• through the software applications made available by us for use on or through computers and mobile devices (the “Apps”),
• through our social media pages and apps (collectively, our “Social Media Pages”), and
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual:
• Postal address
• Telephone number
• Username and password • Futu brokerage account number
• Social Security number (to open a brokerage account)
• Bank account number
• Email address
• Credit and debit card number
• Profile picture
• Social media account ID
• Messages or videos you post to the Forum
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
Through the Services
• We collect Personal Information through the Services, for example, when you register an account to access the Services, or initiate a trade.
From Other Sources
• We receive your Personal Information from other sources, for example:
o publically available databases
o joint marketing partners, when they share the information with us;
If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
Use of Personal Information
We and our service providers use Personal Information for legitimate business purposes including:
• Providing the functionality of the Services and fulfilling your requests.
• To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
• To complete your transactions, and provide you with related customer service.
• To send administrative information to you, such as changes to our terms, conditions and policies.
• To allow you to send messages to another person if you choose to do so. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
• Providing you with our newsletter and/or other marketing materials and facilitating social sharing
• To send you marketing related emails, with information about our services, new products and other news about our company.
• To facilitate social sharing functionality that you choose to use.
• Analysis of Personal Information for business reporting and providing personalized services.
• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
• To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
• Allowing you to participate in sweepstakes, contests or other promotions.
• We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
• Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.
• Aggregating and/or anonymizing Personal Information.
• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
• Accomplishing our business purposes.
• For data analysis, for example, to improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For developing new products and services;
• For enhancing, improving, or modifying our current products and services; • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
Disclosure of Personal Information
We disclose Personal Information:
• To our third party service providers, to facilitate services they provide to us.
• These can include providers of services such as website hosting, data analysis, payment processing, trade clearing and settlement, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• To third-party sponsors of sweepstakes, contests, and similar promotions.
• By using the Services, you may elect to disclose Personal Information
• On the Forum or other message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
• To comply with applicable law and regulations.
• This can include laws outside your country of residence.
• To cooperate public and government authorities.
• To respond to a request or to provide information we believe is important
• These can include authorities outside your country of residence.
• To cooperate with law enforcement.
• For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
• To enforce our terms and conditions; and
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual
• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Through your browser or device:
• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
Through your use of the App
• When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Using pixel tags and other similar technologies
• Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
Using Adobe Flash technology
(including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
• We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
• Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
• We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.] [We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined. security We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
• Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by:
• Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by: We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. How you can access or correct your Personal Information
If you would like to request to review or correct Personal Information, you may contact us by: We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change (e.g., when you make a purchase or enter a promotion, you may not be able to change the Personal Information provided until after the completion of such purchase or promotion).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
THIRD PARTY SERVICES
THIRD PARTY ADVERTISING
use of Services by MINORS
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
Jurisdiction and CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background) on or through the Services or otherwise to us.