B&A Group Limited (“B&A Platform”, or “we” or “our” or “us”, which shall include its holding companies, subsidiaries, directors, investors, employees, etc.) understand the importance of privacy and work hard to keep your personal data confidential. This Privacy Policy, together with our User Registration and Information Service Agreement (the "Service Agreement" or the “Agreement”), outlines how we collect, process and use your personal data. In this Privacy Policy, "personal data" refers to information that may identify an individual, such as name, address, e-mail address, trading information, and banking details, but does not include anonymized and/or aggregated data that does not identify a specific user.
This Privacy Policy is written in English and translated into Chinese. In case of any discrepancy between the Chinese and English versions, the English version shall prevail.
By entering our Service Agreement, you agree to be bound by this Privacy Policy and any amendments thereafter and authorize the collection, processing and communication of your in accordance with provisions described in this Privacy Policy. If there is any conflict or discrepancy between this Privacy Policy and the Service Agreement, the Service Agreement shall prevail.
To provide our services in compliance with any applicable law and the rules, guidelines and instructions from time to time issued by regulatory authorities, we must require you to provide certain information about yourself, including identification documents, financial information (such as details about your identity, e-commerce sales, beneficiary account, etc.) and any other information or documents that may be required periodically by applicable laws and regulatory authorities. We will utilize the data provided by you in accordance with applicable data protection laws, including but not limited to, the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong). In principle, the information obtained by us should be used solely for providing our services and only with the scope necessary for such services. Unless we are under any legal obligation or any directive from a court with competent jurisdiction, or we need to do so to provide our services (such as rendering your personal data to our partners worldwide, e-commerce platform for verification and investigation, or the banks for fund processing), third parties should not have access to your personal date possessed by us. In other cases, we will obtain your consent before disclosing any of your personal data to any third party.
Your privacy is of utmost importance to us. At B&A Platform, we uphold the following fundamental principles:
We don’t ask for your personal information unless we truly need it.
We don’t share your personal information with anyone except for complying with the law, providing our services, or protecting our rights.
We limit access to your personal information to Affiliates and third-party service providers who need to know such information to provide you with services, or any third party who needs such information to comply with requirement relating to anti-money laundering, counter terrorist financing, and/or other applicable laws.
We maintain physical, electronic and procedural security methods to protect your personal information.
Please carefully review this Privacy Policy before registering a B&A Platform Account and providing us with your personal information. If you have any questions about how your data is protected, please don't hesitate to contact B&A Platform Customer Support. You may also consult your own legal representative who will be able to give you the best advice before establishing any relationship with us.
For the purpose of this Privacy Policy, if you have registered a B&A Platform Account or otherwise are using B&A Platform services, the term “B&A Platform”, “we”, “ours”, “B&A Platform Account”, and “Service Provider” are as defined in our Service Agreement. (If you are just a visitor to our website, the term “B&A Platform” refers to B&A Group Limited.)
Like most website operators, B&A Platform collects non-personally identifiable information typically provided by web browsers and servers, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose in collecting non-personally identifiable information is to better understand how platform visitors use our website. B&A Platform may periodically publish aggregate non-personally identifiable information, such as report on website usage trends. When you log in, B&A Platform may also collect your personally identifiable information like Internet Protocol (IP) addresses. B&A Platform will use your IP addresses strictly in accordance with the rules outlined below for personally identifiable information.
You may provide us with your personal data by filling in forms from our website (e.g. B&A Platform Account Registration Form), or by contacting us (for example, by e-mail or telephone). The data you provide may include information about other persons who are beneficial owners of our services. In the following situations, you need to provide personal information with us:
(1) upon registration for a B&A Platform Account.
(2) when you log in your B&A Platform Account.
(3) when you submit any instruction through your B&A Platform Account.
(4) when participating in contests, promotions or surveys; and
(5) when reporting an issue or requesting for support.
You can always refuse to supply such personal data, but it may prevent you from using our services.
