Purpose of Processing EU and UK Personal Data Acquired from Customers and Other Subjects Concerned

GMO-Z.com Forex HK Limited (hereinafter referred to as "Company", “we”, “our” and “us“), as a Leveraged Foreign Exchange Trading Business processing EU and UK personal data, in accordance with the General Data Protection Regulation (effective on May 25, 2018) prescribed by the European Commission and UK Data Protection Act, we shall process customers’ EU and UK personal data only within the scope necessary for the intended use that is specified and publicized in advance. However, in the case where it is required by laws and regulations, we may process EU and UK personal data of customers and other subjects beyond the scope necessary for achieving the intended use specified and publicized in advance. Moreover, providing EU and UK personal data is indispensable for fulfilling contractual agreement, and therefore if EU and UK personal data cannot be provided at each customer’s own discretion, providing services to such customer may be hindered.

We may use your data for the following purposes:

1. processing the Client's applications for opening accounts, financial accommodation or credit facilities or other services or products;
2. daily administering and operation of the accounts, services and facilities provided to Client;
3. conducting client identification and verification procedures and credit checks at the time of application and from time to time during the continuation of the business relationship between the Client and us whether at special or regular reviews;
4. meeting the disclosure requirements under any law, regulations, guidelines, codes of practice or court orders binding on, or applicable to, us or any of its group companies, including but not limited to disclosure requirements relating to prevention of money laundering and terrorist financing;
5. complying with the obligations, requirements or arrangements for disclosing and using data that apply to us or any of its group companies or that it is expected to comply according to:
   1. any law binding or applying to it within or outside the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
   2. any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future (e.g. guidelines, guidance or requests given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information) and any international guidance, internal policies or procedures;
   3. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers (together the "Authorities" ) that is assumed by or imposed on us or its group company by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
   4. any agreement or treaty between Authorities;
6. assisting other financial institutions to conduct credit checks and collect debts;
7. designing services and products for the Client's use;
8. your name and contact details may be used for marketing Leveraged Foreign Exchange trading, financial or related services and products of us and/or its group companies;
9. ensuring ongoing credit worthiness of the Client;
10. determining amounts owed to or by the Client from time to time;
11. collecting amounts outstanding from the Client and/or other persons providing security for the Client's obligations;
12. provision of reference (status enquiries) relating to the Client;
13. conducting matching procedures by comparing data for producing or verifying data that may be used for or against the Client;
14. enabling an actual or proposed assignee of us or an actual or proposed participant, sub-participant or transferee of our rights in respect of the Client to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer; and
15. purposes relating to the above

Rights of Customers and Other Subjects Concerned

Each customer or the other subject concerned has the following rights regarding EU and UK personal data about himself or herself.

1. Right to access to his or her own EU and UK personal data and other information relating to its personal data.
2. Right to rectify inaccuracies of his or her EU and UK personal data without undue delay
3. Right to erase his or her EU and UK personal data without undue delay
4. Right to restrict processing of his or her EU and UK personal data
5. Right to receive EU and UK personal data provided by customer or other concerned subject by himself or herself in a general format that is readable on computers, and right to transfer (i.e. data portability) the EU and UK personal data to other organizations in order for them to manage without hindering transferring process.
6. Right to object to public interest; processing for the interests of Company, a third party or both;
   and processing for direct marketing for EU and UK personal data of customers and other subjects concerned.
7. Right not to be subjected to assessments conducted or decisions made through automatic processing such as profiling that have serious impact including legal effects on individuals.
   Note: We do not perform profiling.
8. Right to lodge a complaint with a supervisory authority

Conditions for Processing of EU and UK personal data

We may process EU and UK personal data when any one of the following cases is applicable, even if we have not obtained consents from customers and/or others concerned.

1. When the processing is necessary for the execution of the contract where a customer or other subject concerned himself or herself is the contracting party.
   Or when the processing is necessary in accordance with request from a customer or other subject concerned at the stage when the contract is not concluded yet.
2. When the processing is necessary to comply with the legal obligation that we shall abide by; for example, when following information disclosure orders based on laws and regulations from government agencies etc.
3. When the processing is necessary to protect serious interests of customers, other subjects concerned, or both.
4. When it is deemed appropriate to investigate, prevent, or take measures against illegal acts or suspicious acts.
5. When the processing is necessary for legitimate interests pursued by a third party or us to the extent that its processing does not infringed right, profit, and freedom concerning the privacy of a customer or other subject concerned.

Special Types of EU and UK Personal Data

In principle, in order to conduct various procedures concerning the services providing, we shall obtain prior consent from customers and other subjects concerned.
Moreover, we collect, use and transfer special types of EU and UK personal data belonging to customers and other subjects concerned such as health conditions and physical characteristics that are necessary in relation to the scope of the purpose; and its EU and UK personal data shall not be processed except for its purpose.

