Privacy Policy

Data protection is of a high priority for ALGOGENE Financial Technology Company Limited (refer to "ALGOGENE" or "We"). In complying with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong, this Privacy Policy sets out matters relating to the collection and use of your personal data.

1. Definitions

Our data protection declaration is for the general public, as well as our customers, employees, agents and business partners. In this Privacy Policy, ALGOGENE uses the following terms:

A. Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

B. Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

C. Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

D. Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

E. Controller

Controller or controller responsible for the processing is the 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 personal data; where the purposes and means of such processing are determined by applicable law, the controller or the specific criteria for its nomination may be provided for by applicable law.

F. Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

G. Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

H. Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

I. Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.


A. Why ALGOGENE collects information including Personal Data

In order to better serve your particular needs, ALGOGENE may collect confidential information from and/or about you during the course of your relationship with ALGOGENE. This confidential information is collected through various methods including, but not limited to ALGOGENE’s platform(s), applications and websites. ALGOGENE may also obtain information directly from you and from third party sources. We may also use the standard "cookie" feature of major browser applications and other data capture mechanisms that allow us to store data about you including, without limitation, your visit to our platforms, applications and websites.

B. Specific information ALGOGENE collects and how it is collected

i. General

ALGOGENE collects several types of information when a data subject or automated system interacts with ALGOGENE, its platforms, applications, websites and service offerings. This information includes, for example:

  • Contact information including name, email, phone and address of individual users of ALGOGENE’s platforms, applications and websites
  • Organization/Company name and customer type of individual users of ALGOGENE’s platforms, applications and websites
  • National ID (e.g. driving license, Passport, tax Id) of users of ALGOGENE’s platforms where required by applicable law
  • The browser types and versions used
  • System information related to the accessing of ALGOGENE’s platforms, applications, websites and services including, without limitation, the website from which an accessing system reaches our website (so-called referrers), the date and time of access to the Internet site, an Internet protocol address (IP address), the Internet service provider of the accessing system, and any other similar data
  • Personal data of employees and agents relevant to their employment or work on behalf of ALGOGENE including, name, email, phone, address, passport information, date of birth, photo, marital status, spouse and dependent information, bank account details, emergency contact information, salary information and past employment history

ii. Cookies

The Internet pages of ALGOGENE use cookies which allows visited Internet sites and servers to differentiate the individual browser of the dates subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID. Through the use of cookies, ALGOGENE can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow ALGOGENE to recognize our website users. The purpose of this recognition is to make it easier for users to utilize ALGOGENE’s website. The website user that uses cookies, does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. The data subject may, at any time, prevent the setting of cookies through the ALGOGENE website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

iii. Information about data subjects from third parties

ALGOGENE obtains information including personal data from third parties, including

  • Personal data about data subjects that are individuals that are employees or agents of ALGOGENE’s institutional customers
  • Service providers to ALGOGENE related to employment or retention of ALGOGENE’s employees or agents

In such cases, ALGOGENE is a Processor and not a Controller and ALGOGENE processes the information on behalf of or for the benefit of the Controller and relies on the Controller for obtaining consent or other lawful purpose for processing the information.

3. What ALGOGENE Does with the Information it collects

ALGOGENE uses confidential information including Personal Data in:

  1. authenticating and verifying authorized use of our platforms, applications, websites, and services
  2. improving, offering and administering platforms, applications, websites, and services
  3. giving information about ALGOGENE's related or new products or services
  4. using and disclosing confidential information and Personal Data in aggregate or statistical form which is not identifiable with the submitter, or as permitted/required by law

4. What is the lawful basis for ALGOGENE controlling or processing the information

ALGOGENE will ensure that one of the following lawful bases exist for all confidential information collected, including, Personal Data

  1. Information is required to be collected by contract: where the processing is necessary for the performance of a contract
  2. Compliance with legal/regulatory obligation: where the processing is necessary for ALGOGENE to comply with a legal obligation under applicable law
  3. Legitimate interest: including fraud prevention and transferring personal data within a group of companies or processing of personal data strictly necessary and proportionate for the purposes of ensuring network and information security
  4. Consent: where the individual has given consent for their personal data to be processed for a specific purpose

5. What is the Period which ALGOGENE will keep the information

The criteria used to determine the period of storage of confidential information including personal data is the relevant lawful purpose for which it is held or 10 years, whichever is later. If the storage of the data is no longer required as previously stated then the confidential information including personal data is blocked or erased.

6. Rights of the data subject for information it collects

A. Right of confirmation

Each data subject shall have the right to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact ALGOGENE’s Data Protection staff at the contact information stated herein.

B. Right of access

Each data subject shall have the right to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the data subject may have access to the following information:

  1. the purposes of the processing
  2. the categories of personal data concerned
  3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  5. the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
  6. the existence of the right to lodge a complaint with a supervisory authority
  7. where the personal data are not collected from the data subject, any available information as to their source
  8. the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer

C. Right to rectification

Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

D. Right of restriction of processing

Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

  1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  2. The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  3. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  4. The data subject has objected to processing pursuant to pending the verification whether the legitimate grounds of the controller override those of the data subject.

E. Right to withdraw data protection consent

Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time. If a data subject wishes to exercise the rights stated herein, he or she may, at any time, contact ALGOGENE’s privacy staff in writing at the contact information provided above.

If you wish to access or correct your personal data held by us, please submit a request to:

7. Data protection

To help ensure the security of your confidential information that you submit to us via our platforms or Sites that use HTTPS , we use security software to encrypt the information before and during its transmission through the Internet. We allow information to be submitted for transmission only if your browser is compatible with our security software. If your browser is not compatible, you will receive a message indicating your transaction cannot be completed because of the security risk.

E-mail messages are not secure. Our security software does not encrypt e-mail messages. Please keep in mind that transmitting information via the Internet is never completely secure and that, therefore, any information submitted may be intercepted, viewed, collected, used, altered, copied or disclosed by others. We are not responsible for the security or confidentiality of communications you send to us (or that we send to you) through the Internet.

8. Links to Other Web Sites

ALGOGENE’s applications and websites may contain links to other websites and applications of third parties. Please note that when you click on one of these links, you will be accessing a website or application that ALGOGENE does not control and which may be governed by privacy policies and practices that differ from ALGOGENE’s. ALGOGENE is not, and will not be, responsible for the privacy policies or practices of third parties or the content or security of any third-party websites and applications.