites or DNBC Accounts and to detect harmful or illegal use of DNBC Services.

Settings: We can use cookies to remember your settings of the DNBC Services so you do not have to change them each time you log into DNBC Site or DNBC Account. For example, you can choose to remember payment details and associate them with your computer to make recurring payments or use the language or font you prefer.

Improving DNBC Services: We use cookies to understand how we can make DNBC sites and services better. Cookies help us to know how people reach DNBC sites, detect and gather reporting on bugs; and improve the functionality and speed of DNBC sites and the DNBC Account portal.

Marketing: From time to time we can use cookies to show you more relevant ads, e.g. to not show the same ads multiple times or recognize actions across multiple devices or browsers, etc. We reserve the right to use Google Analytics to understand how DNBC sites or DNBC Account is used by its users. 

What other technologies can we use?

There are other technologies used by us to track your activity on the site or the DNBC Account portal.

Web beacons (web pixels) are small graphics that help to understand browsing activity, track conversion, and optimize ads. These graphics files are downloaded when you visit the site or the DNBC Account portal.

Local storage objects (flash cookies) are files that can be stored on your browser and can be used to detect preferences, record the history of usage, or remember the settings of the site or DNBC Account. You can block or control flash cookies at any time by modifying the settings of your browser.

Google Analytics is third-party technology, that allows collecting and analyzing information about how you use the DNBC Services and websites and creating relevant reports. Upon you have accepted the use of cookies on our Site, we may use Google Analytics. Nevertheless, you can at any time opt-out through Google ads settings. Google also provides a Google Analytics opt-out plug-in for the web.

Type of data	Retention period
The data of our registers	At least 05 (five) years from the day of termination of transactions or other business relationship with you
Documents confirming monetary operation or transaction or other documents having legal force related to the performance of the monetary operations or conclusion of the transactions	For a period of 05 (five) years from the day of the performance of the monetary operation or conclusion of the transaction
Copies of the documents proving your identity, invoices and/or contractual documentation (original documents)	For a period of 05 (five) years from the day of termination of the transactions or business relationship with you
Written or electronic correspondence relating to the business relationship with you	For a period of 05 (five) years from the day of the termination of the transactions or business relationship with you
Results of investigations of complex or unusually large transactions and unusual transaction structures	For a period of 05 (five) years in paper format or on an electronic medium

How can you change the cookie setting?

You can delete and disable cookies using the settings of your browser. You can find out more about how to manage cookies from the following links:

For the Chrome browser:

https://support.google.com/chrome/answer/95647?hl=en

For Explorer browser:

https://support.microsoft.com/en-us/products/windows?os=windows-10

For Safari browser:

https://support.apple.com/kb/ph21411

For Firefox browser:

https://support.mozilla.org/products/firefox/cookies

For Opera browser:

http://www.opera.com/help/tutorials/security/cookies/

Also you can use third-party tools, like browser plug-ins or applications allowing you to monitor, block or limit third-party cookies, web pixels and some javascript-based technologies.

HOW LONG WE RETAIN YOUR DATA

We may use your data for as long as reasonably necessary for the limited purpose of providing DNBC Services to you.

DNBC as a regulated Payment Institution is obliged under local authority regulation and AML laws to keep your data so long as mentioned below:

The storage period may be extended additionally upon a reasoned instruction of a competent institution, nevertheless, the extension cannot last longer than 2 (two) years. Moreover, we follow the requirements of legal acts of Hong Kong while keeping other personal data.

After the termination of the agreement between DNBC and you, you may request deletion of your data. We are able to consider your request and delete your data within 90 (ninety) days. Nevertheless, we may retain some of your personal information for the purpose of complying with technical and legal requirements related to the security, integrity, and operation of DNBC Services. For instance, if a DNBC Account has been terminated because of fraud or security reasons, we may retain certain information from that account to prevent opening a new DNBC Account by the same user.

Please be aware that applicable law may prevent us from returning or destroying all or part of the personal data or require storage of the personal data for some period to comply with AML requirements, tax reporting, or auditing. In this case, we will protect the confidentiality of the personal data and will not actively process the personal data anymore after the termination of the legal relations with you.

Your personal data is processed for the purposes of sending personalized offers of services and products or to find out your opinion on different issues in relation to us and our services (direct marketing) are used so long as we have a contract with you or until you unsubscribe from receiving such messages using the link in the bottom of the e-mail or by using the functionality of DNBC Account.

YOUR RIGHTS AS A DATA SUBJECT

When we act as data controllers, you have the following rights for personal data that we have about you.

• You have the right to know about the processing of your personal data as well as to have access to your personal data and processing;
• You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you). We have to properly authenticate you before we fulfill your request. Some of your information may be used further in order to track any unpaid fees, and unresolved disputes, and prevent scams. We keep your data during the term of the contract with DNBC and delete it if it is no longer needed or if the law does not require otherwise. Notwithstanding the above, we may be obliged to store your data longer for the purpose of compliance with applicable law.
• You can also ask us to change, update, or fix your data in certain cases, particularly if it is inaccurate. You may do it by yourself, simply log in to your DNBC account and change profile settings at once. You can also close your account using the DNBC Account functionality. 
• You can ask us to stop using all or some of your personal data (e.g., if you believe that we have no legal right to keep using it) or to limit our use of it (e.g. if you believe that your personal data is inaccurate or unlawfully held). You have the right to temporarily mark your profile as restricted by using the relevant option in your DNBC account. That means it should no longer be visible to the back office staff and its processing will be suspended.
• You can obtain a copy of the personal data we retain about you unless this adversely affects the rights and freedoms of others. You have the right to ask us to provide your information in an easily readable format to another company.
• Where we are processing your personal information based on the legitimate interest you may object to this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object to the usage of personal information for direct marketing purposes or automated decision-making.
• You have the right to appeal to the Data Protection Authority of Hong Kong or the court, in case you do not agree with our answer to your request or claim other rights established in Hong Kong’s Personal Data Protection Ordinance (PDPO)

You may contact us using the contact information below to make the request or ask us about your rights.

