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Privacy Policy
1. Our Commitment to Your Privacy
Our registered address is FLAT/RM 519, 5/F, EAST OCEAN CENTRE, 98 GRANVILLE ROAD, TSIM SHA TSUI, KL, Hong Kong. We are the data controller for the information we process, unless otherwise stated.
This Policy is designed to be compliant with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong ("PDPO"). By accessing or using our Services, you signify your understanding of and agreement with the terms of this Privacy Policy. If you do not agree with any part of this Policy, please do not use our Services.
2. Scope of This Policy
● Website Visitors: Individuals who browse our website.
● MSO Service Users: Individuals or entities who register for and use our remittance and payment services.
● Business Partners and Vendors: Individuals and entities who work with us to provide or support our Services.
3. The Information We Collect
3.1. Information You Provide to Us Directly (The information we collect may be updated to comply with legal and regulatory requirements)
● Account Registration Information: When you create an account for any of our Services, we may collect your name, email address, phone number, company name (if applicable), and a password.
● Communication Information: When you contact us via email at [email protected], through our website forms, or by other means, we collect the content of your communications and any information you choose to provide.
● Information for MSO Service Users (Required for Legal Compliance):
Due to the regulated nature of our MSO Services and our obligations under Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) laws, we are required to collect and verify detailed personal and financial information. This includes, but is not limited to:
● Identity Information: Your full legal name, date of birth, gender, and nationality.
● Contact Information: Your residential address and proof of address (e.g., utility bill, bank statement).
● Identification Documents: A copy of your government-issued identification, such as a Hong Kong Identity Card (HKID), passport, or national ID card.
● Financial Information: Information about your source of funds, bank account details (account number, bank name), and reason for the transaction.
● Transaction Details: Information about the remittance, including the amount, currency, and purpose of the transfer.
● Recipient Information: The full name, address, and bank account details of the person or entity receiving the funds.
● For Corporate Users: We may also collect business registration certificates, articles of incorporation, register of directors, register of shareholders, and information to identify the Ultimate Beneficial Owners (UBOs).
3.2. Information We Collect Automatically
When you use our website or online platform, we automatically collect certain technical and usage information:
● Log and Usage Data: We collect information about your interactions with our Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
● Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, and unique device identifiers.
● Cookies and Similar Tracking Technologies: We use cookies, web beacons, and similar technologies to operate and improve our website, understand user behavior, and for purposes. For more details, please see Section 11 on "Cookies and Tracking Technologies."
3.3. Information We Collect from Third Parties
● Identity Verification Services: For our MSO Services, we may use third-party services to verify your identity and to conduct sanctions and politically exposed person (PEP) screening to comply with our legal obligations. These services may provide us with confirmation of your identity based on the information you provided.
● Financial Institutions: We may receive information from our banking partners or payment processors related to your transactions.
4. How We Use Your Information
● To Provide, Maintain, and Improve our Services:
● To operate our platform, create and manage user accounts, and process transactions.
● To develop new features and improve the functionality and user experience of our Services.
● For MSO Services:
● To verify your identity and perform due diligence as required by AML/CFT regulations.
● To process your remittance and payment transactions accurately and securely.
● To monitor transactions for fraud, sanctions violations, and other illicit activities.
● To manage risk and ensure the security of our platform and our users.
● For Communication:
● To send you transactional communications, including account confirmations, transaction receipts, security notices, and support messages.
● To respond to your comments, questions, and requests for customer service.
● To send you marketing communications about our products and services, subject to your opt-out rights.
● For Legal, Safety, and Security Purposes:
● To comply with our legal and regulatory obligations, including reporting to authorities as required.
● To enforce our Terms of Service and other policies.
● To protect the rights, property, and safety of our company, our users, and the public.
5. Our Legal Basis for Processing Information
● Performance of a Contract: We process your data when it is necessary to fulfill our contractual obligations to you (e.g., processing a remittance transaction or managing an ad campaign as per our agreement).
● Legal Obligation: We process your data to comply with our binding legal and regulatory obligations, most notably the AML/CFT requirements for our MSO Services.
● Legitimate Interests: We process your data for our legitimate business interests, such as improving our Services, preventing fraud, and for direct marketing, provided that these interests are not overridden by your rights and interests.
● Consent: Where required by law, we will obtain your consent to process your information, for example, for using non-essential cookies or sending certain marketing emails. You can withdraw your consent at any time.
6. How We Share and Disclose Information
● With Service Providers and Vendors: We share information with third-party vendors, consultants, and other service providers who need access to such information to carry out work on our behalf. This includes hosting providers, analytics companies, IT support, and marketing automation platforms.
