In order to be able to make our services available to you in compliance with the obligations imposed by any applicable law and by rules, guidelines and directives from time to time issued by regulatory authorities, we must ask you for certain information about yourself, including identification documents, financial information (e.g., information about your identity, e-commerce sales, beneficiary account, etc.) and other information/documents as from time to time required by the applicable laws and rules, guidelines and directives. We will utilize the data provided by you in accordance with applicable provisions of governing data protection laws, which shall include, without limitation, the Personal Data (Privacy) Ordinance (Cap.486 of the laws of Hong Kong). The information obtained shall, as a matter of principle, be used by us solely for providing our services and solely to the extent necessary to render such services. The information about you which we possess shall, as a matter of principle, not be made accessible to third parties unless we are under any legal obligation to do so or under any court order with competent jurisdiction, or we must do so to render our services to you (such as rendering your personal data to our counterparts in any part of the world, the online marketplaces for verification of your data and for investigation purposes, or the banks for processing the funds). In other cases, we will obtain your consent before we disclose any of your personal data to any third party.
Your privacy is of utmost importance to us. At Skyee, we uphold the following fundamental principles:
- We don’t ask you for personal information unless we truly need it.
- We don’t share your personal information with anyone except to comply with the law, provide our services, or protect our rights.
- We restrict access to your personal information Affiliates and Service Providers who need the information to provide services to you or to comply with applicable anti-money laundering, counter terrorist financing, and/or other laws and regulations.
- We maintain physical, electronic and process security protocols to protect your personal information.
2. Website Visitors
Like most website operators, Skyee collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Skyee’s purpose in collecting non-personally identifying information is to better understand how Skyee’s visitors use its website. From time to time, Skyee may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website. Skyee also collects potentially personally identifying information like Internet Protocol (IP) addresses for logged in users. Skyee only discloses logged in user IP addresses under the same circumstances that it uses and discloses personally identifying information as described below.
You may provide us data about you by filling in forms on our website (e.g. Skyee Account Registration Form), or by corresponding with us (for example, by e-mail or telephone). The data you provide may include data about additional persons that are beneficial owners of our services. This includes that is provided to us about you:
(1) upon registration for a Skyee Account;
(2) when you log in to your Skyee Account;
(3) when you submit any instruction through your Skyee Account;
(4) when entering a competition, promotion or survey; and
(5) when a problem is reported or a request for support is received.
You can always refuse to supply such personal data, but it may prevent you from being able to use our services.
3. Collection of information
We collect the personal data you provide directly to us when you apply for a Skyee Account, perform any transactions on our platform, or use other services provided by us. This may include:
(1) your contact information (e.g., name, email address, phone number, billing or mailing address);
(2) bank and credit account information, including PSP account information, list of virtual bank accounts owned by or related to you, beneficiary account details (including routing number and bank code);
(3) corporate information (e.g. company name, corporate documents, business information or tax information etc);
(4) IP address;
(5) identity validation (e.g., photograph, other information requested to verify your information, including copy of valid ID document or corporate documents);
(6) publicly available and/or criminal history;
(7) national or tax identification numbers;
(9) date and place of birth;
(10) risk rating and risk level of you;
(11) details of any transactions carried out using any the services which shall include the disbursement information, transaction date, transaction ID, transaction type, destination bank account, destination customer ID and destination currency;
(12) any other information that you choose to provide to us (e.g., if you send us an email/otherwise contact us) ;
(13) calls/emails/other correspondence; and
(14) information through Cookies and other tracking technologies as listed above and as described in the section below entitled “Cookies”.
You shall be responsible for providing accurate and up-to-date information to us or we may not be able to provide any service to you. You shall also provide all information that we consider necessary and appropriate to prove that the details provided are true, accurate and complete.
If you are required to provide information about shareholders or beneficial owners of your business, you hereby acknowledge and confirm that you have that person’s consent to provide his/her information to us. This may include:
(1) contact information, such as name, home address, and email address;
(2) online marketplace account information, such as username and password;
(3) financial information, such as bank account numbers, bank statement, and trading information;
(4) identity verification information, such as images of your government issued ID, passport, national ID card, or driving license. Depending on nationality, the information request may be different; and
(5) residence verification information, such as Utility bill details or similar information.
