Wonder App will collect your personal data to help us operate as a service provider. Broadly, Wonder App will collect, process and store the personal data you provide to us (such as your name, date of birth, identity card number, correspondence address, phone number, email address, nationality, or “sensitive” data such as your facial image, and videos and voice recordings of you that you make while communicating with us) to keep you and Wonder App secure, meet our business obligations and comply with the law. This includes establishing, maintaining and operating your Wonder App Account or other accounts, Wonder App Card (and any other Wonder App product or service you use), also providing rewards and running competitions and games. The provisions of this PICS form part of the account terms and conditions (including the terms applicable to your use of our App) and any other agreement or arrangements you enter into with Wonder App.

We collect your data so we can provide the best possible service to you. If you do not provide us with the personal data we require from you, we may not be able to establish, maintain or provide our products and services to you.

We may also collect your data, directly or indirectly, from your transactions with or through Wonder App in the ordinary course of our business, including information received from third parties, the public domain, collected through your use of our App, websites, cookies, behavioral or location tracking tools, financial services or other services provided by Wonder App and/or when you deposit money or execute transactions through your Wonder App Card. Understanding your spending and saving behavior helps us make suggestions to you, to make informed financial decisions for you, and to help keep your account(s) and data secure.

Please note that we also collect data to help us comply with laws, regulations, guidelines and requests or investigations by the authorities.

1. Who we collect data from

We will collect personal data from our customers and other individuals in connection with the purposes set out in this PICS. These customers and other individuals may include the following, and we refer to them collectively as “you/your” in this PICS:

A. applicants or account-holders of Wonder App products or services;

B. customers; and

C. any third party transacting with or through us.

2. Use of your data

We may use your data for any of the following purposes:

A. considering and processing your application/s (including assessing the merits and/or suitability of your application/s) for Wonder App products and services;

B. operating, maintaining and informing you of Wonder App products and services;

C. developing, improving and designing Wonder App products and services;

D. meeting our internal operational requirements (including credit and risk management, system or product development and planning, carrying out testing and analysis and insurance, audit and administrative purposes);

E. marketing services, products and other subjects (see paragraph below, “Direct Marketing”);

F. meeting or complying with any obligations, requirements or arrangements for disclosing and using data that apply to us, including those that we or any such member is expected to comply with according to:

• (a) any present or future law or regulation within or outside Hong Kong (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
• (b) any present or future guidelines or guidance issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong (e.g. guidelines or guidance given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information);
• (c) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self- regulatory or industry bodies or associations of financial services providers applicable to us by reason of its financial, commercial, business or other interests or activities in or related to the relevant jurisdiction (each an “Authority”); or
• (d) any investigation, demand or request from an Authority;

G. enabling an actual or potential transferee, assignee of all or any part of our business and/or asset or participant or sub-participant of our rights in respect of you, to evaluate the transaction intended to be the subject of the transfer, assignment, participation or sub-participation;

H. in connection with us defending or responding to any legal, governmental, or regulatory or quasi-governmental related matter, action or proceeding (including any prospective action or legal proceedings), including where it is in the legitimate interests of us to seek professional advice, for obtaining legal advice or for establishing, exercising or defending legal rights;

I. in connection with investigating an insurance-related matter;

J. organising and delivering seminars to you;

K. managing, monitoring and assessing the performance of any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or securities clearing or other services to us in connection with the establishment, operation or maintenance of any Wonder App product or service; and

L. any other purposes relating thereto.

3. Disclosure of your Data

Data we hold is kept confidential but we may provide, transfer or disclose such data or information to other parties (whether within or outside Hong Kong*) if it will help with any of the uses we’ve listed in the “Use of your data” paragraph above. These other parties include:

A. any organisation, agent, contractor or third party service provider who provides administrative, telecommunications, identity verification/ know-your-customer, computer, payment/ transaction, cloud storage or services, data analytics, cybersecurity or securities clearing or other services to us in connection with the establishment, operation, maintenance or provision of any Wonder App product or service to you;

B. anyone who works for (or provides services to) us (or any of the parties referred to in paragraph A);

C. any person who owes a duty of confidentiality to Wonder App;

D. any financial institution or merchant acquiring company which you would like to, or already have, dealings with;

E. any person or organisation that Wonder App owes an obligation to (which may exist now or in the future);

F. any actual or proposed assignee or transferee of all or any part of Wonder App’s business and/or assets or participant or sub-participant or transferee of Wonder App’s rights in respect of you;

G. charitable or non-profit making organisations;

H. any external service provider that we engage to provide marketing services (including anyone who works for such a service provider);

I. any interface (such as an application programming interface) that links to, or in any way makes available information about, our products and/or services;