HOW WE DEAL WITH YOUR REQUESTS

If you reasonably believe that the processing of personal data related to you is performed in violation of the applicable legal requirements you have the right to submit a complaint to us. You can submit a complaint by post or e-mail, specifying your name, surname, contact details, and relevant information, which would indicate why you reasonably believe that the processing of the data related to you is performed in violation of the applicable legal requirements. Upon receipt of a complaint from you, we confirm receipt of the complaint and indicate the time limit within which the reply will be submitted. In each case, the deadline for submitting a reply may vary as it directly depends on the extent and complexity of the complaint filed, but we will make the maximum effort to provide the response to you within the shortest possible time. We, after examining the complaint, report the results and actions taken to satisfy your complaint or provide relevant information on what further actions you may take if your complaint is not satisfied.

LEGAL BASIS FOR PROCESSING

Our legal basis for collecting and using personal data depends on the type of personal information collected and the specific context in which we collect it.

• Contract

We can process your personal data to fulfill our contractual obligations. We rely on contracts as a legal basis to process personal data submitted by you. Processing of your personal data is necessary to provide you with DNBC Services. We cannot provide you with payment services without carrying out a KYC procedure or business risk assessment.

You acknowledge and agree that your personal data may be transferred to countries situated outside Hong Kong when it is necessary for the conclusion or performance of a contract concluded in your interest between us and another legal person.

• Legitimate interest

We may process your personal data on the basis of our legitimate interests provided that such processing shall not outweigh your rights and freedoms. We rely on this legal basis when we carry out procedures that are part of our services or that are transparent, expectable, and a stable business practice. For example, to:

• Safeguard the prevention, investigation, and detection of payment fraud;
• Comply with applicable laws, industry standards, or requests from regulatory bodies;
• Provide you with high-quality customer service;
• Manage corporate transactions, such as mergers or acquisitions;
• Provide you with technical and administrative notifications;
• Lawfully disclose personal data to a third party, provided we take all technical and legal measures to protect personal data;
• Send you information or promotion on products and services that we offer that are similar to and related to DNBC Services (direct marketing). These communications may be via email or in-app messages, which can be viewed in the notification center of the DNBC Account. If you do not want to receive a direct marketing message from us, you can opt-out (i) the first time you give us your contacts by ticking the respective checkbox, or (ii) at any time by changing the notification setting in your DNBC Account, or (iii) by clicking on the respective link in each e-mail, or message you received, or (iv) by contacting us;
• Comply with KYC standards and anti-money laundering rules;
• Process payment transaction by your request.

Please note that in most cases, if you do not provide the requested information, DNBC will not be able to provide the requested service to you, e.g. our support cannot reach you in case of an emergency without collecting your email address or phone number.

If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

• Consent

We can request your consent for processing when we are required to do so by law or when we do not have another legal basis for the processing of your data. Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time.

We do not rely on consent in common cases, because the right to withdraw consent can be used for fraudulent activity. This would jeopardize the financial stability of DNBC, the reliability, and integrity of DNBC Services, thereby harming all legitimate parties in the payment process.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

PASSWORD POLICY

You shall maintain the confidentiality of your password and log in from the DNBC account. You are recommended to sign out of the DNBC account when you have finished work with it. In any case responsibility for any loss of passwords and misuse of DNBC accounts by third parties lay with you.

MINORS

DNBC does not voluntarily collect, use, or disclose the personal data of minors, according to the minimum age equivalent in the relevant jurisdiction. DNBC Services are not designed to attract minors. If you are a minor, you may not submit any personal information to us or subscribe to the DNBC Services. If we become aware that we collected the personal information of a minor, we will take steps to delete the information as soon as possible.

HOW MAY THIS PRIVACY POLICY BE CHANGED

We can make amendments to this privacy policy at any time by the means of publishing a revised edition on the site. You will be notified of any substantial changes. The revised version will be in effect immediately and be noted by the updated date to the end of this privacy policy. You are entitled to terminate the agreement with DNBC if you do not agree to any changes. By continuing to use DNBC Services, you accept the changes.

DATA BREACHES

We ensure that we have all the necessary technologies and methods to prevent, detect, and investigate a personal data breach. In case of any data breach, we will endeavor our best efforts to notify you and any applicable regulator of becoming aware of the breach as soon as possible.

Please feel free to contact our data protection officer to:

• Request access to information that DNBC has about you
• Correct any information that DNBC has about you
• Delete information that DNBC has about you
• Ask any other questions or concerns.

OUR CONTACTS

Tel: +852 3464 0419

[email protected]

https://www.dnbcgroup.com/contact-us/

Privacy policy last modified on 24 March 2023