Private Policy
PARemit
Private Policy
Last updated: September 2024
This Privacy and Security Policy (“Privacy Policy” or “This Policy”) sets out the basis on which we, Everpro Holdings Limited, under the brand name “PARemit” (“we” or “PARemit”), together with our subsidiaries, our holding company, aIiliated company (Our Group) from time to time, collect, use, store, share and protect your personal or company information as you use our website (https://www.paremit.com) or any other Uniform Resource Locators (“URL”), application and tools (collectively, the “Our Platform”) through or on which we provide services oIered to you. Based on the specific services you use, diIerent subjects may provide you with corresponding services, the entities that provide diIerent services are called relevant service parties, in order to comply with relevant laws, regulations and regulatory requirements, and to provide you with services or improve your service experience, relevant service parties will collect, use, store and share your personal information and company information, and relevant service parties will process your personal data and company information in accordance with this policy.
We strongly suggest you to read this policy carefully and prudently since what stated in this policy is very important to your rights and benefit. If you have any questions, please contact us through contact information stated in this policy.
If you have any queries regarding this Policy or our use of personal data, please refer to contact information at the end of this Policy.
1. Policy Statement
1.1 This Policy provides you with notice as to how and why your personal data is collected, how it is intended to be used, to whom your personal data may be transferred to, how to access, review and amend your personal data, and our policies on direct marketing and the use of Cookies, etc.
1.2 We collect and process your personal data in compliance with the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of the Hong Kong Special Administrative Region ( “PDPO”) in Hong Kong, General Data Protection Regulation (“GDPR”) in the European Union, or Data Protection Act 2018 in the United Kingdom (as the case may be). Terms like “data”, “personal data”, “data user” or “data controller”, “processing”, “disclose” and other terms defined by the PDPO or GDPR (as the case may be) (the “relevant data protection regulation”) are used in this Policy in accordance with the definitions given by the relevant data protection regulation.
1.3 You may be asked to consent to this Policy when you access, or interact with us via our platform. Otherwise, by using our platform, you are accepting the practices and statements in this Policy. You may choose not to provide us with the requested data, but failure to do so may inhibit our ability to provide information and Services to you or to respond to your enquiries.
1.4 Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Policy may from time to time be revised.
2. How we collect data
2.1. We will collect your personal data that you voluntarily provide to us through your user account on our platform or using our or Our Group’s or our business partners’ services. Based on laws or your authorization, we may also collect your personal data from third parties (e.g., marketing agencies, market research companies, our suppliers, contractors and consultants at our group companies, your colleagues and business contacts, public websites and public agencies) or sent to us automatically when using our platform and services. We, and our third party service providers, automatically collect your information about your use of our Website / App and our Services through cookies, web beacons, and other technologies.
2.2. How we use Cookies
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes, The information collected (including but not limited to: your IP addresses (and domain names), browser software, types and configurations of your browser, language settings, geo-locations, operating systems, referring website, pages and content viewed, etc.) will be used to ensure operation of the website and enable you to log in securely, for compiling aggregate statistics on how our visitors reach and browse our websites for web enhancement and optimization purposes, and to help us understand how we can improve your experience on it.
You can edit your browser options to block cookies. Visitors to our Website / App who disable their web browsers’ ability to accept cookies will still be able to browse our Website / App. However, most website features will not function correctly, if you disable all cookies (including essential cookies) and you may not even be able to login to use our Services. More information can be found in our Cookie policy.
3. When Does PARemit Collect Your Information
We may collect and store any information you provide us when you use our Services, including when you add information on a web / app form, add or update your account information, participate in dispute resolutions, or when you otherwise correspond with us regarding our Services.
4. Why we collect your data and what kind of data we collect
4.1. Realize the necessary functions of our Services When you use our Services, you may need to provide or authorize us to collect your data required for the corresponding Services in the following conditions. If you refuse to provide data required for some Services, you may not be able to have access to these Services, but it will not affect your normal use of our other Services.
(a) Registration and certification
When you register for a PARemit account, you need to provide us with your phone number, email address and set a password to create a PARemit account. We will verify whether your information is valid by sending an SMS verification code or verification email.
(b) Sending/Money Transfer
In order to realize the function of sending/money transfer, you are required to provide your own credit card and / or bank account information to upload money, the bank account information of the recipient/beneficiary and related business information (including contracts or invoices, etc.).
4.2. Optimize of Service Experience, Customer Service, Protection of User Rights and Interests (additional functions)
For the purpose of optimizing your Service experience, providing you with better customer Service and protecting your rights as our user, we and our third-party service providers may collect the following information about you, in case that you do not provide or agree with our retention of the aforementioned information, we may not be able to provide you with certain Services related to the optimization of service experience, customer service and user rights protection, but it will not aIect your use of our other Services.
(a) Optimize of Service Experience
We and our third-party service providers may collect the following information from you: your domain name, your browser type and operating system, your Internet Protocol (IP) address, the duration of your visit to our website or use of our services, your activities on our platform, and the referring URLs or pages that lead you to our platform.
