Terms

Privacy Policy and Personal Information Collection Statement

XIN WANG GOLDEN COMPANY LIMITED (“the Company”, “we” or “us”) values the proper use and protection of personal data. This policy explains how we collect, use, retain and disclose personal data through our website, enquiries, account opening, account management and related services, and how we handle it under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and other applicable requirements. Where a particular form or service has its own collection statement, please read it as well.

1Data user and contact details

Data user: XIN WANG GOLDEN COMPANY LIMITED. For requests about this policy or to access or correct personal data, contact the Company’s [title of the officer responsible for personal data]. Email: [personal data email]; postal address: Room 1006, 10/F, Kam Ngan Commercial Building, 12-18 Mercer Street, Sheung Wan, Hong Kong. Please mark your request “Personal data enquiry” and provide enough information to identify it; don’t send passwords or verification codes in general enquiry emails.

2Information we may collect

1. Identity and contact details: such as name, date of birth, nationality, proof of identity, address, phone and email; what we collect depends on the service you apply for and the checks required.
2. Account and verification details: such as occupation or business, purpose of the account, financial or trading experience, source of funds, payment accounts and supporting documents, and for companies, authorisation, control structure and beneficial owner details.
3. Service records: such as account applications, account activity, orders, trades, fund movements, customer service, enquiries, complaints and related communications.
4. Website and device records: such as IP address, browser, device or system type, time of visit, pages viewed and data generated by cookies or similar technologies, depending on the website’s actual features and your settings.

We may obtain information from what you submit, your activity in our services, representatives you have properly authorised, and verification or public sources we may lawfully use. If a service involves call or other communication records, you will be told when they are collected, as applicable. We will not ask you to submit full account-opening or source-of-funds documents just because you browse general pages.

If you act for a company, or give the Company details of directors, beneficial owners, authorised representatives or other individuals, first make sure you are entitled to provide them, and tell those individuals about this policy and the relevant collection statement. Only provide what the application or verification requires; don’t upload other people’s information unrelated to the matter.

3How we use information

1. Responding to enquiries, processing account and service applications, and checking identity, authorisation and eligibility.
2. Opening, managing and maintaining accounts, and processing trades, payments, fees, instructions and related records.
3. Carrying out necessary client verification, source-of-funds enquiries, risk management, anti-fraud, anti-money-laundering and lawful cooperation.
4. Providing customer service and handling complaints, technical issues, record checks and disputes.
5. Keeping the website and accounts secure, fixing faults, and analysing and improving services within the scope consistent with the purpose of collection.
6. Complying with applicable law, lawful orders, reporting and record-keeping, and reasonable requirements directly related to the purposes above.

If we intend to use personal data for a new purpose beyond the original purpose of collection and directly related purposes, we will give the notice and obtain the consent required by applicable law. Direct marketing is covered in Part 7 of this policy; making an enquiry, applying for an account or accepting the terms of service does not automatically mean you agree to marketing.

4What information you must provide

The relevant form or verification notice will state which information is mandatory and which is optional. If you don’t provide information needed for account opening, verification or a particular service, we may be unable to process the application or continue the service. Marketing preferences and optional information unrelated to the necessary service are your choice. Choosing not to receive marketing does not affect applications for necessary services or existing account services; clients must still meet the eligibility and information requirements of the service itself.

5Who information may be disclosed to

Where necessary and consistent with the stated purposes, or as permitted or required by law, information may be provided to the categories below. We limit what is provided according to the matter; this list is not authority to share information with everyone without restriction.

1. Service providers that actually provide hosting, IT, account platform, communications, document storage, security or customer support services to the Company.
2. Banks, payment, settlement and identity or fund verification institutions that actually provide services for the relevant payments or checks.
3. Auditors, lawyers and other professional advisers handling the relevant matters for the Company.
4. Trading venues, regulators or law enforcement agencies, courts and other competent authorities that receive information under applicable business or legal requirements.
5. Persons you have validly authorised, or who are otherwise permitted by applicable law to receive such information.

If other group entities process information, their category, function and access must match the actual service and the purposes above; “group member” or “business partner” alone does not permit unrelated uses. Providing information to third parties for their own direct marketing is handled separately under Part 7.

Company staff and service providers processing data on the Company’s behalf should only access personal data where authorised, where their work genuinely requires it and consistent with the relevant purpose. Being engaged to process data does not permit using it independently for unrelated promotion or other purposes; any other use requires a proper legal basis.

6Processing or storage outside Hong Kong

If a service involves processing, storage or support outside Hong Kong, information may be transferred to those places for the stated purposes. The Company’s published information on actual arrangements is: [main processing or storage locations and categories of service providers]. We consider applicable law, the nature of the data and the recipient’s safeguards and take measures proportionate to the risk. Data protection regimes differ between places; where a particular transfer requires separate notice or consent, we will follow the applicable requirements.

