Privacy policy

Last updated: June 20, 2024


Introduction

In accordance with relevant laws and regulations, FILL EASY (the “Company” or “we”) is publishing this Personal Information Privacy Policy (the “Policy”) to explain how we handle your personal information. The Company refers to FILL EASY (Guangzhou) Personal Information Technology Co. Ltd. and FILL EASY LIMITED.

The Company is committed to protecting the privacy and security of your personal information. As the personal information controller of this personal information, the Company is responsible for ensuring the lawful processing of your personal information.

Please make sure to read this Policy and any privacy policies that we may provide on specific occasions when collecting or processing personal information about you to understand how and why we use such information.


Definitions

The definition of “personal information” aligns with the definition of personal information and personal data as defined in relevant laws and regulations.

The definition of “sensitive personal information” aligns with the definition of sensitive personal information as defined in relevant laws and regulations.

The definition of “processing” aligns with the definition of processing as defined in relevant laws and regulations.

“Personal Information Controller” in mainland China refers to an organization or individual who independently determines the purpose and means of processing personal information in personal information processing activities; in the Hong Kong Special Administrative Region of China, this term also includes “data users,” which refers to individuals or entities that collect, possess, process, or use personal data alone or jointly with others or exercise control over such data. The Company is considered a personal information controller when it processes your personal information. However, in certain cases, the Company’s customers may also act as personal information controllers when they process your personal information in the context of purchasing services from the Company. The customer and the Company may act as joint controllers or separate controllers depending on the purpose of the processing.

“Recipient” refers to organizations or individuals who receive personal information across borders from the personal information processor.

“Relevant Laws and Regulations” in mainland China refer to laws and regulations such as the Cybersecurity Law of the People’s Republic of China, the Data Security Law of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China, and other applicable laws and regulations; in the Hong Kong Special Administrative Region, it refers to laws and regulations such as the Personal Data (Privacy) Ordinance.

This policy is drafted in compliance with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong (the "Ordinance"). We are committed to ensuring that your privacy is protected.


Information we collect

We may collect personal information from you when you use our services, sign up for our newsletters, or engage with our website. Personal information we collect may include but is not limited to your name, contact information including email address, demographic information such as postcode, preferences, and interests, and other information relevant to customer surveys and/or offers.


Use of information

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

a) To facilitate and process transactions that take place on our platform.

b) To communicate with you, including responding to your enquiries and/or sending you important notices.

c) For record-keeping purposes.

d) To improve our products and services.

e) To periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.


Protection of personal data

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.


Sharing Personal Information

We do not sell, trade, or rent your personal information collected by us through this website to others. However, we may share personal data with trusted third parties to assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential and to comply with corresponding standards of security and confidentiality.


Your rights

You have the right to request access to and correction of information held by us about you. If you would like to exercise this right, please contact us at our specified address.


Changes to our privacy policy

We reserve the right to amend this Privacy Policy from time to time and the updated versions will be posted on our website and date stamped so that you are aware of when the Privacy Policy was last updated.


Fundamental Principles of Personal Information Protection

We must:

  • Use the personal information we hold about you in a lawful, fair, and transparent manner.
  • Only collect the personal information that we hold about you for such valid purposes as we have clearly explained to you and do not use the personal information that we hold about you in any way incompatible with such purpose.
  • Collect and use personal information that we hold about you for the purposes of which we have informed you and only for those purposes.
  • Ensure the accuracy of the personal information we hold about you and keep it updated.
  • Only keep the personal information we hold about you for the time necessary to fulfil the purposes we have informed you about.
  • Securely store the personal information we hold about you.

What personal information does the Company process, for what purposes, and for how long is it processed?

What personal information does the Company process?

The personal information processed by the Company includes the following categories of personal information:

  • Identity verification: Identity card information (citizen identification number, name, ethnicity, gender, date of birth, address, validity period, issuing authority, passport) and passport information (passport number, English name, name, country code, date of birth, date of issue, date of expiry, personal number, photo).
  • Other information: Profile of the enterprise’s personnel, all roles of the personnel, all companies owned by the personnel, all partners of the personnel, enterprises controlled by the personnel, all historical roles of the personnel, search of negative news.

Among them, the personal information of “identity verification” as specified above shall belong to your “sensitive personal information.”

Why does the Company process your personal information?

The Company processes your personal information primarily for the following purposes:

The Company processes your personal information to assist its clients (financial institutions, etc.) in user identity verification and credit investigation to help its clients verify identities, assess risks, comply with anti-money laundering legal requirements, provide financial services to mainland individuals in Hong Kong, prevent financial fraud, protect the involved financial institutions and their clients, and comply with applicable financial laws and regulations.

Sensitive Personal Information

Please note that the disclosure or illegal use of sensitive personal information may easily lead to infringement of your dignity or pose risks to your safety and the security of your assets.

The Company may need to process sensitive personal information provided that:

  • It is necessary for your identity verification and credit investigation.

How does the Company process your personal information?

The Company collects personal information necessary for identity verification and credit investigation from legal sources.

The Company utilizes personal information by querying other data sources and conducting comparative analysis to verify identities, assess risks, etc.

