Privacy Policy (ENGLISH VERSION ONLY)

 

We are a marketplace to facilitate services between Corporate User and Banker User. Corporate User is defined as company or its representative or its authorized person signed up/potentially signed up as Corporate I n FinMonster Platform while Banker User is defined as a person who has/potentially has a BankerUser Account on the Platform, otherwise any individual visit our Platform before has definite role is classified as Potential Users (Collectively as “Users”). Users of our platform can explore opportunities to satisfy or serve their banking needs. We pledge to comply with the obligations and requirements of the Personal Data (Privacy) Ordinance and to respect the confidentiality of all personal or business information collected, stored and used by us.


In this Privacy Policy (“Policy”), “FinMonster” or “we” or “Company” refers to “Eureka Holding Limited” of 12B, Century House, 3 Hanoi Road, Kowloon, Hong Kong,, “Platform” means our website  www.finmonster.com, and the term "Personal Data" means any data relating directly or indirectly to a living individual which is capable of being used to identify that individual. This Privacy Policy covers the collection and use of any Personal Data that we gather when you are on this Platform and when you are using our services. Also, this Privacy Policy covers the use of any Personal Data that our business partners may share with us. This Privacy Policy does not cover personal data (if any) that may be collected elsewhere, including without limitation offline and on other sites linked to and from this Platform as well as the practices of third parties that the Company does not control or own, or individuals that we does not employ or manage.


By using this Platform, submitting information or using any of our services, you are agreeing with and accepting the terms and the practices outlined in this Privacy Policy. If you do not agree with and accept this Privacy Policy, please do not use or visit this Platform, provide information to us or use our services.



1           What information we collect about you

We collect the information (non-exhaustive) from you in different circumstances in below examples while using our Platform or from other sources.


  • The sign-up of new accounts as “Corporate User” or “Banker User”. (Collectively as “Users”)
  • The submission of new service requests as Corporate Users.
  • The provision of indicative offers as “Banker User” in relation to corporate’s new service requests.
  • The communication with us through telephone, email or face-to-face meeting.
  • Surveys that we use for research or business analytics 
  • Referral from third-parties such as our business partners or other registered users. 
  • Browsing our Platform, accessing market data, reading our content, blog, news, articles, any text in the Platform.
  • Application of financing or banking services through our Platform. 


Below are the examples (non-exhaustive) of data or information we collect during different circumstances. Lack of below information may result in our Platform being unable to provide our high-quality services. 


  • Basic information of Corporate User(e.g. company name, certificate of incorporate number, place of information, description, geographical coverage, email, phone number, staff number, industries, general financial information and favourite bankers, etc)


  • Contact information and Personal Data of Corporate User(e.g. contact person, business title, email, phone number, preferred languages and Wechat ID,etc)


  • Basic information and Personal Data of Banker User and his/her current job functions (e.g. banker’s name, name of financial institution he or she currently belongs to, job title, years in corporate banking, banking function, geographical location, specialized industry, preferred language, office address, email, phone numbers, target size of customer, business name card, link to his/her Linkedin profile, Wechat ID and favourite corporates)


  • Details of service request by Corporate User (e.g. requesting service, service location, service related amount, tenor, type of securities and market value, existing offer reference and excluded banks).  


  • Corporate business operation data including but not limited to financial information, legal information and company background. 


  • Information related to Users behaviour on browsing our Platform. 


The accuracy of data is largely depending on User’s input. While we do basic screening to check the consistency and integrity of information, it is User’s responsibility to verify and keep information up-to-date for the best matching of banking needs. We do not assume any loss or damage caused to any of our Users or third parties due to the provision of incorrect, inexact or incomplete information. 


We do not collect sensitive Personal Data such as your ethnicity, religion, politics, genetics, biometrics or health. 



2           How we use information we collect

We collect the information above including but not limited to the following purposes, used by us in or outside Hong Kong:


  • To register and operate your account as a Corporate User or Banker User with our Platform;
  • To understand your business background so as to introduce best-matching bankers for your on-going service request if you are a Corporate User;
  • To understand your professional background so as to introduce best-matching business needs from potential Corporate User if you are a Banker User;
  • To get back to your enquiries from time to time;
  • To facilitate the matching of banking requests raised by Corporate User, we may share some or all your corporate information and service request details to our Banker Users. Meanwhile, if you are our Banker User, we may also share some or all of your Personal Data such as contact to our Corporate Users. 
  • To analyse corporate’s general banking needs, demographics, market trends and industries on aggregated or de-identified basis for our continuous service improvement, provision of better matching and sharing of more relevant information for both our Corporate Users and Banker Users;
  • To enable our efficient on-going business operation;
  • To allow direct marketing subject to your consent;
  • To comply with legal and regulatory requirement.
  • To allow you to access and use corporate banking solution services and to provide quotes to you
  • To allow you access Platform provided information related to businesses
  • To analyse Users behaviour, market trends, information preference and Users demographics so that enable us to provide a better experience to you over using our services;
  • To allow us continuous serving you for the above and/or otherwise related to your use of the Platform.
  • To apply for any products or services provided by Third Party Vendors


3           How we store and secure information we collect

Though there is no 100% safe in Internet, we will take reasonable endeavours to ensure information security. Our Platform is designed to offer a high level of data protection. We use leading cloud hosting service provider Amazon Web Services to host our information we collect securely. The information is fully encrypted using SSL/TSL protocol and industry standard AES-256 encryption algorithm. Having said that, we cannot guarantee that information stored on the Internet is absolutely safe and secured. 