(b) Communications of Customer Service
In order to respond to inquiries and assist you when oIering customer Services, we may collect your PARemit account information (including phone number, corporate basic information and your position, etc.) and related transaction information to verify your identity. Under certain occasions, in the need of check the authenticity of the transaction and complete the collection, we may collect name, ID number and bank account information of legal person’s spouse.
(c) Protection of User Rights and Interests
From time to time, we may collect feedback/recommendations information or the information you provided during reporting.
5. Use of data
Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal data for the following purposes:
(a) to validate your identity and to conduct checks related to anti-money laundering compliance;
(b) to process and administer your PARemit account, to implement and eIect the requests or transactions contemplated by the forms available on our platform or any other documents you may submit to us from time to time;
(c) to exercise our rights and perform our obligations relating to your contract with us, to communicate with you about our Services or any changes in the Service’s terms and conditions that apply to you;
(d) to respond to your inquiries and oIer you customer Services;
(e) to administer our Services for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(f) to protect our customers, employees or property – for instance, to investigate fraud, harassment or other types of unlawful activities involving us or other companies that we operate business with;
(g) to monitor your use of the platform and conduct analysis of the use of the platform in order to operate, evaluate and improve the platform and our Services, understand your preferences and troubleshoot any problems;
(h) to assist in law enforcement purposes, investigations by police or other government or regulatory authorities and to meet requirements imposed by applicable laws and regulations or other obligations committed to government or regulatory authorities;
(i) to personalize the appearance of our platforms, provide recommendations of relevant products, information and services and provide targeted advertising on our platform or through other channels;
(j) other purposes as notified at the time of collection; and
(k) other purposes directly relating to any of the above.
6. Personal Data Sharing and Disclosures
As a global company, PARemit may share data with its group of companies, business partners, or government authorities, etc. PARemit applies caution when contracting with data processors, performs the relevant activities and puts all the safeguards in place, as required to comply with the relevant data protection regulation.
6.1. With Our Group
We share personal data with Our Group as necessary to provide the Services or perform usual technological activities. Personal data shared within Our Group are in compliance with laws stipulated in the relevant data protection regulation. Access to personal data within Our Group is restricted to those individuals who need to access the information for our business purposes.
6.2. With Business Partners
We may share certain clients’ data (such as basic corporate information, bank account information, etc.) with our business partners (such as bank, payment institution, etc.). In addition, we will sign strict confidentiality agreements with business partners that we shared your information with, requiring them to process and use data in accordance with this Policy and take strict data security measures.
6.3. With Government Authorities
We may provide personal data to government authorities as requested by public authorities, auditors or institutions competent to exercise inspections on PARemit, based on their legal 5 obligations, which may ask us to provide information. In addition, we may provide personal data to comply with a legal requirement or to protect the rights and assets of PARemit or other entities or people, such as courts of law, or enforcement authorities.
6.4. With Potential Acquirers or Investors
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our platform of any change in ownership or uses of your personal data, as well as any choices you may have regarding personal data.
6.5. To Protect us and Others
We may disclose your information when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Services’ terms and conditions or this Policy, or as evidence in litigation in which we are involved.
6.6. With Analytic and Search Engine Providers
We may disclose your information to analytic and search engine providers that assist us in the improvement and optimization of our platform. For our policy on sharing of your personal data for promotional and marketing purposes, please see the section entitled “Use of Personal Data for Direct Marketing Purposes”.
7. Use of Personal Data for Direct Marketing Purposes
7.1. In addition to the purposes set out above, where permitted by law, PARemit may use your name and contact details for promotional or marketing purposes including sending you promotional emails and conducting direct marketing in relation to our products, services, or activities or, as appropriate, those of Our Group or other companies with whom we have partnered.
7.2. For the purposes of direct marketing, we may, where permitted by law, provide your personal information to marketing and call center providers so that they can send you promotional materials and conduct direct marketing in relation to our Services (these materials may be sent to you by SMS, email or other means).
7.3. Before using or providing your personal data for the purposes and to the transferees set out in this section, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use and provide your personal data for any promotional or marketing purpose.
7.4. If your consent is required, and you provide such consent, you may thereafter withdraw your consent to the use and provision to a third party by PARemit of your personal data for direct marketing purposes and thereafter PARemit shall cease to use or provide such data for direct marketing purposes.
7.5. If you have provided consent and wish to withdraw it or if you prefer not to receive marketing communications from us in any form, please contact us as described in this Policy.
8. Data Transfers and Global Processing
Due to the nature of our global business and the technologies required, your personal data may be transferred to third-party service providers outside Hong Kong. We are committed to take all reasonably necessary steps and exercise all due diligence to make sure all personal data collected, held, stored, used, or otherwise processed outside Hong Kong are treated securely, in accordance with this Policy and in compliance with the relevant data protection regulation.
