INFORMATION WE COLLECT
We want you to understand the types of information we collect when you register for and use Amber’s Services
When you open an account to use our Services, you provide us with your personal information to enable us to assess your application and comply with the relevant laws and regulations. The information that we may collect from you is as follows:
Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bill, photographs, phone number, home address, and/or email.
Formal Identification Information: Government-issued identity document such as passport, driver license, national identity card, state ID card, passport number, driver license details, national identity card details, visa information and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
Institutional Information: Employer identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation) and/or personal identification information for all material beneficial owners.
Financial Information: Bank account information, payment card primary account number (“PAN”), transaction history and/or trading data.
Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount and/or timestamp.
Correspondence: Survey responses, information provided to our support team, trading team, sales team and/or user research team.
We may collect and store certain information automatically when you use our Services. Examples include the internet protocol (the “IP”) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, log in details, the full URL clickstream to, through and from the Site or APP or Services, cookie Identifier and your activity on our Site or APP or Services, including the pages you visited, the searches you made and, if relevant, the services your purchase.
We obtain information about you in a number of ways through your use of our Services, including through any of our Site, APP or Services, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of ongoing support service communications. We also receive information about you from third parties such as your payment providers and through publicly available sources. For example:
The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details.
Your business partners may provide us with your name and address, as well as financial information.
Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website or APP.
Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided to us.
WHY DO WE COLLECT THIS INFORMATION
To provide and maintain our services
We use the information collected to deliver our Services and verify user identity.
We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with Services without data like identification, contact information and transaction-related information.
To protect our clients
We use the information collected to protect our platform, users’ accounts and archives.
We use IP addresses and cookie data to protect against automated abuse such as spam, phishing and Distributed Denial of Service (DDoS) attacks.
We analyse trading activity with the goal of detecting suspicious behavior early to prevent potential fraud and loss of funds to bad actors.
To comply with legal and regulatory requirements
Respect for the privacy and security of data you store with Amber and complying with laws and regulations, we will not disclose or provide any personal information to third party sources without review from our legal case team and/or prior consent from the user.
To measure site performance
We actively measure and analyse data to understand how our Services are used. This review activity is conducted by our operations team to continually improve our platform’s performance and to resolve issues with the user experience.
We continuously monitor our systems’ activity information and communications with users to look for and quickly fix problems.
To communicate with you
We use personal information collected, like an email address to interact with users directly when providing customer support on a ticket or to keep you informed on logins, transactions, and security. Without processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions and inquiries. All direct communications are kept confidential and reviewed internally for accuracy.
To enforce our Terms of Service and other agreements
It is very important for us and our customers that we continually review, investigate and prevent any potentially prohibited or illegal activities that violate our Terms of Service. For the benefit of our entire user base, we carefully enforce our agreements with third parties and actively investigate violations of our posted Terms of Service. Amber reserves the right to terminate the provision of service to any user found engaging in activities that violate our Terms of Service.
HOW DO WE USE YOUR PERSONAL INFORMATION
We only use your personal and sensitive information for the reason we collect it as set out above and for the purpose(s) for which it was collected, or as otherwise permitted by law.
HOW DO WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose your personal information:
for the primary purpose for which it was collected.
for the purposes that a reasonable person will consider appropriate in the circumstances.
where you have consented.
for direct marketing by us where consent has been given but giving you the opportunity to opt out of such direct marketing. We include our contact details in direct marketing.
to any members of us, which means that any of our affiliates and subsidiaries may receive such information.
to any of our service providers and business partners, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, research or other services.
where permitted under the PDPO or other applicable law.
If we disclose your personal information to service providers and business partners, in order to perform the services requested by the client, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations.
We do not disclose your personal information for any secondary purposes unless your consent has been given or if so permitted or required under the PDPO or other applicable laws and regulations.
We will not sell or license any personal information that we collect from you without your explicit consent. We will share your information with the following service providers and business partners:
HOW DO WE PROTECT YOUR PERSONAL INFORMATION
We have implemented a number of security measures to ensure that your information is not lost, abused, or altered. Our data security measures include, but are not limited to: PCI Scanning, Secured Sockets Layered encryption technology, pseudonymization, internal data access restrictions, and strict physical access controls to buildings & files. Please note that it is impossible to guarantee 100% secure transmission of data over the Internet nor method of electronic storage. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.
If you suspect that your personal information has been compromised, especially account and/or password information, please lock your account and contact customer service immediately.
WITHDRAWAL OF CONSENT
Upon reasonable notice being given by you of your withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of your personal information, we will inform you of the likely consequences of withdrawing your consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal information unless it is required or authorized under applicable laws.
ACCESS, ACCURACY AND CORRECTION OF YOUR PERSONAL INFORMATION
We rely on you to ensure that your profile and contact information is accurate. Please let us know of any changes to your personal information. You may update the accuracy or completeness of such information, and request that corrections be made to it. Please send all your inquiries, requests and notifications to email@example.com.
TRANSFER OF PERSONAL INFORMATION OUTSIDE OF HONG KONG
We will ensure that any transfers of personal information to a territory outside of Hong Kong will be in accordance with the PDPO so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPO.
LINKS TO OTHER WEBSITES
DATA PROTECTION OFFICER
If you have concerns or further queries about how we are handling your personal information, or any problem or complaint about such matters, please contact our Data Protection Officer at firstname.lastname@example.org.