Private Policy

Overview

This policy sets out how we will use, store, share, processes, discloses, and protect the information we collect about you when you visit our website or App, use our products or services, or otherwise interact with us and how you may access and control the information. In this policy, INK.HK, or “we”, refers to INK.HK Technologies Limited (together with our subsidiaries) and “Platform” means our website at https://inkfinance.hk and our software, namely https://inkhk.app.inkfinance.xyz. In this policy, “you” or “User” refers to you, as an individual user, and/or as an authorized representative of a Business you represent.

In this policy, “personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services, including but not limited to providing information about potential borrowers with specific profiles (the “Services”), that relates to an identifiable individual acting in its own capacity and/or on behalf of the Business it represents. 

Please read this Privacy Policy carefully and ensure that you understand it. If you do not agree with our policies and practices, do not access our Platform or use our Services. Your continued use of the Services is deemed as acceptance of our Privacy Policy. This policy may change from occasionally (see Changes to Our Privacy Policy below). Your continued use of the Platform and the Services after we revise this policy means you accept those changes, so please check the policy periodically for updates.


What this Policy covers

This Privacy Policy applies only to your use of our Services, including newsletter subscription and any promotion/offers we make available from time to time. It does not extend to any websites that are linked to or from our site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by third party websites you connect to, and we advise you to check the privacy policies of any such websites before providing any data to them.


Your Account

Stage 1 – Creating your Account

To create an account with us, all we need is for you to submit your email address.


Stage 2 – Getting verified

For individual users, to get verified you will need to add your personal information such as name, address, photographic and video ID. To enhance the accuracy of your digital identity you may be required to provide additional data, such as date of birth, copy of ID, citizenship information, country of residence, among others which may include a selfie and/or video verification. Under your instructions and consent we will share the data to be verified.

For business users, to get verified you will need to add personal information as referred to above as well as information about the business you represent such as business or trade name, registered address, business’ jurisdiction of incorporation. You will also need to add relevant information about the business controller(s) (including his/her passport or national ID and proof of address), email address, telephone number(s). You will also be required to submit business documents which includes the business’ Certificate of Incorporation, Articles of Association/Bylaws, Shareholder(s)’ Register, Director(s)’ Register, Organizational Chart and Certificate of Incumbency (“business information”),


Stage 3 – Reaching agreements with Borrowers

Now that you are verified, you are able to use your Account to reach agreements with the borrowers through the Platform. Different Borrowers, as well as loan intermediaries may require different types of information. BY PROCEEDING, YOU EXPRESSLY CONSENT TO SHARE THE RELEVANT DATA WITH THE BORROWERS AND LOAN INTERMEDIARIES AS NECESSARY SO YOU CAN REACH AN AGREEMENT WITH THEM. If you choose to cancel your account with us, we will delete your information unless we are contractually or legally prevented to do so and to prevent fraud and money laundering. Your personally identifiable information will not be sold and it will only be shared with third parties when necessary for the provision of the services to you, to prevent fraud or money laundering and assist law enforcement in accordance with this Privacy Policy.

IT IS IMPORTANT TO UNDERSTAND THAT THE ROLE OF INK.HK IS SOLELY THAT OF A PLATFORM PROVIDER FACILITATING THE CONNECTION BETWEEN PARTIES. INK.HK ASSUMES NO LIABILITY WHATSOEVER IN RELATION TO THE LOAN AGREEMENTS, THE ACTIONS OR OMISSIONS OF THE BORROWER OR THE LENDER, OR ANY LOAN INTERMEDIARIES INVOLVED IN THE TRANSACTIONS. THE PLATFORM SERVES AS A CONDUIT TO ENABLE TRANSACTIONS AND INTERACTIONS; HOWEVER, WE ARE NOT A PARTY TO, NOR ARE WE RESPONSIBLE FOR, ANY AGREEMENT OR TRANSACTION MADE BETWEEN USERS OF THE PLATFORM.


