SP Global Trust Limited

Definitions

“Personal Data” means personal data as defined in the Personal Data (Privacy) Ordinance (Chapter 486) of the Laws of Hong Kong.

“SP Global Trust” means SP Global Trust Limited, together with its subsidiaries and associated companies.

Uses / Purpose of Collection

SP Global Trust is committed to maintaining the confidentiality of your Personal Data. It will not be shared for commercial purposes without your prior permission unless required by law.

By submitting Personal Data, you agree that it may be used for purposes including:

• Processing applications and daily operations of services;
• Client relationship management (e.g. loyalty programs);
• Maintaining credit and instruction history;
• Enhancing or launching services/products;
• Direct marketing (with consent);
• Determining indebtedness and collecting payments;
• Compliance with legal and regulatory obligations;
• Personalized advertising;
• Legal proceedings or inquiries;
• Obtaining support services (banking, audit, etc.);
• Other lawful and incidental purposes.

Classes of Potential Transferees

SP Global Trust may transfer your Personal Data to the following parties, where consent has been given or allowed by law:

• Law enforcement agencies or regulators;
• Third-party service providers (e.g. IT, auditing);
• Other members of the SP Global Trust group;
• Sureties or persons under confidentiality obligations;
• Financial institutions;
• Partners in rewards/charity programs;
• Credit or debt collection agencies;
• Assignees/transferees of SP Global Trust entities;
• Overseas transfers and anonymized data recipients.

Potential Personal Data to Be Collected

Data may be collected directly, through interactions, or from third-party sources:

• Transaction data (bank details, purchases);
• Technical data (IP address, browser info);
• Biometric data (voice ID, fingerprint, etc.);
• Geographic/location data;
• Data from your agents or contacts;
• Public sources, credit and fraud agencies.

SP Global Trust may also use cookies and analytics to generate behavioral data.

Direct Marketing

SP Global Trust may use your data for marketing financial, insurance, or related products and services. This includes:

• Demographics and behavioral data;
• Transaction history and location data;
• Social media data and third-party analytics.

Access and Rectification of Personal Data

You may request access, correction, or restriction of your personal data held by SP Global Trust. Contact:

A reasonable fee may be charged for processing access requests.