● With Financial Partners (for MSO Services): To process your transactions, we must share information with correspondent banks, payment network operators, and other financial institutions involved in the payment chain.
● With Regulatory and Law Enforcement Authorities: We are required to share information with the Hong Kong Customs and Excise Department, law enforcement agencies, courts, and other government authorities when compelled by law, subpoena, or other legal process.
● For Services: We may share campaign performance data and reports with you, our client. We will not share your confidential business information or Client Materials with other clients.
● In Connection with a Business Transfer: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
● With Your Consent: We may share your information with other third parties when we have your explicit consent to do so.
7. International Data Transfers
When we transfer your data internationally, we take steps to ensure it is protected in a manner that is consistent with Hong Kong's data protection laws. We will only transfer data to jurisdictions that have adequate data protection laws or where the recipient is bound by legally enforceable obligations (e.g., through contractual clauses) to provide a standard of protection that is comparable to that under the PDPO.
8. Data Security
● Encryption: Using Secure Socket Layer (SSL) and transport layer security (TLS) to encrypt data in transit.
● Access Controls: Limiting access to personal data to authorized employees and contractors who have a legitimate business need to know.
However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
9. Data Retention
For our MSO Services, we are legally required under the AML/CFT Ordinance to retain all records, including identity verification data and transaction details, for a period of at least six (6) years after the end of our business relationship with you or after the date of a particular transaction.
10. Your Data Protection Rights and Choices
● Right to Access: You have the right to request a copy of the personal data we hold about you.
● Right to Correction: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
● Opt-Out of Marketing Communications: You can opt out of receiving promotional emails from us at any time by following the unsubscribe instructions included in those emails. Please note that you may still receive essential transactional or administrative messages from us.
● Cookie Choices: You can manage your cookie preferences through your browser settings. Please see our Cookie section below for more details.
To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request in a timely manner and in accordance with applicable law. We may need to request specific information from you to help us confirm your identity.
11. Cookies and Tracking Technologies
● Strictly Necessary Cookies: These are essential for the website to function and cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences or filling in forms.
● Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
● Functional Cookies: These enable the website to provide enhanced functionality and personalization.
● Advertising Cookies: These may be set through our site by our partners to build a profile of your interests and show you relevant on other sites.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
12. Children's Privacy
13. Links to Other Websites
14. Changes to This Privacy Policy
15. Contact Us
PAN-ASIA PAYMENT COMPANY LIMITED
Attn: Data Protection Officer
FLAT/RM 519, 5/F,
EAST OCEAN CENTRE,
98 GRANVILLE ROAD,
TSIM SHA TSUI, KL
Hong Kong
Email: [email protected]
Terms of Service
1. Introduction and Acceptance of Terms
Welcome to PAN-ASIA PAYMENT COMPANY
LIMITED. These Terms of Service
("Terms") constitute a legally
binding agreement between you
("User," "you," or "your") and
PAN-ASIA PAYMENT COMPANY LIMITED
("Company," "we," "us," or "our"), a
company registered in Hong Kong with
its address at FLAT/RM 519, 5/F,
EAST OCEAN CENTRE, 98 GRANVILLE
ROAD, TSIM SHA TSUI, KL.
These Terms govern your
access to and use of our website,
and our
money transfer and payment services
("MSO Services"), collectively
referred to as the "Services."
By accessing our website,
creating an account, or using any of
our Services, you acknowledge that
you have read, understood, and agree
to be bound by these Terms and our
Privacy Policy, which is
incorporated herein by reference. If
you do not agree with any part of
these Terms, you must not use our
Services.
If you are using the
Services on behalf of an
organization or entity
("Organization"), then you are
agreeing to these Terms on behalf of
that Organization, and you represent
and warrant that you have the
authority to bind the Organization
to these Terms. In that case, "you"
and "your" will refer to both you as
an individual and that Organization.
2. Definitions
● "MSO Services" refers to
the money remittance, currency
exchange, and other payment services
provided by the Company under its
Money Service Operator License
issued by the Hong Kong Customs and
Excise Department.
● "User Account" or
"Account" means the account you
create on our platform to access and
use the Services.
● "Intellectual Property"
means all patents, copyrights,
design rights, trademarks, service
marks, trade secrets, know-how,
database rights, and other rights in
the nature of intellectual property
rights (whether registered or
unregistered) and all applications
for the same, anywhere in the world.
● "AML/CFT" stands for
Anti-Money Laundering and
Counter-Financing of Terrorism.
3. Eligibility and User Account
To be eligible to use our Services,
you must be at least 18 years old
and have the legal capacity to enter
into a binding contract.