The information we collect about you

We collect the following types of information about you:

  • For individual users, account and profile information that you provide when you register for an individual account or sign up for our products or services, for example your name, date of birth and gender, residential address, email address, telephone number(s); for business users, account and profile information that you provide when you register for a business account or sign up for our products or services, for example your name, business name or trade name, registered address, business’ jurisdiction of incorporation, business controller’s information, email address, telephone number(s) and business documents; and for shareholders and business controllers, your passport or national ID and proof of address provided by the relevant business user when they register for a business account or sign up on behalf of the business for our products or services (collectively, “Account Data”);
  • Information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
  • Communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data”);
  • Information about your device or connection, for example your internet protocol (IP) address, log-in data, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our products or services and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data”);
  • Blockchain addresses; Details of transactions with the Protocol you carry out through our Platform; and Information about your use of or visit to our Platform, for example your clickstream to, through, and from our Platform, products you viewed, used, or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page. (collectively, “Usage Data”).

Without this information, we may not be able to provide you with our Services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

We collect the above information when you provide it to us or when you use or visit our Platform. We may also receive information about you from other sources as necessary, including:

  • People you know – such as
    • your joint account holders
    • your referees; and
    • other people you appoint to act on your behalf
  • Businesses and other organisations – such as
    • your employer and/or company, business or organisation you represent or is related to you
    • other financial institutions and financial service providers
    • credit bureaus or credit reference agencies, credit protection providers, rating agencies, debt collection agencies, fraud prevention agencies and organisations
    • service partners, such as advertising and market research companies and social media platform providers
    • regulatory and other entities, such as tax authorities, law enforcement or authorities imposing financial sanctions
  • Our corporate and business clients – where you receive the benefit of our services in relation to our contract with the company, business or organisation you interact with.
  • Publicly available resources – such as online registers or directories or online publications, social media posts and other information that is publicly available
  • Blockchain service providers – such as RPC provider, cryptocurrency wallet provider
  • Cryptocurrency exchanges – such as Binance, Coinbase

We do not collect sensitive data. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, health, or sexual orientation.


Third-Party Information Collection

When you access the Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Analytics companies.
  • Your device manufacturer.
  • Your service provider.

When you use the Platform, certain third parties may use automatic information technologies to collect information about your on-chain activities. These third parties may include:

  • Blockchain explorers.
  • Decentralized infrastructure providers.
  • Your Web3 Service.
  • Any DAO or other entity that controls, interacts with, or provides services related to the Protocol.
  • Any other party with access to the underlying blockchain.

These third parties may use tracking technologies to collect information about you when you use the Platform or the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible party directly.

Important Note About Public Blockchains

Information stored on a blockchain may be public, immutable, and not easily removed or deleted. Your transactions and addresses may reveal information about you, and information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. We do not control how other parties may use this information and cannot provide you any protection related to such information.   You acknowledge that you are at your own risks in respect to information stored on a blockchain.

How we use information we collect

We only use your personal information and business information where the law allows us to. We use your personal information and business information only where:

  • to provide you with the Platform, and any other information, products, or services that you request from us.
  • to provide customer support and personalised features, and to protect the safety and security of our Platform;
  • it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests;
  • you’ve given us express consent to do so for a specific purpose, for example we need to verify your ID via a selfie or video ID or we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
  • we need to comply with a legal or regulatory obligation.

If you have given us consent to use your personal information and business information for a specific purpose, you have the right to withdraw your consent at any time by contacting us (please refer to contact information below), but please note this will not affect any use of your information that has already taken place.

We do not share your personal information and business information with any company outside our group for marketing purposes, unless with your express specific consent to do so. For visitors to or users of our Platform who are located in the European Union, we have set out our legal basis for processing your information in the Legal Basis List at the end of this Policy.

How we share information we collect

We share information with other companies in our group in order to operate our Platform and to offer and improve our Services.

We share information with third parties that help us operate, provide, support, improve, and market our products and services, for example third-party service providers who provide identity verification services, website and application development, data storage and backup, infrastructure, customer support, business analytics, and other services.

As part of our customer support service, we are using new and innovative technologies to help us address your inquiries, provide assistance, and ensure a satisfactory customer experience. These customer support tools may involve the use of automated systems, algorithms, or machine learning technologies to analyze and process support interactions. The AI-based services may help us identify common issues, improve response times, and ensure accurate and consistent information is provided to our customers.

To enable us to manage and track your support requests efficiently using these new and innovative technologies, we may need to share certain personal information submitted by you to our customer support team as part of your support request with the relevant third-party IT providers and/or systems.  Please note we will not be using these technologies for any decision-making purposes.

