Dragon Gateway and its affiliates (hereinafter, “DG”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. “dragongateway.com” is being operated by Dragon Gateway, part of ICI Limited part of ICI Limited Unit A, 3/F Cheong Sun Tower 116-118 Wing Lok Street, Hong Kong including, without limitation, its owners, directors, investors, employees or other related parties.
your ability to correct, update and delete your Personal Information; and the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control.
Gathering and Use of Personal Information
We may collect your Personal Information if you use the Site or write to us. The types of Personal Information which we collect may include:
your photographic identification;
your phone number;
your e-mail address;
your banking details including account numbers;
your date of birth;
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your Personal Information to:
The email address you provide may be used to communicate information and updates related to your use of the dragongateway.com Services. We may also occasionally communicate company news, updates, promotions, and related information relating to similar products and services provided by dragongateway.com.
We do not perform behavioural tracking of a customer’s activities on our Website or across different Websites, nor do we allow third-party data collection through our Service.
EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information based on our contract with you to comply with our legal obligations, to satisfy our legitimate interests as described above and to satisfy on your consent.
DISCLOSING AND TRANSFERRING PERSONAL INFORMATION
We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information outside the EEA, as described below.
A.DISCLOSURES TO THIRD PARTIES
Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses.
B.DISCLOSURES TO LEGAL AUTHORITIES
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:
Compelled by subpoena, court order, or other legal procedure.
We believe that the disclosure is necessary to prevent physical harm or financial loss.
Disclosure is necessary to report suspected illegal activity.
C.INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We store and process your Personal Information in data centres around the world, wherever dragongateway.com facilities or service providers are located. As such, we may transfer your Personal Information outside of the EEA. Such transfers are undertaken in accordance with our legal and regulatory obligations.
Disclosure of Personal Information
We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, trusted service providers and contractors for these limited purposes.
We may also share Users’ Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organisation.
We may also share Users’ Personal Information with law enforcement or regulatory agencies, as may be required by law.
Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for dragongateway.com, unless otherwise required or permitted by law.
Correction⁄Updating⁄Deletion of Personal Information
You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at: email@example.com
You may also request the deletion or destruction of both the Account and Personal Information by sending an email to us at: firstname.lastname@example.org. dragongateway.com will action your request only where this is not inconsistent with its legal and regulatory obligations.
Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. We will also give you a copy of the Personal Information we have retained. There may be a minimal charge for accessing your Personal Information.
We have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Only authorised personnel of dragongateway.com have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.
Retention of Personal Information
You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise the right at any time by contacting us at email@example.com.
European Economic Area Users & Data
If you are a resident of the European Economic Area (the “EEA”), Dragon Gateway is the controller with respect to your personal information.
Legal bases for processing personal information
Our legal bases for processing under EEA Data Protection Law are described above in the sections entitled “What do we use your personal information for?”. We may process your personal information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of Dragon Gateway, our customers or others.
If you are a current customer residing in the EEA, we will only contact you by electronic means (email) with information about our services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.
If you are a new customer and located in the EEA, we will contact you if you are located in the EU by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to use your personal information in this way, or to pass your personal information on to third parties for marketing purposes, please contact us to opt-out immediately. You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting products and services
EEA residents have the following rights, which can be exercised by contacting us at [email address for Dragon Exchange that deals with Privacy] so that we may consider your request under applicable law.
All EEA users will have the following rights which can be exercised anytime by contacting us:
Right to withdraw consent. You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of Dragon Gateway’s processing based on consent before your withdrawal.
Right of access to and rectification of your personal information. You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by Dragon Gateway that is inaccurate. Your right to access and rectification shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.
Right to delete. You have the right to request deletion of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your personal information public and are obliged to delete the personal information, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your personal information that you have requested the deletion of any links to, or copy or replication of your personal information. The above is subject to limitations by relevant data protection laws.
Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.
Right to restriction of or processing. You have the right to restrict or object to us processing your personal information where one of the following applies:
You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
The processing is unlawful, and you oppose the deletion of your personal information and request the restriction of its use instead.
We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
You have objected to processing, pending the verification whether the legitimate grounds of Dragon Gateway’s processing override your rights.
Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
Notification of deletion rectification and restriction. We will communicate any rectification or deletion of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.
Right to object to processing. Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
Right to lodge a complaint. If you believe that we have infringed your rights, we encourage you to contact us first at firstname.lastname@example.org so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place. In the UK, the relevant data protection authority is the Information Commissioner’s Office (ICO).
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 0303 123 1113, email@example.com.
Storage of your personal information. Dragon Gateway will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.
Your rights to personal information are not absolute. Access may be denied when:
Denial of access is required or authorized by law;
Granting access would have a negative impact on other’s privacy;
Granting access would have a negative impact on other’s privacy;
To protect our rights and properties; and
Where the request is frivolous or vexatious.
We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact us by using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.
If we have not responded to you within a reasonable time or if you feel that your compliant has not been resolved to your satisfaction, you are entitled to make a complaint to the Hong Kong Privacy Commissioner for Personal Data. For EEA residents, you may refer to the above section for the complaint authority.
E-Mail : firstname.lastname@example.org