Safeguards

In order to appropriately manage EU and UK personal data of customers and other subjects concerned and prevent leakage, loss and damage of those EU and UK personal data, including other safety management approaches, we carry out technical, physical, organizational and human related safeguards.

Joint Control

We jointly control EU and UK personal data customers and other subjects concerned that we hold with our group companies in order to promote activities such as service development and service guidance;
and communication with customers and other subjects concerned.In addition, when we jointly control EU and UK personal data with our group companies, the scope of responsibility relating to the processing of the personal data of customers and other subjects concerned, and the contact point for inquiries shall be clearly defined among us and group companies.Items of EU and UK personal data that we jointly control are stated as follows:

• Name;
• Address;
• Email address;
• Phone number;
• Contract details;
• Any other items necessary in accordance with the purpose of use (*)

* For details, please refer to the above section 1, "Purpose of Processing EU and UK Personal Data Acquired from Customers and Other Subjects Concerned".

The joint controllers are the group companies of us that are listed on:

https://www.gmo.jp/en/company-profile/groupinfo/

Note: Group companies may be changed in the future due to new establishment, consolidation, abolishment and other reasons.

Transfer of EU and UK Personal Data

EU personal data belonging to customers and other subjects concerned are transferred to our group companies and outsourcing contractors such as cloud provider and IT service vendor to which we have subcontracted our business operation to the extent necessary for service provision.
In addition, we request appropriate processing of the transferred EU and UK personal data to those outsourcing contractors, and manage EU and UK personal data of customers and other subjects concerned appropriately.

Archiving, Deletion, Disposal of EU and UK personal data

Except where otherwise specified by laws and regulations, we define the retention period of EU and UK personal data of customers and other subjects concerned within the scope necessary for the purpose of use.
After the defined retention period has expired or the purpose of use has been achieved, we erase EU and UK personal data of customers and other subjects concerned without delay.

About Cookies and Other Similar Technologies.

We use cookies on this site with a view to increasing the usability. When you re-visit this site cookies are used for user tracking, re-targeting advertisement, affiliate advertising and retaining login information of registered users, users can view this site more conveniently.
A cookie is an information used to transmit information from this site to your browser. When you, as a customer or other visitor, visit this site again, the cookie helps you to use this site more conveniently and is stored in your personal computers/devices.
Furthermore, the stored information does not include information such as your name, your residential address, your phone number and your email address which can be used to identify an individual.
Cookie does not also have negative effects on your computers/devices.
Cookie information that is collected from customers and other visitors will be transmitted to and stored in servers at Google LLC, Adobe Systems Incorporated and some other entities from our web servers.
We also obtain statistical data concerning access information such as the number of accesses and stay period for this site from stored data by using Google Analytics service, Adobe Analytics that is provided by Adobe Systems Incorporated and some other services.
It is possible to block cookie, if you, as a customer or other visitor, change the setting of your web-browser. In such cases, you will not have a trouble viewing this site except for some functions.
Please make contact with the developer and/or distributor of the web-browser that you are using for its setting procedure.

Group-wide Data Protection Officer and Group-wide Representative for EU Personal Data

＜Group-wide Data Protection Officer for EU and UK Personal Data (G-DPO)＞
GMO Internet Group, Inc.,
Cerulean Tower 4-14F, 26-1 Sakuragaokacho, Shibuya ku, Tokyo, 150-8512 , Japan.
Email address: dpo@gmo.jp

＜Group-wide Representative for EU Personal Data＞
JANSON BAUGNIET CVBA
Congreslaan 27
B-9000 Ghent
BELGIUM
E-mail address: gdpr.representative@janson.be

＜Group-wide Representative for UK Personal Data＞
Shakespeare Martineau
60 Gracechurch Street
London EC3V 0HR
DX 700 London City
E-mail address: ukdataprotectionrep@shma.co.uk

Claims and Inquiries

For inquiries regarding this privacy policy, please make contact to the following contact point.

https://forex.z.com/hk/en/contact/index.html

Disclosure and other requests of EU and UK personal data

Requests for Disclosure, correction, addition, deletion, suspension of use, suspension of provision of third party, transferring (data portability) shall be dealt with in the following manner.
Please be aware that we will not accept requests by telephone, fax, email, verbally or by any method other than that laid out below.

Please print out our prescribed form and fill in necessary information.
After filling in, please enclose the necessary documents, and send them to the following address by certified mail.

Address:
GMO-Z.com Forex HK Limited
Suites 2308-09, 23/F, Tower 1, The Gateway, Harbour City,
Kowloon, Hong Kong

Disclosure and Other Requests Form is below,

Disclosure and Other Requests on EU and UK Personal Data (PDF) (356KB)