Hong Kong Reference Version for Futures and Cryptocurrency Market Information Services
Effective Date: [1 September 2026] Last Updated: [1 September 2026]
Applicable Application: [Stocex Pro]
Operator: [ALGOQ LIMITED] Registered Address: [RM A1, 3/F, ASTORIA BUILDING, NO.12 ASEY ROAD, TSLM SHA YSUI, HONG KONG] Contact: [algoqservice@gmail.com]
Important Notice: This document is a reference template. It must be completed and reviewed in light of the actual product features, data flows, charging arrangements, place of incorporation and territories served before publication.
This Policy explains how [ALGOQ LIMITED], as a data user within the meaning of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”), collects, holds, processes, uses, discloses, transfers and protects personal data when operating [Website Name] and its related applications, interfaces and customer support activities, and how you may exercise your rights. Independently operated third-party websites, brokers, exchanges, payment services and sign-in services are governed by their own privacy policies.
We observe the six Data Protection Principles, covering the purpose and manner of collection, accuracy and retention, use, security, openness, and access and correction. Where an institutional customer submits personal data relating to its employees or users, the parties’ respective responsibilities depend on who actually controls the purposes and manner of processing and on the applicable contractual arrangements.
|
Category of Information |
Examples |
Typical Source |
|
Device and Log Data |
IP address, device model, operating system, browser, login time, crash logs and security logs |
Automatically generated by devices and servers |
|
Usage and Preferences |
Watchlist instruments, searches, browsing, indicator settings, alerts, language and time zone |
Your actions and local or account settings |
|
Customer Support and Feedback |
Enquiries, complaints, recordings or attachments |
Your interactions with customer support |
|
Approximate Location |
Country, city or time zone inferred from IP address |
Used for language, market hours, security and compliance; precise location requires separate authorisation |
Your financial preferences may indicate investment interests, but we do not treat a watchlist as evidence of actual asset holdings. If a product permits connection to a broker or trading platform, or the import of holdings, a separate notice will explain the relevant fields, permissions, purposes, retention period and withdrawal method, and any required authorisation will be obtained.
We use personal data only for the purposes notified to you when it was collected, purposes directly related to those purposes, or other purposes for which you have given prescribed consent. Collection will be lawful, fair, necessary and not excessive. The Personal Information Collection Statement will explain whether provision is obligatory, the consequences of not providing the data, the purposes of use, the classes of persons to whom the data may be transferred, and the means of requesting access to and correction of the data.
We may use essential cookies, local storage, pixel tags or software development kits (“SDKs”) to maintain sign-in sessions, remember interface preferences, provide security protection, analyse performance and measure promotional effectiveness. We will clearly explain the purposes of non-essential technologies and provide a [Cookie Settings Link]. Disabling essential technologies may prevent sign-in, subscription or personalisation features from functioning.
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Category |
Purpose |
Can It Be Disabled |
|
Strictly Necessary |
Authentication, load balancing, security and consent records |
Generally cannot be disabled |
|
Preferences |
Language, time zone, chart and watchlist display preferences |
Can be disabled; the experience may change |
|
Analytics and Performance |
Traffic statistics, error diagnosis and feature improvement |
Can be selected in settings |
|
Advertising and Marketing |
Frequency control, conversion measurement and relevant content |
Used after consent; consent may be withdrawn |
We do not sell personal data. To the extent necessary, we may provide information to the following recipients:
U.S. stock, global futures and cryptocurrency data may be supplied by providers outside Hong Kong. We may also use overseas cloud services, customer support or technical support. We observe the Data Protection Principles and use due diligence, data minimisation, access controls, encryption and contractual safeguards, requiring recipients to process data only for specified purposes and to provide protection comparable to that available in Hong Kong.
As of the date of this version, section 33 of the PDPO, concerning cross-border transfers of personal data, has not commenced. We nevertheless follow the good practices recommended in the Guidance on Personal Data Protection in Cross-border Data Transfer issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong (“PCPD”), and will update our arrangements if the law changes. Complete before launch: recipient or class [ ]; country or territory [ ]; categories of data [ ]; purpose [ ]; safeguards [ ]; retention period [ ].
