Last updated on 1/21/2021
1. GENERAL INFORMATION
2. PERSONAL DATA
2.1 Under the PDPA, "personal data" means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which an organisation has or is likely to have access.
2.2 The types of personal data that we collect depend on the circumstances. Common examples of personal data that we may collect include:
· full legal name,
· home address,
· email address,
· mobile phone number,
· proof of identity (e.g.,driver’s license, passport, or government-issued identity card),
· date of birth,
· bank account details and/or credit card numbers,
· online identifiers (e.g. IP address),
· device and other logging information,
· transaction and/or payment related information, and
· any information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering ("AML")laws.
3. COLLECTION OF PERSONAL DATA
4. PURPOSES OF COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4.1 We only collect, use and disclose your personal data to the extent necessary for the purposes described below, to the extent allowed under the PDPA.
4.2 We may collect, use, and/or disclose your personal data for one or more of the following purposes:
(a) to verify your identity;
(b) to respond, handle and process queries, requests, applications, complaints and feedback from you;
(c) to provide you with the Services, including processing, monitoring and fulfilling your instructions and to administer, improve and provide the Services;
(d) to provide you with notices, including general updates and market updates, or information about the Services for marketing purposes;
(e) to conduct research, statistical analysis and other development activities to improve our Services;
(f) to provide you with customer and technical support and manage your relationship with us;
(g) to monitor and prevent illegal activities (e.g. fraud, money laundering);
(h) to monitor or improve IT and network security;
(i) to prevent the misuse of the Services;
(j) to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority to the extent required;
(k) to protect and enforce our contractual and legal rights and obligations; and
(l) any other purposes for which you have provided the personal data.
4.3 We may disclose your personal data for the following purposes:
(a) where such disclosure is required for performing obligations in the course of or in connection with the Services requested by you; or
(b) to third parties including our agents, service providers, advertisers, and related organisations for one or more of the above purposes.
5. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
We will make reasonable security arrangements to guard your personal data from any unauthorised access, collection, use, disclosure, copying, modification, disposal or similar data risks. However, we do not guarantee or warrant the security of any personal data which you provide us and we do not assume responsibility for any unauthorised use, collection or disclosure of your personal data by third parties which are wholly attributable to factors beyond our control.
6. ACCESS TOAND CORRECTION OF PERSONAL DATA
6.1 It is important that the personal data we hold about you is current, complete and accurate. If there are changes to your personal data, please update your personal data by (HUMBL Financial collects no personal data)
6.2 If you wish to make (a) an access request for a copy of the personal data which we hold about you or other information about our collection, use or disclosure of your personal data, or (b) a correction request to correct or update any of your personal data, please (HUMBL Financial collects no personal data) We may charge a reasonable administrative fee to cover the costs of responding to an access request and a written estimate of such fee will be provided to you.
6.3 We may require you to submit certain forms or provide certain information, including verification of your identity, before we are able to respond to any request about your personal data. We may also refuse your request with or without providing you with any reasons for doing so, to the extent permitted by the PDPA or any applicable law.
7. WITHDRAWAL OF CONSENT
7.1 You may withdraw your consent to the collection, use or disclosure of your data at any time by (HUMBL Financial collects no personal data). You acknowledge that the withdrawal of your consent may result in certain consequences, including our inability to continue providing any Services to you.
7.2 Upon the withdrawal of your consent, we shall no longer collect, use, and disclose your personal data, unless we obtain new consent from you or unless required or permitted under the PDPA (or other applicable law). For example, we may collect, use, and disclose your personal data to pursue our legitimate interests.
8. RETENTION OF PERSONAL DATA
8.1 Despite the withdrawal of your consent, we may retain personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted under the PDPA or other applicable law.
8.2 Personal data that is retained in our possession or under our control will be destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
9. TRANSFERS OF PERSONAL DATA
10. THIRD PARTY SITES AND SERVICES
10.1 Our Services may contain links to third-party sites or resources. Certain third parties may market or sell their own promotions or services on, or through, our Services. We have no control over the content and privacy practices of such third-party sites or resources. You should review the privacy policies of these third-party sites and resources in order to understand how your personal data may be used by these third parties. We do not endorse or otherwise accept any responsibility or liability resulting from such third party sites or resources, or third parties' terms and conditions or policies.
10.2 We may share your personal data with third party service providers (such as payment service providers) or our affiliates in order for them to offer services to you other than ours. Your acceptance and use of the third party service providers' and/or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider and/or our affiliate. You should review the privacy policies of these third party service providers and/or our affiliates in order to understand how your personal data may be used by them.
11. BUSINESS TRANSFERS