Privacy Policy Statement

Effective as at April 2021

HashKey Digital Asset Group Limited (or its affiliates, hereinafter referred to as “HashKey”) is committed to protecting the privacy, confidentiality, and security of the personal data held by HashKey complying with the requirements of Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) with respect to the management of personal data. Meanwhile, HashKey is equally committed to ensuring that all its employees and agents uphold these obligations.

HashKey reserves the right from time to time to revise this Privacy Policy Statement (“Privacy Policy”). Where any changes to this Privacy Policy are material, HashKey will notify the users by updating and issuing the new version on the HashKey website. HashKey has the right to decide whether or not to notify users by using the contact details they have provided to HashKey. The users shall check the Privacy Policy periodically and pay attention to its revision. If disagreeing with this Privacy Policy or the revised contents, the users shall stop accessing the HashKey website immediately. After the publication of the new version of this Privacy Policy, the continued use by the users of the HashKey website or the users’ continued relationship with HashKey shall be deemed to be the users’ acceptance of and consent to this updated Privacy Policy, as amended from time to time.

HashKey will take reasonable and practicable steps to ensure the security of the users’ personal data and to avoid unauthorised or accidental access, erasure or use for other purposes. This includes physical, technical, and procedural security methods, where appropriate, to ensure that the users’ personal data may only be accessed by authorised personnel.

Please note that if the users do not provide HashKey with personal data (or relevant personal data relating to persons appointed by the users to act on their behalf), HashKey may not be able to provide the information, products or services the users have asked for or process the users’ requests, applications, subscriptions or registrations.

Purpose

HashKey may not collect any personal data from users and no registration is required in order to gain access to any information provided by HashKey website.

Personal data may be collected from users on a voluntary basis for some particular purposes or services. The users’ personal data that are collected and held by HashKey including but not limited to users name, telephone number, mobile phone number, address, email address, fax number, resume etc, are set out in the HashKey website which invite users to provide users’ data. Refusal to supply personal data may result in HashKey being unable to process users request or provide services to users.

From time to time, where personal data is provided by users, HashKey may use users’ personal data for one or more of the following purposes:

◊ responding to and processing users’ enquiries and taking further actions or doing proper follow-ups

◊ marketing and promoting existing and future HashKey products or services;

◊ providing users with information regarding the market insights in connection with HashKey products or services;

◊ providing users of the online services available at HashKey website and/or through other telecommunication channels;

◊ compiling general statistics in relation to the number of visitors to HashKey website and also the usage of HashKey website;

◊ conducting research and/or analysis from time to time to better understand users needs, preferences, interests, experiences and/or habits;

◊ designing new and/or enhancing existing services, products, activities, and/or other events relating to HashKey products or services;

◊ processing job applications by keeping job application records;

◊ for other purposes directly relating to any of the above.

How does HashKey use cookies

If the users access HashKey’s information or services through the HashKey website, the users should be aware that cookies are used. Cookies are data files stored on the users’ browsers. The HashKey website automatically installs and uses cookies on the users’ browsers when the users access it, which are used to store the users’ preferences, enhance the function of this website, and facilitate the users’ browsing. The cookies used in connection with the HashKey website do not contain personal data. The users may refuse to accept cookies on their browsers by modifying the settings in their browsers or internet security software. However, if the users do so they may not be able to utilise or activate certain functions available on the HashKey website.

Third party websites

The HashKey website may from time to time contain linkages to other websites. These other websites are independent from the HashKey website. HashKey has no control or management over the contents of such other websites or their privacy policies or compliance with the law. Users should be fully aware that the provisions of such links do not constitute an endorsement, approval, or any form of association by or with Hashkey and HashKey has no control over users’ personal data submitted by users, if any, to other websites.

Notice on Direct Marketing

HashKey may use users’ personal data (including your name and contact details) to send users marketing or promotion communications such as emails containing news, promotions and marketing offers. If users do not wish to receive further marketing or promotional materials from HashKey, you may opt out of receiving marketing or promotion communications by contacting HashKey.

Utilisation of the users’ personal data

HashKey may be required to retain, process and/or disclose the users’ personal data to the following parties, to which HashKey does not assume any liability for any loss or damage that the user may sustain, in order to

(1) comply with applicable laws and regulations;

(2) comply with a court order, subpoena or other legal process (whether in Hong Kong or elsewhere);

(3) comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong or elsewhere);

(4) provide to the third-party database for submitting behaviors concerning anti-money laundering, terrorism financing, and evading trade and economic sanctions;

(5) provide to a third party which provide services (such as legal, financial, management, operation, market surveillance or technical services) or is associated or acting as a nominee to HashKey;

(6) provide to any third party to whom HashKey’s businesses or any part of HashKey’s businesses will be sold, assigned or transferred to, if applicable; or

(7) HashKey may need to retain, process and/or disclose the users’ personal data in order to enforce any agreement with the users, protect HashKey ’s rights, property or safety, or the rights, property or safety of HashKey’s employees.

Such information may be transferred to a place outside Hong Kong.

Corporate reorganisation

As HashKey continue to develop its business, it may reorganise its corporate structure or undergo a change of control or business combination. In these circumstances it may be the case that the users’ personal data is transferred to a third party who will continue to operate HashKeyo’s business or a similar service under either this Privacy Policy or a different privacy policy which will be notified to the users. Such a third party may be located, and use of the users’ personal data in connection with such acquisition or reorganisation outside of Hong Kong.

Termination or cancellation

Should the users’ relationship with HashKey be cancelled or terminated at any time, HashKey shall cease processing the users’ personal data as soon as reasonably practicable following such cancellation or termination, provided that HashKey may keep copies of the users’ data as is reasonably required for reasonable purposes, such reasonable purposes shall include keeping of records, use in relation to any actual or potential dispute, complying with applicable laws and regulations, and protecting HashKey’s rights, property or safety, or the rights, property or safety of HashKey’s employees.

Retention of the users’ personal data

If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

Contact HashKey

If the users have any questions about this Privacy Policy or how HashKey use their personal data, or if the users would like to make a request for access or update of their personal data, please contact HashKey via [media@hashkey.com]

In accordance with the terms of the PDPO, HashKey has the right to charge a reasonable fee for the processing of any data access request.