Harbour and Hills Privacy Policy Statement

Harbour and Hills Financial Services Limited, and from time to time, its subsidiaries and affiliates (together the “Group”) (and each being “HHFS”, “we”, “us” or “member of the Group” for the purposes of this Privacy Policy Statement as appropriate recognise their responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. We will use your personal data which we may from time to time collect in accordance with this Privacy Policy Statement.

We regularly review this Privacy Policy Statement and may from time to time revise it or add specific instructions, policies and terms. Where any changes to this Privacy Policy Statement are material, we will notify you using the contact details you have provided us with and, where required by the PDPO, give you the opportunity to opt out of these changes by means notified to you at that time. Otherwise, in relation to personal data supplied to us through the HHFS website or otherwise, continued use by you of the HHFS website or your continued relationship with us shall be deemed to be your acceptance of and consent to this Privacy Policy Statement, as amended from time to time.

If you have any questions about this Privacy Policy Statement or how we use your personal data, please contact us through one of the communication channels set out in the “Contact Us” section below.

We will take all practicable steps to ensure the security of the personal data and to avoid unauthorized or accidental access, erasure or other use. This includes physical, technical and procedural security methods, where appropriate, to ensure that the personal data may only be accessed by authorized personnel.

Please note that if you do not provide us with your personal data (or relevant personal data relating to persons appointed by you to act on your behalf) we may not be able to provide the information, products or services you have asked for or process your requests.

The purpose is to share with you our policies and practices concerning our commitment to protect the privacy of personal data and to comply with the relevant privacy regulations in the locations we operate in. It is the corporate policy and the social responsibility of the Group to respect and safeguard the privacy of individuals’ personal data. Compliance with this Privacy Policy Statement and the respective jurisdiction’s privacy laws and regulations is not only the responsibility of HHFS management but also the direct responsibility of every employee of the Group. In cases where there are conflicts between this Privacy Policy Statement and local privacy legislation, the latter shall prevail. Therefore, it is necessary for you to share your personal data in connection with the opening or continuation of accounts and the establishment or continuation of any services/facilities with HHFS to initiate or maintain the business relationship.

We have a long history of handling personal, including sensitive information, confidentially. We value the ongoing trust you have in us to protect your privacy. Personal data means information that can be linked to a specific individual, such as name, address, telephone number, and email address. We encourage users to review our Privacy Policy Statement and become familiar with it; however, users should note that we do not sell or rent our users’ personal data to third parties. You are not required to register or provide this information to us in order to view our website or access its content.

Collection of Information

On our website, we collect both personal data and aggregate information that users voluntarily provide either while on the website or in response to emails related to features provided on the website. We do not require users to register or provide information to us in order to view our website or access its content. Personal data may be collected with your consent or as permitted or required by law.

We collect personal data when users request services from us. This personal data may include identities and contact information of senders and recipients of money transfers, credit card, banking, or  ther billing information, birth dates, personal identifiers, information for identity verification, identification numbers, and transaction amounts.

Information about user transactions with us, including transaction history, such as frequency of use and transaction amounts, is also collected.

For identity verification, fraud prevention, and security purposes, we collect and/or verify certain identity-related information, financial background, and similar data from third-party sources such as government agencies and consumer reporting agencies.

Aggregate information relates to metrics like website visitor numbers, accessed pages, downloaded information, web browser and operating system types, internet service provider names, and more. When users visit our website, this information is automatically collected and combined with data from all other visitors to help us enhance our website for our visitors.

Users can visit our website without disclosing their identity or any personal data. We track the internet domains from which visitors access our website and analyse this data for trends and statistics while maintaining user anonymity.

For website management purposes, we may:

• Log users’ browsing history;
• Log non-personally identifiable information, including IP addresses, profile information, aggregate user data, and browser types;
• Record user IP addresses for security and monitoring purposes.

Cookies

We may place a text file called a “cookie” in the browser files of the user’s computer. The cookie itself does not contain personal data, although it will enable us to relate the user’s use of this website to information that the user has specifically and knowingly provided. The only personal data a cookie can contain is information that the user supplies. A cookie cannot read data off the user’s hard disk or read cookie files created by other websites. We may use cookies to track user traffic patterns. Our advertising system may deliver a cookie to better track ad impressions and click rates.

The user can refuse cookies by turning them off in the browser options. If the user has set the browser to warn before accepting cookies, they will receive a warning message with each cookie. The user need not have turned the cookies on to use this website.

Use of Personal Data

HHFS generally uses personal data for providing money transfer and related products and services. This may include the following purposes:

• Authorising and processing transactions, including effecting and administering money transfers, ensuring proper payment to designated recipients.
• Collecting amounts owing, enforcing and collecting on accounts or agreements.
• Monitoring and improving the website and its content.
• Sending information about products and services upon request.
• Meeting legal, regulatory, self-regulatory, risk management, fraud prevention, and security requirements, including verifying identities against money laundering, terrorist financing, or similar watch lists.
• Maintaining business and transaction records, managing and administering business.
• Meeting insurance, audit, and processing requirements.
• Otherwise with consent or as permitted or required by law.

How we use cookies

When accessing our information or services through the HHFS website, please note that cookies are used. Cookies are data files stored on your browser. The HHFS website automatically installs and uses cookies on your browser upon access. Two types of cookies are used on the HHFS website:

Session Cookies: temporary cookies that only remain in your browser until you leave the HHFS website, utilised to store configuration information and administer the website, including carrying information between pages to avoid re-entering data on each visit. Session cookies are also used to compile anonymous website usage statistics.

Disclosure of Your Personal data

We may disclose your personal data to our affiliates and to unaffiliated third parties in connection with the purposes described in this Privacy Policy Statement as follows:

To Provide Services: In order to process and complete requested money transfers and other transactions, we may disclose personal data to the recipient of a money transfer, our agents or affiliates, and, if applicable, the recipient, any intermediary banks, or other financial institutions or financial services companies involved in the transaction or our services.

Service Providers: HHFS may transfer personal data to outside agents or service providers that perform services on our behalf, for example, information technology and/or data hosting or processing services. We take reasonable measures to ensure that personal data processed by our service providers on our behalf is protected and not used or disclosed for purposes other than directed by us, subject to legal requirements applicable to HHFS affiliates, agents, and service providers, including lawful requirements to disclose personal data to government authorities in those countries.

Business Transactions: Your personal data may be used by HHFS and disclosed to parties connected with the contemplated or actual financing, securitisation, insuring, sale, assignment, or other disposal of all or part of our business or assets (including your account with us) for purposes related to the evaluation and performance of these transactions, including:

• Allowing parties to evaluate and determine whether to proceed or continue with the transaction.
• Fulfilling reporting, inspection, or audit requirements or obligations to such parties.
• Successors and assigns of HHFS and/or its business or assets may use and disclos your personal data for similar purposes as described in this Privacy Policy Statement.

Compliance with laws and regulations

The Group may be required to retain, process, and/or disclose your personal data to comply with applicable laws and regulations, or to comply with a court order, subpoena, or other legal process (whether in Hong Kong or elsewhere), or to fulfil a request by a government authority, law enforcement agency, or similar body (whether located in Hong Kong or elsewhere), or to meet legal, regulatory, self-regulatory, insurance, audit, and security requirements, and with your consent or as permitted or required by law. The Group may need to disclose your personal data to enforce any agreement with you, protect our rights, property, or safety, or the rights, property, or safety of our employees, or to fulfil or discharge such disclosure duties in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering, and similar laws and regulations.