To access most features of
our Services, you must register for
a User Account. You agree to:
a) Provide true, accurate,
current, and complete information
about yourself or your Organization
as prompted by the registration
form.
b) Maintain and promptly
update your information to keep it
true, accurate, current, and
complete.
c) Maintain the security and
confidentiality of your password and
any other account credentials.
d) Be solely responsible for
all activities that occur under your
Account. You must notify us
immediately at
[email protected] of any
unauthorized use of your Account or
any other breach of security.
We reserve the right to
refuse registration, suspend, or
terminate your Account at our sole
discretion if we suspect that you
have provided inaccurate information
or have violated any of these Terms.
4. Terms for MSO Services
This section applies specifically to
users of our MSO Services for
remittance and payments.
4.1. Compliance with Laws:
Our MSO Services are provided in
strict compliance with the Hong Kong
Anti-Money Laundering and
Counter-Terrorist Financing
Ordinance (Cap. 615) and other
applicable regulations. By using our
MSO Services, you agree to comply
with all applicable laws and
regulations.
4.2. Identity Verification
(KYC/CDD): To use our MSO Services,
you must provide us with certain
personal information for the purpose
of identity verification
(Know-Your-Customer or KYC) and
Customer Due Diligence (CDD). This
may include, but is not limited to,
your full name, address, date of
birth, government-issued
identification document, and proof
of address. For corporate users, we
may require business registration
documents, director information, and
ultimate beneficial owner details.
You authorize us, directly or
through third parties, to make any
inquiries we consider necessary to
validate your identity. We reserve
the right to refuse service,
suspend, or terminate your account
if you fail to provide the required
information or if we cannot verify
your identity to our satisfaction.
4.3. Transaction Processing:
● Accuracy of Information:
You are solely responsible for
providing accurate and complete
information for each transaction,
including the recipient's full name,
bank account details, and any other
required information. We are not
liable for any losses resulting from
your provision of inaccurate
information.
● Processing Times: We will
make every reasonable effort to
process your transactions promptly.
However, processing times are
estimates and are not guaranteed.
Delays may occur due to factors
beyond our control, including checks
required for compliance, the
operating hours of correspondent
banks and financial institutions,
public holidays in the destination
country, and system availability.
● Exchange Rates: The
foreign exchange rate applied to
your transaction will be a variable
rate that changes. The rate provided
at the time of your transaction
request will be clearly displayed.
By proceeding with the transaction,
you agree to the specified exchange
rate.
4.4. Transaction Limits and
Refusal of Service: We may, at our
sole discretion, impose limits on
the amount and frequency of
transactions you can conduct. We
also reserve the right to refuse to
process any transaction or suspend
your access to the MSO Services if
we believe the transaction:
a) Violates these Terms or
any applicable law.
b) Is fraudulent,
suspicious, or related to any
illegal activity, including money
laundering or terrorist financing.
c) Involves a sanctioned
individual, entity, or country.
d) Exceeds any applicable
transaction limits.
e) Poses an unacceptable
level of risk to our business.
4.5. Prohibited Activities
for MSO Services: You agree not to
use our MSO Services for any of the
following:
● Any activity that is
illegal in Hong Kong or the
jurisdiction where you or the
recipient resides.
● Funding of illegal
organizations, terrorism, or the
purchase of illegal goods and
services.
● Fraud, scams, or any
deceptive practices.
● Any activity that
infringes on the intellectual
property rights of others.
5. Fees and Payment (General)
You are responsible for all fees associated with your use of the Services. For MSO Services, applicable fees and exchange rates will be disclosed to you prior to you confirming a transaction. Fees will be governed by the applicable Proposal. You authorize us to charge your designated payment method for all applicable fees.
6. Intellectual Property Rights
6.1. Our IP: All rights, title, and interest in and to the Services, our website, our platform, and all content therein (excluding Client Materials), including all related Intellectual Property rights, are and will remain the exclusive property of PAN-ASIA PAYMENT COMPANY LIMITED and its licensors.
7. Confidentiality
"Confidential Information" means any information disclosed by one party to the other which is designated as confidential or which should reasonably be understood to be confidential given the nature of the information and the circumstances of disclosure. Both parties agree to use the other's Confidential Information only for the purpose of fulfilling their obligations under these Terms and any Proposal, and to not disclose it to any third party without prior written consent, except as required by law.
8. Privacy Policy
Your privacy is important to us. Our Privacy Policy explains how we collect, use, and protect your personal information. By using our Services, you agree to the collection and use of information in accordance with our Privacy Policy.