We may collect and process Personal Data about your counterparties or third parties related to your business in providing our services. You shall be responsible to make sure that the privacy rights of any third parties, including your counterparties and other individuals related to your business, are respected, including ensuring appropriate disclosures about third party data collection and use; with respect to such data you hereby undertake with us that we are acting as your data processor, and we will process personal data in accordance with the terms of the Terms and Conditions of Use and act in accordance with your lawful instructions.
4. Use of personal data
We will only use your personal data to:
(1) process your transactions, including transfers into and out of any country in the World in accordance with the local laws of each such country;
(2) perform the required controls and checks in accordance with money laundering/terrorist financing and know your customer requirements under any applicable law (which shall include the Anti-Money Laundering and Counter Terrorist Financing Ordinance (Cap.615 of the laws of Hong Kong), our internal control policies, and also the needs of any law enforcement agencies;
(3) analyze our website usage, and improve our website and website offerings;
(4) help us respond to your customer service requests and support needs;
(5) fulfill our obligations under any agreement to which we are a party, in particular, the agreements with online marketplaces, other payment processors or banks;
(6) verify the account numbers you have registered with the online marketplaces;
(7) compare the identities that you have provided to us to your identities provided to the online marketplaces for the purpose of identity verification and detecting and mitigating account takeovers;
(8) identify any abusive behaviour of you;
(9) identiy clusters of online marketplace accounts and virtual bank accounts related to those owned by you that online marketplace has identified abusive behaviour;
(10) for analytical, modelling, research, risk management, remediation or forecasting purposes, identify fact patterns associated with account takeovers and other fraud modus operandi, and identify bad actor activities earlier or with a greater degree of certainty and to take actions in connection therewith in compliance with the laws;
(11) verify the validity of cross border disbursements done by you;
(12) verify the identity of you and the bank account(s) provided by you;
(13) for measurement, analytics and risk management purposes, identify fact patterns associated with fraud and bad actor patterns;
(14) identify, prevent and mitigate fraudulent, illegal or abusive behaviour or you in online marketplaces;
(15) contact you about our services. The email address you provide may be used to communicate information and updates related to your use of our services. We may also occasionally communicate company news, updates, and related information relating to similar products and services provided by us; and
(16) administer contests, surveys or other site features as will from time to time be announced on our website.
We will not use your personal data for any purpose other than the purpose specified above and will delete the applicable information regarding marketplace data after it is no longer required, in particular your data relating to disbursement and to online marketplaces.
5. Disclosure of Personal Data
(1) Disclosure to Third Parties
We may need to disclose certain transaction data provided by you or your marketplace to our counterparts in China to ensure that the funds can be remitted to your designated account in China in fulfillment of all legal requirements under the laws of the People’s Republic of China.
(2) Disclosure to Legal Authorities
We may share your personal data with law enforcement agencies and other governmental or regulatory bodies when:
(a) we are compelled by subpoena, court order, or other legal procedure; or
(b) we have a reasonable ground to believe that the disclosure is necessary to prevent physical harm or financial loss; or
(c) disclosure is necessary to report suspected illegal activity; or
6. Transfer and storage of data
7. Protection of Certain Personal Data
Skyee takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of personally identifying information. These measures include computer safeguards and secured files. Skyee will not rent or sell personally identifying information to anyone. Skyee may disclose personally-identifying information to its Affiliates and Service Providers for the purpose of providing services to Skyee or complying with applicable anti-money laundering, counter terrorist financing, and/or other legal requirements. Some of these Affiliates and Service Providers may be located outside of your home country. We may also need to provide your information to government authorities, regulatory bodies, police/law enforcement agencies, or a court of law. This would be done, for example, to meet legal requirements, to aid in the prevention of a crime, or for other lawful purposes. By using our services, you consent to the disclosure of your personally-identifying information to the aforementioned persons or entities. Skyee may use your personal contact information to reach out to you regarding any account correspondences and any changes, improvements, or promotions related to our services. In the event that we correspond with you via phone, please note that we may record our telephone calls with customers for security and training purposes.
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11. Governing Law