We collect the personal data you provide directly to us when you apply for a B&A Platform Account, perform any transactions on our platform, or use other services provided by us. This may include:
(1) your contact information (e.g., name, email address, phone number, billing or mailing address);
(2) bank and credit account information, including PSP account information, list of virtual bank accounts owned by or related to you, beneficiary account details (including routing number and bank code);
(3) corporate information (e.g. company name, corporate documents, business information or tax information etc.);
(4) IP address.
(5) authentication (e.g., photograph, other information requested to verify your information, including copy of valid ID document or corporate documents);
(6) public criminal records;
(7) national or tax identification number;
(8) nationality.
(9) date and place of birth.
(10) risk rating and risk level of you.
(11) details of any transactions for using any services which shall include the disbursement information, transaction date, transaction ID, transaction type, destination bank account, destination customer ID and destination currency.
(12) any other information that you choose to provide to us (e.g., if you send us an email/otherwise contact us);
(13) calls/emails/other correspondence; and
(14) information from Cookies and other tracking technologies as listed above and as described in the section below entitled “Cookies”.
You shall be responsible for providing us with accurate and up-to-date information, otherwise we may not be able to provide any service to you. You shall also provide all information that we deem necessary and appropriate to verify that the details you have provided are true, accurate and complete.
If you are required to provide information about shareholders or beneficial owners of your business, you hereby acknowledge and confirm that you have obtained their consent to provide his/her information to us. This may include:
(1) contact information, such as name, home address, and email address.
(2) e-commerce platform account information, such as username and password.
(3) financial information, such as bank account numbers, bank statement, and trading information.
(4) authentication information, such as images of government issued ID, passport, national ID card, or driving license. Depending on nationality, the information request may vary; and
(5) proof of residence information, such as Utility bill details or similar information.
When providing our services, we may collect and process personal data of third parties related to your business or counterparties. You shall make sure to respect the privacy rights of any third parties, including your counterparties and other individuals related to your business, ensure proper disclosure of collection and use of third party data; with respect to such data, we are acting as your data processor, and we will process such data in accordance with the terms of the Service Agreement and act in accordance with your lawful instructions.
We will only use your personal data to:
(1) process your transactions, including transfer funds to or from any country or region in the world in accordance with the local laws;
(2) perform necessary controls and inspections in accordance with money laundering/terrorist financing and know your customer requirements under any applicable law (which shall include the Anti-Money Laundering and Counter Terrorist Financing Ordinance (Cap.615 of the laws of Hong Kong), our internal control policies, and also the needs of any law enforcement agencies;
(3) analyze our website usage and improve our website and services.
(4) assist us in responding to your customer service requests and support needs.
(5) fulfill our obligations under any agreement to which we are a party, particularly the agreements with e-commerce platform, other payment processors or banks.
(6) verify the account you have registered on the e-commerce platform;
(7) compare the identity that you have provided to us with the identity you provided to the e-commerce platform for verification purpose and to detect and reduce account takeover;
(8) identify any abusive behaviour by you.
(9) identify clusters of e-commerce platform accounts and virtual bank accounts owned by you that have been identified as exhibiting abusive behaviour by e-commerce platform.
(10) for purposes of analysis, modelling, research, risk management, remediation or prediction, identify fact patterns associated with account takeover and other fraudulent activities, and detect malicious actors’ activities as earlier as possible or with higher certainty, and take related actions in compliance with the law;
(11) verify the validity of cross border disbursements made by you.
(12) verify your identity and the bank account(s) provided by you.
(13) for the purposes of assessment, analysis and risk management, identify fact patterns associated with fraud and malicious actor;
(14) identify, prevent and reduce fraud, illegal activities or abusive behaviour in e-commerce platform or involving yourself;
(15) introduce our services to you. The email address you provide may be used to communicate information and updates related to the service you are using, as well as to send company news, latest developments, and information related to similar products and services we may offer.
(16) manage contests, surveys or other website features announced from time to time on our website.