Your Consent

Consent to the collection, use, and disclosure of personal data may be given in various ways. Consent can be express (for example, orally, electronically, or on a form you sign describing the intended uses and disclosures of personal data) or implied (for example, when you provide information necessary for a service you request). You may provide consent in some circumstances where notice has been provided to you about our intentions regarding your personal data and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if available. Consent may also be given by your authorised representative (such as a legal guardian or a person with power of attorney, where legally permissible).

Generally, by providing us with personal data, we will assume that you consent to our collection, use, and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection. If you provide us with personal data about a third party, you represent that you have consent from that individual to provide us with their personal data.

You may withdraw your consent to our collection, use, and disclosure of personal data at any time, subject to contractual and legal restrictions and reasonable written notice. Note that if you withdraw consent to certain uses of your personal data, we may no longer be able to provide certain products or services. In cases where we have provided or are providing services to you, your consent will be valid for as long as necessary to fulfil the purposes described in this Privacy Policy or as stated at the time of collection. You may not be permitted to withdraw consent for certain necessary uses and disclosures.

HHFS collects, uses, and discloses your personal data with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use, or disclose personal data without your consent, for example, to comply with a court order, local or federal regulations, a legally permitted inquiry by a government agency, or to collect a debt owed to us.

Member Communications and Email

We adhere to a strict policy against sending unsolicited emails. Please note that opting not to receive emails does not exempt you from receiving administrative emails. Our Customer Care department may contact you in response to your inquiries, to provide services at your request, and to manage your requirements.

Security

We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and upon receipt. While we strive to use commercially acceptable means to safeguard your personal data, it is important to note that no method of transmission over the internet or electronic storage is 100% secure. Therefore, while we make every effort to protect your personal data, we cannot guarantee its absolute security.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights, or to comply with a judicial proceeding, court order, or legal process served on our website.

Changes to this Privacy Policy

Please note that we periodically review our Privacy Policy and may make changes to the policy accordingly. It is advisable to bookmark this page and periodically review it to ensure you have the most up-to-date version.

Corporate reorganization

As we continue to develop our business, we may reorganise our group structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate our business or a similar service under either this Privacy Policy Statement or a different privacy policy statement which will be notified to you. Such a third party may be located, and use of your personal data may be made, outside of Hong Kong in connection with such acquisition or reorganization.

Access and correction of personal data

Under the PDPO, you have the right to ascertain whether we hold your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request us to inform you of the type of personal data held by us. All data access requests shall be made using the form prescribed by the Privacy Commissioner for Personal Data (“Privacy Commissioner”) which may be found on the official website of the Office of the Privacy Commissioner or via this link

https://www.pcpd.org.hk/english/publications/files/Dforme.pdf

Requests for access and correction of personal data or for information regarding policies and practices and kinds of data held by us should be addressed in writing and sent by post to us (see the “Contact Us” section below).

A reasonable fee may be charged to offset our administrative and actual costs incurred in complying with your data access requests.

Termination or cancellation

Should your account or relationship with us be cancelled or terminated at any time, we shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that we may keep copies of your data as is reasonably required for archival purposes, for use in relation to any actual or potential dispute, for the purpose of compliance with applicable laws and regulations and for the purpose of enforcing any agreement we have with you, for protecting our rights, property or safety, or the rights, property or safety of our employees, and for performing or discharging our functions, obligations and responsibilities.

Contact Us

If you have any questions or suggestions about our Privacy Policy, you can contact us at info@harbourandhills.com

We will be happy to resolve your concerns.

Harbour and Hills Financial Services Limited, Hong Kong is the holding company of Harbour and Hills subsidiaries globally.

Harbour and Hills Financial Services Pty Limited (Harbour and Hills) is registered in Australia with Australian Securities and Investments Commission (ACN: 088958105)

Office Addresses

Hong Kong
Suite Nos. 1604 & 05, 16 Floor, Tower 3, China Hong Kong City, China Ferry Terminal, 33 Canton Road, Kowloon, Hong Kong

Australia
Suite No 3, Level 23, Collins Square Tower Five, 727 Collins Street, VIC 3008, Australia