All2Pay Limited (“All2Pay,” “we,” “us,” or “our”), incorporated in Hong Kong, is committed to protecting the privacy and personal data of our customers (and/or their employees), service providers (and/or their employees), partners (and/or their employees), applicants, prospects, website visitors, and other third parties. We are dedicated to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and adhering to globally recognized best practices for data protection.
Your Rights as a Data Subject
As a Data Subject, you have rights under the PDPO. All2Pay respects your rights regarding the processing of your personal data. Please find our contact details below if you have any concerns or questions regarding how we process your data or wish to exercise your rights under the PDPO.
Principles Governing Our Collection and Processing of Personal Data
All2Pay has adopted the following principles to govern its collection and processing of Personal Data:
- Lawfulness and Fairness: Personal Data shall be processed lawfully and fairly.
- Purpose Limitation: The Personal Data collected will only be those specifically required for the purposes of using our payment services and website. Such data may be collected directly from the Data Subject or provided to All2Pay via their employer or business partner. Data will only be processed for the stated purpose.
- Data Minimization: Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed.
- Accuracy: Personal Data shall be accurate and, where necessary, kept up to date.
- Storage Limitation: Personal Data shall only be retained for as long as it is required to fulfill contractual, legal, or regulatory requirements.
- Rights of the Data Subject: The Data Subject has the right to request from All2Pay access to and correction of their personal data. All such requests must be made in writing as described in the “Contact Us” section.
- Legal Basis for Processing: Personal Data shall only be processed based on a lawful purpose.
- Security: All reasonable steps will be taken to protect personal data from unauthorized or accidental access, processing, erasure or other use.
- No Automated Decision-Making or Profiling: All2Pay will not use personal data for any monitoring, profiling activity, or automated decision-making processes that produce legal effects concerning the data subject or similarly significantly affects the data subject.
Sharing Your Information
All2Pay may share your information in order to:
- Provide you with the payment products or services you’ve requested.
- Manage risk, verify your identity, and combat fraud or abuse of our website or services.
- Comply with legal and regulatory requirements, including those related to anti-money laundering and counter-terrorism financing.
- When you have given us consent.
We may share your information with:
- Our service providers who assist us in providing our services.
- Partners whose products or services you have requested.
- Regulatory or law enforcement agencies when required by law.
Information We Collect
All2Pay may collect information about your computer (or mobile device), including where available your IP address, operating system, and browser type, for system administration, security, and analytical purposes. This is statistical data about our users’ browsing actions and patterns. We also collect information required to complete payment transactions, and to comply with legal obligations like KYC/AML.
Transferring Your Information
Your information may be transferred to and stored in locations outside of Hong Kong. When we do this, we’ll take reasonable steps to ensure that it has an appropriate level of protection in line with the requirements of the PDPO.
Data Security
We use a range of measures to keep your information safe and secure, including encryption and other security technologies. We require our staff and any third parties working on our behalf to comply with appropriate compliance standards, including obligations to protect information and apply appropriate measures for its use and transfer.
Contact Us
If you would like further information on anything we have said in this Privacy Notice, or to contact our Data Protection Officer, please contact us at:All2Pay Limited, 8/F Eton Tower, 8 Hysan Avenue, Causeway Bay, Hong Kong
Updates to This Privacy Notice
This Privacy Notice may be updated from time to time, and the most recent version will always be available on our website.