Any third-party service providers who have access to your personal information and business information will only be granted such access for the purpose of performing their services and in compliance with applicable laws and regulations. We require these third-party service providers to maintain confidentiality and security of all personal information and business information that they process on our behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of your personal information and business information.

We take reasonable steps to confirm that all third-party service providers that we engage process personal information and business information in the manner that provides at least the same level of protection as is provided under this policy. Where any third-party provider is unable to satisfy our requirements, we will require them to notify us immediately and we will take reasonable steps to prevent or stop non-compliant processing.

We may share personal information and business information on an aggregated or de-identified basis with third parties without restriction, except as prohibited by applicable law.

If you use any third-party software in connection with our Services, for example any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this Policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.

Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.

We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.

If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information and business information may be disclosed and/or transferred to a third party in connection with such a transaction. We will notify you if such a transaction takes place and inform you of any choices you may have regarding your information.

How we store and secure information we collect

We use data hosting service providers based in United States to host the information we collect. Your account is password protected to protect the security and integrity of your personal information and business information.

Access to your personal information and business information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so and our information collection, storage, and processing practices are reviewed regularly.

While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

How we transfer information internationally

We collect information globally and primarily store that information in Hong Kong. We may transfer, process, and store your information outside your country of residence where we or our service providers operate for the purpose of providing our products and services to you.

Some of the countries in which our companies or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information.

Your rights

You have the right to:

  • be informed of what we do with your personal information;
  • request a copy of personal information we hold about you;
  • require us to correct any inaccuracy or error in any personal information we hold about you;
  • request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
  • object to or restrict the processing by us of your personal information (including for marketing purposes);
  • request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
  • withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).

Our Platform enables you to update certain information about yourself, for example you may change your personal information and business information by updating your user profile or changing your user settings in your account.

You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications or by contacting us. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.

As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

Any request under this Section will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.

Changes to this policy

We may amend this policy from time to time by posting the updated policy on our website. You are responsible for periodically visiting this privacy policy to check for any changes. By continuing to use our Platform and Services after the changes come into effect, you agree to be bound by the revised policy

Policy towards children

Our products and services are not directed to individuals under 18. We do not knowingly collect personal information and business information from individuals under 18. If we become aware that an individual under 18 has provided us with personal information and business information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 18.

Contact us

Should you have any questions or concerns regarding your personal data, or wish to exercise any of your data protection rights, please contact us at ink@inkfinance.hk or to Ink.HK office through registered mail:

INK.HK Technologies Limited
Registration number
3298823

Incorporation Country and Registered office
10/F China Merchants Building
303-307 Connaught Road Central
Sheung Wan, Western District, Hong Kong Island
Hong Kong, PRC

If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed.  Please include your full name and a detailed description of your request or concern in your communication. This will help us to accurately identify your data and respond to your query efficiently.

Last updated: [January 2024]

Cookies policy

Cookies are small text files that are placed on your device by a web server when you access our website, subject to your consent. We use cookies to distinguish you from other users, to identify access and monitor web traffic on our website https://inkhk.app.inkfinance.xyz. Cookies also help us to provide you a good experience and improve our products and services.

LEGAL BASIS LIST

  • We process: Account Data. For the purpose of: Registering you as a user on our Platform. Legal basis: To perform our contract with you.
  • We process: Account Data, Support Data, Technical Data and User Content. For the purpose of: Enabling you to use our products and services. Legal basis: To perform our contract with you.
  • We process: Account Data, Preference Data. For the purpose of: Notifying you about changes to our products, services or terms. Legal basis: To perform our contract with you.
  • We process: Technical Data, Usage Data. For the purpose of: Administering and maintaining safety and security of our platform. Legal basis: To perform our contract with you.
  • We process: Support Data, Technical Data, Usage Data. For the purpose of: Studying usage of our products and services. Legal basis: Legitimate interest to improve our Platform, products and services.
  • We process: Account Data. For the purpose of: Gathering feedback on our products, services or features. Legal basis: Legitimate interest to improve our Platform, products and services.
  • We process: Account Data, Preference Data. For the purpose of: Providing information on products and services that may be of interest to you. Legal basis: Consent, which you may withdraw at any time.