7Direct marketing and your choice

If we intend to use your name, phone number, email or other contact details you provide to promote XinWang Gold’s precious-metals products, trading services, related events or educational information, we will clearly tell you which data and what kinds of marketing before use and obtain the consent required by law. You can agree, refuse or accept only certain channels; making no choice or simply continuing to browse the website is not consent to marketing.

If we intend to provide your personal data to another organisation for its direct marketing, we will separately state the categories of recipient, data and marketing, and whether it is provided for gain, and obtain separate written consent where required by law. Accepting the Company’s marketing does not mean you agree to third-party marketing.

You may ask us at any time, free of charge, to stop using your data for direct marketing through the unsubscribe option in marketing messages or the contact details in this policy. Unsubscribing does not affect earlier lawful processing, and does not stop non-marketing notices required for account security, trading, fund processing or legal obligations.

8Cookies, similar technologies and choices

The website may use cookies or similar technologies to keep you logged in and secure, remember preferences, analyse visits or support other properly notified features. Different purposes should not all be treated as necessary for the website to work. The actual cookie list and settings are at: [cookie list and settings link]. There you can see the names or categories, providers, purposes and retention or expiry periods.

You can manage cookies through the settings the website actually provides and your browser. Turning off necessary cookies may affect login, security checks or some features; optional analytics or advertising technologies should be used in line with the stated arrangements and applicable requirements. Embedded third-party content may also collect data, so note its provider and separate policy before use. Where cookies or other records can identify an individual, we treat them as personal data under this policy.

A record without a name is not necessarily anonymous data that cannot identify a person. If device, visit or cookie records can identify an individual when combined with an account or other data, we still treat them as personal data; protection cannot be excluded simply because the record originally had no name.

9Accuracy and retention

Please tell us promptly about changes to your contact, identity, authorisation and other important details. We take reasonable steps to keep data accurate for the relevant purposes, and decide retention periods by data category, service needs, applicable statutory periods and the needs of lawful disputes or investigations. Data is not kept indefinitely for convenience; however, closing an account or withdrawing marketing consent does not necessarily require immediate deletion of records that must be kept by law or for lawful purposes.

10Security and your cooperation

We take reasonable technical and organisational measures proportionate to the nature of the data and the risk to limit unauthorised or accidental access, processing, loss and use, and, where applicable, impose protection requirements on processors we engage. No electronic transmission or storage can be guaranteed to be completely risk-free. Only submit information through verified channels, and keep your password, verification codes and device access safe.

Before uploading ID documents, payment proofs or complaint screenshots, verify the receiving page and channel, and avoid disclosing full ID numbers, bank details or trading passwords in public messages. If you find information was sent by mistake, your account was accessed unusually or you suspect data has been misused, contact the Company as soon as possible using the details in this policy, stating when it happened, the channel and what was involved.

If a feature you use needs camera, photo or other device permissions, first read the actual provider’s explanation of the purpose, scope and the effect of refusing. Permissions should be proportionate to the feature you use; if you download or link to third-party trading software through the Company, also read that software provider’s privacy and permission statements. This policy does not mean XinWang Gold has obtained all permissions on your device.

11Access, correction and other requests

As required by applicable law, you may ask us to confirm whether we hold your personal data, access it and correct inaccurate data. To protect the data, we may reasonably verify the requester’s identity and authority, and will process the request or explain lawful restrictions within the applicable period. If we intend to charge a fee permitted by law for a data access request, we will first explain the amount and basis; the fee must be directly related to and necessary for that request and will not be replaced by general account service fees or unrelated costs.

If you ask us to stop a non-essential use, withdraw a particular consent or delete certain data, we will assess it under applicable law, the purpose of collection and lawful retention needs, and explain what can be done. Different requests may affect services differently; this policy does not promise that all records can be deleted immediately in every case.

12External websites and policy updates

External websites and third-party services linked from this website may have their own privacy arrangements, and this policy does not directly bind those independent entities. Please read their statements before submitting information. We may update this policy according to our actual services and legal requirements, stating the version and effective date on the relevant page; where a change of purpose requires separate notice or consent, we will follow the applicable requirements rather than simply updating the web page.

13Personal information collection statement for enquiry and application forms

The information on this form is collected by XIN WANG GOLDEN COMPANY LIMITED to respond to your enquiry, process the relevant application and carry out necessary follow-up. Fields marked as required are needed to handle the matter; if they are not provided we may be unable to respond or process it, and other information is optional. Information may be provided as needed to service providers supplying technical, communication or customer support for this matter, and to authorities lawfully entitled to receive it. Don’t enter trading passwords, verification codes or unrelated complete ID and bank details in general enquiry forms. For access and correction requests, contact the officer responsible for personal data as set out in Part 1 of this policy. For details, please read the Privacy Policy and Personal Information Collection Statement.

Optional marketing choice

I agree that XinWang Gold may use the name and contact details I provide to send me information about precious-metals products, services, events and education through the phone, SMS or email channels I choose. I understand this is optional and I can unsubscribe free of charge at any time.