We will not use your personal data for any purpose other than those specified above, and we will delete usage information related to platform data, especially data relating to your disbursement and e-commerce activities, when it is no longer needed.
We only disclose your personal data (a) to legal and regulatory authorities as required by applicable law or court order with competent jurisdiction; and (b) to our employees, service providers and affiliated organizations. We assure you that such disclosure shall be on a need-to-know basis, and receive undertaking from relevant parties that they agree to keep such data confidential and will be subject to this Privacy Policy.
(1) Disclosure to Third Parties
In processing your transactions, we may share some of your personal data (on a need-to-know basis) with our service providers. Your information will not be sold, exchanged, or shared with any third parties without your prior consent, except to provide services you need or as required by law or court order with competent jurisdiction. By using our services, you accept the contents of this Privacy Policy and agree to our disclosure of your personal data in accordance with this Privacy Policy.
Our service providers are contractually obligated to protect and use such information solely for the disclosure purposes, except required or permitted by law. We strive to ensure that such third parties are subject to protective clauses that are consistent with this Privacy Policy and all applicable laws, rules, guidelines and directives from time to time issued by any relevant regulatory authority.
We may need to disclose certain transaction data provided by you or your e-commerce platform to our counterparts in China to ensure that the funds can be remitted to your designated account in China in compliance with all legal requirements under the laws of the People’s Republic of China.
(2) Disclosure to Legal Authorities
We may share your personal data with law enforcement agencies and other government or regulatory authorities in the following circumstances:
(a) we are compelled by subpoena, court order, or other legal procedure; or
(b) we have reasonable grounds to believe that the disclosure is necessary to prevent personal injury or financial loss; or
(c) disclosure is necessary to report suspected illegal activity; or
(d) disclosure is necessary to investigate violations of this Privacy Policy or our Service Agreement.
Our services are global in nature and data may be stored and processed in any country where we conduct business or cooperate with third-party service providers. That means data may be transferred and stored outside the boundary of Hong Kong. Data we collect may be transferred to and/or stored at a destination outside Hong Kong, which may be subject to different data protection rules than Hong Kong. Our staff will do their best to meet your request and provide support services. Meanwhile, we will take measures to ensure that any such transfer complies with the laws of Hong Kong and that your data remains protected according to the standards described in this Privacy Policy. By submitting your personal data to us, you agree to our transmission, storage or processing of data in accordance with this Privacy Policy. We will take reasonable methods to ensure that the security of your data in accordance with this Privacy Policy and the applicable laws.
We will take appropriate measures to prevent unauthorized access, use, alteration or destruction of personally identifiable information, including computer security system and secured files. We will not sell your personally identifiable information to anyone. For purposes of providing services and to comply with anti-money laundering, counter-terrorism financing and other legal requirements, we may disclose your personally identifiable information to our affiliates or third-party service providers. Some of these affiliates and third-party service providers may be located outside of your home country. We may also provide your information to government authorities, compliance departments, law enforcement agencies, court and others to meet legal requirements, prevent criminal activities, or for other lawful purposes. By using our services, you consent to the disclosure of your personally identifiable information to the aforementioned entities. We may contact you through your personal contact information, and communicate account issue, updates, improvements, or promotional services with you. If we contact you via phone, please note that our call may be recorded for security and training purposes.
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. B&A Platform uses cookies to identify and track visitors, enabling the website to remember visitor’s operation and preferences for a period of time. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our websites.
You may choose to accept or reject cookies. If you reject the cookies, you may not be able to use some functions of our website and access some online services on our website.
B&A Platform may, at its sole discretion, change this Privacy Policy from time to time. We encourage you to visit this page periodically to review relevant changes. If you continue to use our website after any amendment in this Privacy Policy, it will be deemed that you accept such changes.
We shall in no event be liable to you in respect of any claims, losses, damages, expenses (including reasonable legal fees) arising out of or in connection with the use and/or disclosure or dissemination of the user data in accordance with this Privacy Policy and any consents that you may have otherwise provided to us.
This Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong.