Privacy Policy Last updated: 24/02/2024
Neon Trivox™ (“we”, “our” or “us”) is committed to protecting your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
This Privacy Policy explains how we collect, store, process, and use your personal information when you interact with Neon Trivox (the “Website”).
Our Data Protection Principles
- Transparency: We strive to keep you informed about how your data is collected and used, including when we refer you to third-party trading platforms. We provide this information clearly and at the appropriate time during your interactions with us.
- Purpose Limitation: Your personal data is processed only for legitimate purposes including account creation, access to the platform, connection with external trading services, user experience improvement, and compliance with legal obligations in Hong Kong and other jurisdictions if required.
- Data Subject Rights: You have full rights to access, correct, delete, or restrict the use of your personal data. Requests can be made via email to [email protected], and will be addressed in compliance with the PDPO.
- Data Security: While absolute protection cannot be guaranteed, we implement reasonable safeguards — including encryption and restricted access — to protect your data from unauthorized or accidental access, processing, erasure, or other misuse.
1. Scope of This Policy
This Privacy Policy outlines the categories of personal data we may collect, the methods of collection, processing, storage, usage, sharing with third parties, and your rights in relation to such data.
The term “Personal Data” refers to information that can identify an individual either directly or indirectly, in line with Hong Kong’s legal definitions.
“Processing” includes activities such as collecting, recording, organizing, structuring, storing, retrieving, consulting, using, disclosing, aligning, combining, restricting, erasing, or destroying your data.
2. Applicability to Children
Our services are not directed at individuals under 18 years of age. We do not knowingly collect data from children. If we become aware that data from a minor has been collected, we will take steps to delete it immediately.
3. When We Collect Data
We may collect data about you when you:
- Access or use the Website
- Communicate with us through our service channels
- Register or engage with our partnered trading platforms
Data may be collected directly from you, automatically through analytics tools, or via third-party providers we work with.
4. Voluntary Nature of Data Submission
Providing your personal data is entirely voluntary. However, failure to provide certain required data may prevent us from delivering the requested services or limit your ability to access and use the Website.
5. Purposes of Processing Personal Data and Legal Grounds
Neon Trivox™ processes your Personal Data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong. We will only use your data where we have a valid legal basis, such as your consent or our legitimate business interests.
The main purposes for processing your data include:
- Consent: You have voluntarily provided your information through the Website to be shared with third-party trading platforms.
- Legitimate Interests: Processing is necessary to improve services, resolve issues, and protect our legal rights.
- Legal Compliance: Processing is required to comply with applicable laws or regulatory obligations in Hong Kong.
If you have any questions about the lawful basis for processing, feel free to contact us at [email protected].
Use Cases and Legal Basis
| # | Purpose | Legal Basis |
|---|---|---|
| 1 | Submitting your data to trading partners at your request. | Consent (DPP1 - Purpose and Manner of Collection) |
| 2 | Responding to your questions or requests. | Legitimate interests (DPP3 - Use of Personal Data) |
| 3 | Fulfilling legal and regulatory obligations. | Legal requirement under Hong Kong law |
| 4 | Improving our services and user experience. | Legitimate interests |
| 5 | Preventing fraud and misuse of the platform. | Legitimate interests |
| 6 | Internal operations (e.g. planning, analytics, admin). | Legitimate interests |
| 7 | Statistical and analytical evaluations. | Legitimate interests |
| 8 | Protecting our legal rights or asserting claims. | Legitimate interests or legal compliance |
6. Sharing Your Personal Data
We may share your Personal Data with:
- Trusted third-party service providers (e.g. hosting, analytics, diagnostics)
- Authorized third-party trading platforms if you request it
- Affiliates and business partners who help us deliver our services
- Governmental and regulatory bodies when legally required
- Investors, buyers, or in the context of a merger, acquisition, or restructuring
Any third party receiving your data is required to handle it in accordance with Hong Kong’s PDPO or equivalent data protection standards. You may contact us to obtain a list of our data recipients.
7. Cookies and Use of Third-Party Technologies
This Website may use "cookies" and similar technologies to enhance your browsing experience, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and related guidance from the Hong Kong Privacy Commissioner.
Cookies are small text files stored on your device when you access our Website. They allow us to remember your preferences, analyze Website performance, and tailor content or ads that may be of interest to you.
We may also partner with third-party providers (e.g. analytics or advertising services) who may set cookies or other tracking technologies, subject to their own privacy policies. Please refer to those policies for details.
Types of Cookies We May Use
| Cookie Type | Purpose | Notes |
|---|---|---|
| Strictly Necessary | Enables essential site functions like page navigation and secure login. | These session cookies expire when you close the browser. Some may store login status. |
| Functionality | Stores user preferences to personalize your experience. | Persistent cookies with a fixed expiration. |
| Performance | Collects anonymized usage data to improve Website performance. | May be session-based or persistent, without storing personally identifiable data. |
Managing Your Cookie Preferences
You can configure your browser to accept or reject cookies, or notify you before one is placed. However, disabling cookies may affect your experience on this Website. Below are help links for major browsers:
Online Tracking Notice
At this time, our Website does not support Do Not Track (DNT) signals.
9. Transfers of Personal Data Outside Hong Kong
Neon Trivox may transfer your Personal Data to jurisdictions outside Hong Kong, including to international organizations, affiliates, or service providers. In accordance with Section 33 of the Personal Data (Privacy) Ordinance (Cap. 486), we will take all reasonably practicable steps to ensure that your Personal Data remains protected to a standard comparable to Hong Kong’s data protection principles.
We will only transfer your Personal Data to third parties overseas:
- Where the data recipient is bound by legally enforceable obligations ensuring a comparable level of data protection;
- Where you have provided express and voluntary consent after being informed of possible privacy implications;
- Or where other exemptions under PDPO Section 33 apply (e.g., for prevention of crime, legal proceedings, or contract performance).
If you would like to learn more about the measures we adopt to protect data transferred overseas, feel free to contact us at [email protected].
10. Security Measures for Safeguarding Personal Data
We are committed to implementing appropriate technical and organizational safeguards to protect your Personal Data against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, or access.
Our practices comply with Data Protection Principle 4 (Security of Personal Data) under Hong Kong law, including:
- Restricted internal access based on job role and necessity;
- Data encryption and secure communication protocols;
- Regular vulnerability assessments and system reviews.
While we adopt best practices, we cannot guarantee absolute security of your data during Internet transmission. By using our services, you acknowledge and accept this risk.
11. Third-Party Website Links
Our Website may include links to third-party websites or applications that operate independently. Neon Trivox has no control over and assumes no responsibility for the privacy practices, content, or policies of such external sites.
We strongly recommend that you carefully review the privacy statements of these third-party platforms before submitting any Personal Data to them.
13. Your Rights in Relation to Personal Data
Under the Personal Data (Privacy) Ordinance, you have the following rights in respect of your Personal Data held by Neon Trivox:
- Right to access – You may request a copy of the Personal Data we hold about you.
- Right to correction – You may request to correct inaccuracies in your Personal Data.
To make a data access or correction request, please contact us at [email protected]. A reasonable administrative fee may apply in accordance with Section 28 of the PDPO.
Neon Trivox will respond to valid access or correction requests within the timeframe stipulated by law. Please note that we may require you to verify your identity before acting on your request.
13. Your Rights Regarding Personal Data
Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you have specific rights related to your Personal Data that Neon Trivox holds:
- Right of Access – You may request access to your Personal Data held by us. This includes the right to be informed whether we hold any Personal Data about you and to obtain a copy.
- Right of Correction – You have the right to request correction of any inaccurate Personal Data we hold about you.
Requests for access or correction must be made in writing to [email protected]. We may charge a reasonable fee for data access requests, but no fee is charged for data correction requests.
We aim to respond within 40 days, as stipulated under the PDPO. If we are unable to comply, we will inform you of the reasons and your rights to complain to the Privacy Commissioner for Personal Data.
We may require additional information to verify your identity before processing your request.
Withdrawal of Consent
If you have provided consent for the processing of your Personal Data, you may withdraw it at any time by contacting us. This will not affect the legality of any processing carried out before the withdrawal.
Right to Object to Direct Marketing
You have the right to object at any time to the use of your Personal Data for direct marketing purposes. Upon your request, we will cease such processing without charge.
12. Updates to This Privacy Policy
Neon Trivox may update this Privacy Policy from time to time to reflect changes in legal requirements, our practices, or service enhancements.
Any updated version will be posted on our Website with the “Last Updated” date. For material changes, we will endeavor to notify you through reasonable means (such as email or website notices).
Your continued use of our services after such updates will constitute acknowledgment and acceptance of the revised policy.