Personal data will not be retained longer than necessary to fulfil the purposes for which it is used, except where Hong Kong law, tax, audit, exchange-licensing or dispute-resolution requirements justify a longer period. When the period expires, the data will be securely deleted or anonymised. Where immediate deletion is technically impracticable, the data will be isolated and further use restricted.
|
Record Type |
Recommended Retention Rationale |
Actual Period |
|
Security Logs |
The minimum period needed for security, fraud prevention and incident tracing |
[Complete] |
|
Customer Support Records |
The period needed to handle requests, complaints and disputes |
[Complete] |
|
Watchlists and Alerts |
For the life of the account or until deleted by the user |
[Complete] |
Primary storage location: [RM A1,3/F，ASTORIA BUILDING，NO.12 ASEY ROAD，TSLM SHA YSUI HONG KONG]. Deletion from backups may be completed according to established rotation cycles. During that period, backup data will be used only for disaster recovery and will remain subject to access restrictions.
We adopt administrative and technical measures appropriate to the risk, including access controls, least-privilege access, encryption in transit, secure password storage, log auditing, vulnerability management, backup and recovery, supplier management, staff training and incident response. No internet service can provide absolute security. Please use a strong password and protect your verification codes and devices.
If an actual or suspected data breach, unauthorised access, alteration, loss or other security incident occurs, we will promptly contain and investigate the risk. In accordance with PCPD guidance and applicable law, we will assess whether to notify the PCPD, affected individuals or other competent authorities and will explain the risk, remedial measures and contact channels.
Under the PDPO, you may ask whether we hold your personal data and make a data access request. After receiving a copy, you may request correction of inaccurate data. You may also withdraw non-essential consent, require us at any time and without charge to cease using your personal data for direct marketing, manage your preferences or request account closure. Requests for deletion, restriction of use or data portability will be considered where required by law or reasonably practicable.
Request channel: [Account Settings Path] or [Privacy Email]. A formal data access request may be submitted using the form specified by the PCPD. We may verify your identity and may charge a fee that does not exceed the direct and necessary cost of complying with the request. Unless the PDPO permits refusal or we cannot fully comply within the prescribed period, we will respond within 40 days after receiving the request or provide a written explanation of the circumstances.
You may request account closure through [Account Closure Path]. Following closure, we will cease providing account services and will delete or anonymise personal data as required by law. Orders, invoices, security logs, dispute records and regulatory records may continue to be retained where legally required. Account closure does not automatically cancel services independently ordered from third parties; you must deal with those services under the relevant third-party terms.
The Platform is primarily intended for adults aged 18 or above and does not target minors. If a minor uses the services, a parent or guardian should read and agree to the relevant arrangements. We will take account of the minor’s capacity to understand, provide notices in clear language and, where appropriate, obtain the consent of a parent or guardian. If we discover that a minor’s data has been collected inappropriately, we will restrict its use or delete it.
The Platform may recommend market-data sections or information based on browsing, searches, watchlists and alert settings. We will not infer a user’s income, assets or credit status merely because the user follows a particular asset class. We will explain the principal logic and purpose of material automated processing and provide reasonable access to human contact and preference controls. Personalisation settings: [Settings Path].
After you click a third-party link, use a third-party sign-in service, or submit account-opening or trading information to a broker or trading platform, that third party may independently collect information. Please review its policy and verify its credentials. Public information displayed by the Platform, such as details of listed-company officers, institutional contacts or on-chain addresses, is processed only within lawful and reasonable limits and must not be used for harassment, discrimination, identity theft or any other improper purpose.
We may update this Policy to reflect changes in features, data flows or Hong Kong law. Material changes may include substantial changes to purposes of use, categories of data, classes of transferees, methods for exercising rights or security implications. We will provide prominent notice by pop-up, in-app message, email or announcement and obtain prescribed consent where a change of purpose requires it. Previous versions: [Link].
Data User: [ALGOQ LIMITED]; Company Number: [+852 57963426]; Data Protection Officer: [Jams]; Privacy Email: [algoqservice@gmail.com]; Hong Kong Registered Address: [RM A1,3/F，ASTORIA BUILDING，NO.12 ASEY ROAD，TSLM SHA YSUI HONG KONG]; Customer Service Telephone: [+852 57963426]. If you are dissatisfied with the handling of your request, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong, or seek any other available legal remedy.
Privacy Policy [ALGOQ LIMITED]