J. third party financial institutions, insurers, credit card companies, securities and investment service providers;

K. third party reward, loyalty, co-branding and privileges program providers;

L. our co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be);

M. any person or company who has a direct or indirect shareholding in Wonder App and their affiliates (each, a “Shareholder”) (for example, to find out whether or not you are a customer of theirs or their affiliates and what products and services they provide or could provide to you), and anyone who works for (or provides services to) a Shareholder;

N. any Authority;

O. any other Wonder App customers in connection with your use of Wonder App products and services; and

P. any other person (1) where the public interest requires or (2) with your express or implied consent.

*This may mean your data is disclosed, transferred, stored or processed outside of Hong Kong. If this happens, then we may need to comply with another country’s laws and requirements on personal data. Such parties may be located in the following countries: Australia, Germany, Hong Kong, India, Ireland, Japan, Mainland China, Malaysia, Netherlands, Philippines, Singapore, United Arab Emirates, United Kingdom, United States of America.

4. Direct Marketing

We would like to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. The data that we may use in direct marketing includes:

A. your name and contact details;

B. your demographic data;

C. the products and services provided to you by Wonder App, or any Shareholder;

D. your saving and spending patterns and behaviour; and

E. your financial background.

We may directly market the following classes of services, products, and subjects:

A. financial, fiduciary, banking and related services and products;

B. reward, loyalty or privileges programs and related services and products;

C. services and products offered by any Shareholder;

D. services and products offered by our co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be); and

E. donations and contributions for charitable and/or non-profit making purposes.

Along with us, the following persons may provide or solicit (in the case of donations and contributions) the above services, products and subjects:

A. third party financial institutions;

B. third party reward, loyalty, co-branding or privileges program providers;

C. our co-branding partners; and

D. charitable or non-profit making organisations.

We may also provide your data to any of these people for them to use in directly marketing the same services, products and subjects to you. Wonder App will always first obtain your consent (which includes an indication of no objection) for that purpose. We may receive money or other property in return for providing your data to these other persons, but we’ll tell you if this is the case when obtaining your consent.

You can change your mind about giving consent for us to use or provide to other persons your data for use in direct marketing, as set out above. Just let us know at any time.

5. Personal data of another person

Where you have provided us with another person’s personal data, you should provide him/her with a copy of this PICS and inform them of how we may use his/her data.

6. Access and correction of your personal data

You have the following rights according to the law:

A. to check what data of yours we hold and be provided with a copy of it;

B. to require us to make changes to any data that is inaccurate;

C. to withdraw any consent that you have previously given us with respect to our use of your personal data;

D. to know our policies and practices on data;

E. to be told what kind of data we hold and what you have access to; and

If you want to exercise any of these rights, see the Privacy Policy page on our website or let us know via the Wonder App, by email to support.hk@agent.wonder.app, or send a letter to:

Data Protection Officer

Suite 05-181, 5/F, The Quayside, 77 Hoi Bun Road, Kwun Tong, Hong Kong

We have the right to charge a reasonable fee for the processing of any data access request you make. We will never charge a fee unless you are requesting a paper record to be sent to you.

7. Security

Once we receive your data, we’ll do our best to protect it because the security of your personal data is important to us. We have technical and organisational security measures in place to safeguard your personal data (including personal data in transit and storage). These security measures ensure that the confidentiality and integrity of your personal data is not compromised. Multiple layers of protection have been put in place to protect against leakage of personal data to external parties. Personal data will be encrypted by strong data encryption algorithms using encryption keys unique to us and with proper key management. When using external service providers, we require that they adhere to certain security standards mandated by us (as applicable). Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.

You should also be aware that the Internet (including applications which use the Internet for data transfer) may not be a secure form of communication and sending us personal data over the Internet may carry with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when the sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than your country of residence.

Wonder App retains personal data in line with applicable legal and regulatory obligations and for business and operational purposes. In the majority of cases, this will be for 7 years from the end of your relationship with us. You can ask us to permanently delete some or all of your data earlier than this but we can only do so if:

A. we have no legal or regulatory obligation to retain it; or

B. we don’t need it to provide a service that you would still like us to provide to you.

If we can’t permanently delete your data promptly after you ask us, please be sure that we’ll let you know.

We may record and monitor electronic communications with you to ensure compliance with legal and regulatory obligations and internal policies.

You should also read our Privacy Policy when using our online services.

The English version prevails if there is any inconsistency between the English and Chinese versions of any of this Wonder App PICS.

This Wonder App PICS is provided to you under Hong Kong’s Personal Data (Privacy) Ordinance and Code of Practice on Consumer Credit Data.