All Users’ accounts are password-protected. Please take your own responsibility to keep the password confidential and do not share it with others.


All information collected will be restricted for access by our staff who needs to provide services to our Users or conduct other necessary business operations on reasonable need basis. 


We keep information as it is reasonably necessary to fulfil the purposes we collected. Our information collection, storage and processing practices are reviewed regularly to meet the latest business need and regulatory requirements.


4           Disclosure of your information

We will keep the information collected confidential and will not disclose or transfer to third parties except for 


  • Our affiliates that provide services to or share services with FinMonster;
  • Our partners who are financial institutions, brokers, lenders;
  • Our service providers that support our business analytics, consultants, IT, legal services and marketing. 


For greater certainty, every authorization which you grant to us in this Privacy Policy, you also grant to any third party entities that we mentioned above for the purpose of maintaining or enhancing operation of Platform on our behalf, or for providing information technology support to us. We or any of the third parties above may be required to disclose our information collected to court, law enforcement body, government and regulator by the laws of Hong Kong SAR or other jurisdictions. To the fullest and maximum extent as is permitted under the applicable laws, you agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.


5           Third Party Vendors

FinMonster allow you to access the market data, advertisement or applying products and/or services provided by third parties (“Third Party Vendors”) through our Platform. Through your manual application and/or discretionarily access on the information, your information will be transferred to the Third Party Vendors providing such information, products and/or services. The Third Party Vendors websites or systems are not owned or controlled by us. Thus, your information will be processed, stored and/or used according to Third Party Vendors privacy policy and terms & conditions which is out of our control. We shall not liable in relation to your activities on or with those Third Party Vendors websites, systems and/or communication. 


6           Cookies

FinMonster allow you to experience a better experience on Corporate Banking services. To achieve this purpose, we use cookies to distinguish you among Users. Cookies are useful because they allow us to recognise your device and they store information about your use of this Platform, thus enabling us to provide customised function to you, to tailor the content, advertisement, information of our Platform to suit your interests and, where permitted by your marketing preferences, provide you with promotional materials or direct marketing based on your usage patterns. We will be able to access the information stored on the cookies and record how you use this Platform.


Cookies are small bits of information that are automatically stored on your web browser in your computer that can be retrieved by this Platform. Generally, cookies are eliminated when you close your browser which are referred to as session cookies. Persistent cookies exist on your browsing device either until such time you delete it or they expire. By using this Platform, you consent to us using cookies. Such use of data does not disclose any of your sensitive Personal Data, and we will not collect, process or use any of your sensitive Personal Data in this regard.


Information to be recorded includes but not limited to:

  • IP Address;
  • Browser type;
  • Website visited before user came to the Platform;
  • What page user viewed on the Website; and/or
  • Time spent on the Website.


Kindly noticed that your devices cookies may be accessible by third parties vendor or provided by third parties vendors such as Google including but not limited to application of Google AdSense, Google Analytics and Google Display Network for serving advertisement on Platform, remarketing and user behaviour analysis. Regarding the detail of Google’s use of data, Users could visit “How Google uses data when you use our partners’ sites or apps”. We do not have any control over and are not responsible or liable for such third parties’ collection and use of the cookies. Please refer to those third parties’ relevant policies regarding their collection and use of cookies for further information. 


Users may opt out of personalized advertising by visiting Ads Settings. Alternatively, you can opt out of some third-party vendors’ uses of cookies for personalized advertising by visiting  www.aboutads.info. If you accept cookies, you will be acknowledging that your information is being collected, stored, accessed and used as outlined above.


7           Your consent and rights

By visiting our website and using our Platform, you consent to our Privacy Policy. 


You have the right to 1) check whether we keep any Personal Data of you and request for a copy of the data; 2) require us to correct any inaccurate Personal Data of you; 3) opt out of receiving direct marketing or promotional communications from us. 


On the other hand, we may need specific information from you to help confirm your identity when you exercise your rights. Reasonable administration fee may be charged if applicable.


Requests for access to data, correction of data or for information regarding kinds of data held are to be addressed as follows:


Eureka Holding Limited

12B, Century House, 3 Hanoi Road, Kowloon, Hong Kong

(852) 3590 8508


8           Changes to this Policy

We might revise this Policy from time to time and would notify you accordingly. By accessing or using our Platform when such changes are made, you agree to the revised Policy. The current Policy is last updated on [9 December 2018]. 


9           Governing law and jurisdiction

This Policy is governed by and construed in accordance with Hong Kong SAR Law, and Users agree to submit to the non-exclusive jurisdictions of the courts/tribunals of Hong Kong SAR.