9. Disclaimers and Limitation of Liability
9.1. Disclaimer of Warranties: THE
SERVICES ARE PROVIDED "AS IS" AND
"AS AVAILABLE," WITHOUT ANY
WARRANTIES OF ANY KIND, EITHER
EXPRESS OR IMPLIED, INCLUDING, BUT
NOT LIMITED TO, IMPLIED WARRANTIES
OF MERCHANTABILITY, FITNESS FOR A
PARTICULAR PURPOSE, OR
NON-INFRINGEMENT. WE DO NOT WARRANT
THAT THE SERVICES WILL BE
UNINTERRUPTED, SECURE, OR
ERROR-FREE.
9.2. Limitation of
Liability: TO THE FULLEST EXTENT
PERMITTED BY APPLICABLE LAW, IN NO
EVENT SHALL PAN-ASIA PAYMENT COMPANY
LIMITED, ITS AFFILIATES, DIRECTORS,
EMPLOYEES, OR AGENTS BE LIABLE FOR
ANY INDIRECT, INCIDENTAL, SPECIAL,
CONSEQUENTIAL, OR PUNITIVE DAMAGES,
OR ANY LOSS OF PROFITS OR REVENUES,
WHETHER INCURRED DIRECTLY OR
INDIRECTLY, OR ANY LOSS OF DATA,
USE, GOODWILL, OR OTHER INTANGIBLE
LOSSES, RESULTING FROM:
(A) YOUR ACCESS TO OR USE OF
OR INABILITY TO ACCESS OR USE THE
SERVICES;
(B) ANY CONDUCT OR CONTENT
OF ANY THIRD PARTY ON THE SERVICES;
(C) ANY CONTENT OBTAINED
FROM THE SERVICES; OR
(D) UNAUTHORIZED ACCESS,
USE, OR ALTERATION OF YOUR
TRANSMISSIONS OR CONTENT.
10. Indemnification
You agree to defend, indemnify, and
hold harmless PAN-ASIA PAYMENT
COMPANY LIMITED and its directors,
employees, and agents from and
against any and all claims, damages,
obligations, losses, liabilities,
costs, or debt, and expenses
(including but not limited to
attorney's fees) arising from:
a) Your use of and access to
the Services.
b) Your violation of any
term of these Terms.
c) Your violation of any
third-party right, including without
limitation any copyright, property,
or privacy right.
d) Any claim that your
content or materials caused damage
to a third party.
11. Term and Termination
These Terms will remain in full
force and effect while you use the
Services.
We may suspend or terminate
your Account and your access to the
Services at any time, for any
reason, without notice, including
for any breach of these Terms. You
may terminate your account at any
time by contacting us, but you will
remain liable for all obligations
related to your Account even after
it is closed.
Upon termination, all
licenses and rights granted to you
in these Terms will immediately
cease.
12. Governing Law and Dispute Resolution
These Terms shall be governed by and
construed in accordance with the
laws of the Hong Kong Special
Administrative Region, without
regard to its conflict of law
principles.
You agree that any legal
action or proceeding arising out of
or relating to these Terms or the
Services shall be brought
exclusively in the courts of the
Hong Kong Special Administrative
Region.
13. Changes to Terms
We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material, we will provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the revised terms.
14. General Provisions
● Entire Agreement: These Terms,
together with our Privacy Policy and
any applicable Proposal, constitute
the entire agreement between you and
PAN-ASIA PAYMENT COMPANY LIMITED
concerning the Services.
● Severability: If any
provision of these Terms is held to
be invalid or unenforceable, that
provision will be limited or
eliminated to the minimum extent
necessary, and the remaining
provisions will remain in full force
and effect.
● No Waiver: No waiver of
any term of these Terms shall be
deemed a further or continuing
waiver of such term or any other
term, and our failure to assert any
right or provision under these Terms
shall not constitute a waiver of
such right or provision.
● Assignment: You may not
assign or transfer your rights or
obligations under these Terms
without our prior written consent.
We may assign our rights and
obligations under these Terms
without restriction.
● Force Majeure: We shall
not be liable for any failure to
perform our obligations hereunder
where such failure results from any
cause beyond our reasonable control,
including, without limitation,
mechanical, electronic, or
communications failure or
degradation.
● Notices: Any notices or
other communications provided by us
under these Terms will be given: (i)
via email; or (ii) by posting to the
website. For notices made by e-mail,
the date of receipt will be deemed
the date on which such notice is
transmitted.
15. Contact Information
If you have any questions about
these Terms, please contact us at:
PAN-ASIA PAYMENT COMPANY
LIMITED
FLAT/RM 519, 5/F,
EAST OCEAN CENTRE,
98 GRANVILLE ROAD,
TSIM SHA TSUI, KL
Hong Kong
Email:
[email protected]