Privacy Policy Statement

Personal data is any information that can be used to identify you. For Mox (Mox/we/us), your personal data is very important. What we can learn from or about you helps us to deliver smart banking to you.

We’re the protector of your data. This Privacy Policy Statement sets out the policies and practices which highlight our commitment to protecting the privacy of your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486).

You should read this Privacy Policy Statement alongside our Personal Information Collection Statement, which details why and how we use your personal data and who we share it with.

After reading this Privacy Policy Statement if you have any questions, please ask us anytime!

1. What Information of Yours Do We Hold and Who Do We Collect It from?

Information Submitted by You:

• Identity data means your personal information you give to us when you apply for our products or services, or enter a Mox competition or game, e.g. your name, date of birth, identity card number, correspondence address, phone number, email address, nationality, credit-related information or even other data such as selfies.
• Communications data includes how you want us to contact you and your preferences for the marketing we send you.

Information We Collect about You and Your Device:

• Financial data includes your Mox Card number, transactions conducted through your Mox Account, Mox Invest Account or any of your Goal accounts and any data on other Mox products and services you use.
• Technical data means details such as your mobile network, operating system, IP address, and the settings and technology on your mobile phone.
• Usage data includes information about how you use our website, the Mox app and products and services.

Information from You (or Created by You) Which You May Give Us Permission to See, for the Purposes of Providing Products or Services to You:

• Your contacts list, to facilitate payments and transactions between you and your contacts.
• Your geolocation, to help you onboard as a Mox customer and for other security and compliance checks while using our products and services.
• Your facial image data from your camera, to help you onboard as a Mox customer and so that we can confirm your identity.
• Information that you may provide to us, including information that you may post on our website and social network sites, to enable us to communicate with you and to provide products and services to you.

Information from Third Parties Which Helps Us Deliver Our Products and Services:

• General due diligence includes data that the law requires us to process about you in relation to illegal activities involving money.
• Financial due diligence includes data we receive from credit reference agencies to help with responsible lending decisions.

Sometimes we will aggregate information. This means we will combine information from groups of customers to create a profile group for research, analysis or to help with general marketing. Aggregated data will not show your identity, but if we end up connecting this to you personally, then we will protect that data in the way stated in this Privacy Policy Statement.

2. How Do We Protect Your Data?

Some of the security measures we use to protect your data include:

• Firewalls – like a security guard whose job it is to decide who can access a building, firewalls proactively block certain information flows to our app by screening the flows based on a set of rules that Mox will set.
• Intrusion detection systems (“IDS”) – like a security camera, IDS monitor information flows for patterns of activity that don’t look normal and might signal an attack on our app.
• 24/7 physical protection of facilities where your data is stored.
• Background checks on people that need access to those physical facilities to do their job.

We also use digital signatures and encryption. Encryption changes your data into a code that can only be read by Mox and some of our trusted partners who need access to it. We always encrypt your data using the highest standards of security technology.

Encryption helps to ensure:

• we can confirm the identity of the user;
• we can prove that a transaction took place on the instruction of a specific person;
• we can make sure that personal data is kept private by keeping the information hidden; and
• we can ensure that the personal data was not changed during transfer or storage by someone without authority.

We always need your help to keep your data secure. Please let us know immediately if your data may have been lost or stolen, or if you think someone has used it without your permission.

3. Automated Decisions and Profiling

We may use algorithms when considering and processing your application for Mox products and services. The algorithms provide automatic assessments and decisions based on the personal data collected in accordance with our PICS. The parameters used in these assessments have been selected to provide a fair and objective assessment of your personal data and have been tested for reliability and fairness. If we are uncertain about the accuracy of the personal data that will be used in an algorithmic assessment, we may ask you to clarify any such personal data.

4. Enquiries

At Mox, we pride ourselves on putting the customer first. So, if you need any additional information about our privacy policies and practices or if you have a complaint then please give us a chance to put things right by messaging us through the Mox app, sending an email (care@mox.com), giving us a call (Tel: 2888 8228) or reaching us by post (address: Data Protection Officer, 39/F., Oxford House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong).

You can also refer your complaint to the Hong Kong Monetary Authority or the Office of the Privacy Commissioner for Personal Data.

5. Linked Websites

This policy does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites which we do not operate or control.

6. Changes to this Privacy Policy Statement

Sometimes, we’ll need to update our Privacy Policy Statement. You can find the latest version on our website and the Mox app.

The English version prevails if there is any inconsistency between the English and Chinese versions of any of this Privacy Policy Statement.

Last updated: 28 November 2023