The Company transfers personal information to FILL EASY LIMITED to ensure the data will not be tampered with during the transfer process.

How long will the Company process your personal information?

The Company will not store your personal information for longer than necessary to fulfil the purposes for which it was collected. Once the personal information is no longer necessary for the Company, or you withdraw your consent for us to process your personal information, or in other cases where the law requires us to delete it, we will delete your personal information. If the deletion of personal information is technically difficult to implement, we will cease the processing activities of it except for storage and necessary security measures.


Will the Company transfer your personal information to countries outside the People's Republic of China?

We may need to transfer your personal information to our affiliated company FILL EASY LIMITED in Hong Kong using dedicated lines. You can contact us by sending emails to matthewlee@fill-easy.com or mailing to Room 979, 9/F, 19 Science Park West Avenue, Sha Tin, New Territories, Hong Kong.

Purpose of transfer: The Company and the Recipient collaborate to assist financial institutions, airports, and the Special Administrative Region government registered in Hong Kong with user identity verification and credit investigation. To ensure the data will not be tampered with during the authentication or verification process, the Company must transfer the verified and investigated user information to the Recipient, who will then transfer it to financial institutions, airports registered in Hong Kong, and the Hong Kong Special Administrative Region government to help them verify identities, assess risks, comply with anti-money laundering legal requirements, provide financial services to mainland individuals in Hong Kong, prevent financial fraud, protect the involved financial institutions and their clients, comply with applicable financial laws and regulations, and so on.

The types of personal information being transferred are:

  • Personal identification information: Identity card (citizen identification number, name, ethnicity, gender, date of birth, address, date of expiry, issuing authority, photo), passport (document number, English name, name, country code, date of birth, date of issue, date of expiry, personal number, photo)
  • Other information: Profile of the enterprise’s personnel, all roles of the personnel, all companies owned by the personnel, all partners of the personnel, enterprises controlled by the personnel, all historical roles of the personnel, search of negative news.

If you wish to exercise your rights related to your personal information, please send an email to matthewlee@fill-easy.com or mail your requests to Room 979, 9/F, 19 Science Park West Avenue, Sha Tin, New Territories, Hong Kong.

Due to the necessity of identity verification and credit investigation, the personal information being transferred includes sensitive personal information such as identity card information and passport information. We will take technical and managerial measures to ensure the security of your sensitive personal information to the best of our abilities. However, please be aware that there is no risk-free online environment. In the event of a personal information security incident, we will take remedial measures promptly to minimize the impact on your rights and interests.

The Company has obtained the filing numbers of the standard contract for the cross-border flow of personal information among the Greater Bay Area (Mainland, Hong Kong) from the Office of the Government Chief Information Officer of the Government of the Hong Kong Special Administrative Region of the People's Republic of China and the Cybersecurity Administration of China (Guangdong Province) in Mainland China respectively. The filing numbers are as follows respectively:

  • Hong Kong: HK 2024000018; and
  • China Mainland: 粤港合同备202400009.

Your rights to personal information and privacy

Your rights to personal information and privacy include:

  • The right to access and copy your personal information;
  • The right to update or correct the inaccuracy of your personal information;
  • The right to request the Company to explain the rules on the handling of your personal information;
  • The right to block or delete your personal information collected by us;
  • The right to restrict or refuse our processing of your personal information; and
  • The right to request us to provide a copy of your personal information and have that copy transferred to a designated third party.

You can exercise these rights by contacting us via email at matthewlee@fill-easy.com or by mailing your requests to Room G07, Software Building South 402, Guangzhou Nansha Information Technology Park, No. 2 South Huanshi Road, Nansha District, Guangzhou. To help protect your privacy and to maintain the security of your personal information, we may take steps to verify your identity to confirm that it is you requesting before we grant you access to the information. The Company shall have the right to refuse to honor your request if your requests are beyond your rights under the applicable laws.

Similarly, if we collect and process your personal information with your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of any processing conducted before your withdrawal nor will it affect any processing of your personal information based on legal bases other than your consent.

The Personal Information Protection Law of China also grants close relatives of deceased individuals the right to access, copy, correct, delete, and exercise other rights over the deceased person’s relevant personal information for their own legitimate and lawful interests. If you are not the data subject yourself but you fall within the definition of the close relatives of the data subjects of us, please provide proof of your relationship with the deceased individual and explain the reasons for your request to comply with applicable laws and regulations.


Changes

We may update this policy from time to time to align with changes in laws, technology, or business developments. When we update this policy, we will take appropriate measures to notify you, and the method of notification will be commensurate with the significance of the revisions. If we make substantial modifications and it requires your consent under applicable personal information protection laws, we will seek your consent.

You can view the last update date of this policy by referring to the “Last Updated” section displayed at the top of this policy.


Contact

If you have any enquiries or complaints about our use of your personal data, please contact us at:

  • Email: matthewlee@fill-easy.com
  • Address: Room 979, 9/F, 19 Science Park West Avenue, Sha Tin, New Territories, Hong Kong.

This Privacy Policy is governed by and construed in accordance with the laws of Hong Kong Special Administrative Region.