9. Personal Data Security
PARemit uses reasonable methods to secure all personal data by a variety of methods, including restricting access to such personal information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of PARemit, securing access to the facility where the personal data is stored and the use of technology and physical controls to secure the personal data. PARemit is required to disclose personal information in response to lawful requests by public authorities including to meet law enforcement requirements. If you have questions about the security of your personal data, please contact us as described in this Policy.
10. Personal Data Retention
We will store your personal data for a limited period of time, as necessary to achieve the purposes of the personal data processing, as described in this Policy, and in accordance with our legal and contractual obligations, or industry practices.
Once the retention period expires for a specific category of data, PARemit will delete, archive, anonymize or destroy it, in accordance with our internal policies and procedures, unless prohibited by the relevant data protection regulation or other applicable law.
You may request to have your personal data deleted at any time by contacting us using the contact details as described in this Policy.
11. How Does PARemit Store and Protect Your Information
We will strictly abide by relevant laws and regulations to respect and protect users’ privacy rights. Unless in accordance with the published guidelines on our platform, we will not disclose and reveal your personal information without your authorization.
We take security measures in respect of physical, electronic, and management that comply with industry standards to protect your personal information. We manage the storage and use of standardized information by establishing data hierarchical management, system security management, and data security development specifications. We conduct comprehensive security control of data by signing confidentiality agreements with information receivers, completing monitoring and internal management systems.
We will take all reasonable and feasible measures to protect your personal information. For example, the data exchange between your browser and PARemit is protected by SSL encryption; encryption technology is used to ensure the confidentiality of data; two-factor authentication is used to protect account security; a trusted protection mechanism is used to prevent malicious attacks on accounts; conduct network information security training and assessment regularly for 7 relevant personnel to make them fully realize the importance of network security and strictly abide by corresponding rules and regulations.
If you accidentally disclose your login account and password, you shall contact us via the contact information on our platform or our customer service hotline as soon as possible for us to lock the user’s operating authority timely to prevent any third-party from illegal operation. Besides, you can reset your password and resume to normal use after providing valid identification and relevant credentials which have been reviewed and verified by us.
12. How Does PARemit Protect the Information of Minors?
We attach great importance to the protection of minors’ personal information, and the services of our platform are mainly for adults. If you are a minor, it is recommended for your parents or guardians to read this policy and you can only use our services or provide us with your information after the consent of your parents or guardians. If your guardian does not agree that you use our services or provide us with information in accordance with this policy, please stop using our services immediately and notify us as soon as possible so that we can take corresponding measures. We will ensure the confidentiality and security of minors’ personal information in accordance with relevant laws and regulations.
For minors’ personal information collected during the use of our products or services with the consent of parents or guardians, we will only use, share, transfer or disclose such information if it is permitted by laws and regulations, there is express consent of parents or guardians or it is necessary to protect minors.
13. Data Subject Rights
The PDPO provides the following rights to individuals with respect to personal data governed by the PDPO, which you (if applicable) may exercise at any time by contacting us using the contact details as described below.
(a) verify whether PARemit holds any personal data about you and to access any such data;
(b) require PARemit to correct any personal data relating to you which is inaccurate;
(c) withdraw your consent for use or provision of personal data for direct marketing;
(d) make a complaint about PARemit’s data processing; and
(e) enquire about PARemit’s policies and practices in relation to personal data.
The GDPR provides the following rights to individuals with respect to personal data governed by the GDPR, which you (if applicable) may exercise at any time by contacting us using the contact details as described below.
(a) the right to information – verify whether PARemit holds any personal data relating to you;
(b) the right to access – to access your personal data held by PARemit;
(c) the right to correct personal data – to require PARemit to correct any personal data relating to you which is inaccurate;
(d) the right to erase personal data, also known as the right to be forgotten – to require PARemit to erase your personal data;
(e) the right to restrict data processing – to require PARemit to restrict the processing of your personal data under certain circumstances;
(f) the right to object to data processing – to object to data processing under certain circumstances;
(g) the right to data portability – to receive a copy of your personal data from PARemit or transfer your personal data to another controller;
(h) the right to not be subject to automated decision-making – to object to automated decision-making, including profiling, under certain circumstances; and
(i) the right to be notified of a data security breach.
Requests for access, correction, complaints, or other queries relating to your personal data should be addressed to the contact details as described in this Policy.
Under applicable laws and regulations, PARemit has the right to charge costs which are directly related to and necessary for the processing of any personal data request.
14. Changes to this Policy
PARemit will occasionally update this Policy as it could become necessary. PARemit encourages you to periodically review this Policy to be informed of how PARemit is protecting your personal data.
15. Contact Information
If you want to exercise your rights as set out in this Policy, or have any queries regarding this Policy or our processing of personal data, please contact us at:
- The Data Protection Officer
- Everpro Holdings Limited
- Address: Room 43A, 21/F., On Hong Commercial Building, 145 Hennessy Road, Hong Kong
- Email: [email protected]
