We are dedicated to upholding the highest standards of security, transparency, and integrity in all our operations. We understand the critical importance of safeguarding your personal data, and this Privacy Policy outlines our unwavering commitment to protecting it.
Our Commitment to Your Privacy
As a leading provider of cross-border clearing and settlement infrastructure for global financial institutions, we collect and process information essential to deliver our specialized services, which include cross-border exchange rate management, cross-border payments, and cross-border regulatory compliance technology. Our focus is on serving global banks, remittance operators, and fintech companies with comprehensive digital cross-border fund solutions, driving industry transformation, and establishing a leading edge in international clearing and settlement for Hong Kong Dollars, offshore RMB, and US Dollars.
This Privacy Policy details how XHUBS FINTECH LIMITED handles information concerning visitors to our website (even if they do not become clients), entities and individuals who register for and utilize our services, and anyone who communicates with us via telephone or in writing.
We urge you to read this Privacy Policy thoroughly, in conjunction with our Terms of Use and any other referenced documents. For the purpose of this policy, "personal data" refers to any information that can directly or indirectly identify an individual, such as name, address, and contact information.
Should you have any questions or require clarification on any aspect of this Privacy Policy, please do not hesitate to contact us using the information provided below. We are here to assist you with any concerns.
1. Information We Collect and How We Obtain It
We gather only the information necessary to provide you with the services you request, handling it with the utmost care and subject to stringent controls to minimize misuse, including unauthorized access or disclosure.
Information You Provide Directly
To establish an account or utilize XHUBS FINTECH LIMITED services, you will be required to furnish identifying information about yourself (e.g., name, address, email address), your organization, and supporting documentation to verify the details provided.
For payment processing, you will need to supply information essential for facilitating the transaction, such as beneficiary details, bank account information, and source of funds.
Throughout our business relationship, we may request additional documentation to ensure compliance with our legal obligations, including anti-money laundering regulations. This may encompass, but is not limited to, documents verifying previously submitted information or proof of fund origins.
Information Collected Through Your Use of Our Digital Platforms
Our website and applications utilize cookies to enhance your user experience, prevent fraud, and deliver relevant internet-based advertisements. For detailed information on our cookie usage and purposes, please consult our comprehensive Cookie Policy.
To improve our services and facilitate new product development, sessions of participants in the XHUBS FINTECH LIMITED user community may be recorded. This is always done with your explicit consent, which you are free to withdraw at any time.
For the detection and prevention of fraud and cybercrime, we collect data including session details, device information, and IP addresses to verify the legitimacy of account logins.
Publicly Available Information
For individuals who are not registered users, we may use publicly available information or data from third parties (where you have consented to its sharing) to inform you about products and services relevant to your business needs.
Transactional Information
Once your account is fully established and you begin transacting with us, we will collect, process, and store your XHUBS FINTECH LIMITED financial and transactional data. This includes details such as the amount, currency, transaction type, source of funds, exchange rate, recipient name, and bank details.
Information Received from Third Parties
To protect both our organization and our clients from fraud, we verify the information you provide with anti-fraud agencies and electronic identity verification services. In the course of this verification, we receive and process information about you from these services. Information may also be obtained from credit reference agencies.
Communications
All telephone calls are recorded, and correspondence is retained for quality control and training purposes, as evidence of transactions, and to fulfill regulatory requirements. Any information you disclose to us will be securely held within these records.
Information Regarding Non-Registered Individuals
Connected Parties
XHUBS FINTECH LIMITED will collect information about parties connected to a XHUBS FINTECH LIMITED client (e.g., company directors or shareholders) during the business relationship to comply with our legal obligations. When clients provide this information, they are responsible for bringing this Privacy Policy to the attention of the individuals concerned.
Beneficiaries
XHUBS FINTECH LIMITED will collect information necessary to facilitate payments to individuals who may not be XHUBS FINTECH LIMITED clients. This includes names and bank account details required by regulations to process the payment.
2. How We Utilize Your Information
We use your information for various critical purposes to ensure the seamless delivery of our services and compliance with regulatory mandates.
Account Registration and Administration
Your information is used to enable your registration with us. Once your account is active, we will use your details to communicate with you and respond to inquiries or requests. We may also use your information for account administration, which includes contacting you to update your account details (ensuring our records are current) or to inform you of changes or improvements to our products or services that may affect your experience.
Service Delivery and Product Fulfillment
We leverage your information to provide you with our products and services and to meet our contractual obligations to you. Additionally, we may need to notify you of any developments pertaining to our offerings.
Crime Prevention and Detection
We are subject to stringent anti-money laundering and counter-terrorist financing regulations, necessitating thorough due diligence on our clients. This may involve the use of electronic verification tools. As part of our verification processes, we may require copies of identification documents and proof of address. We may periodically request additional documentation and information throughout our business relationship to ensure ongoing compliance with our anti-money laundering and counter-terrorist financing obligations.
Direct Marketing
We may utilize your information to keep you informed about products and services from XHUBS FINTECH LIMITED Group Companies, announce new offerings, or solicit feedback on your experience with us. Further details on managing your preferences, including opting out, are provided below.
Monitoring and Quality Assurance
All our telephone calls are recorded for security and training purposes.
3. Information Sharing Practices
We adhere to strict data protection laws when sharing information, maintaining rigorous controls over security and accessibility. Our information access, processing, transmission, and security standards are consistent across XHUBS FINTECH LIMITED Group Companies.
XHUBS FINTECH LIMITED Group Companies
"XHUBS FINTECH LIMITED Group Companies" refers to entities owned (in whole or in part) by [Parent Company, if applicable, otherwise state "our parent company"], including but not limited to those listed below. We only share information in accordance with data protection laws and subject to strict controls on security and accessibility.
Banking Partners
XHUBS FINTECH LIMITED collaborates with various banking partners globally to ensure the swift and efficient routing of your payments. When you conduct transactions with XHUBS FINTECH LIMITED, we may need to share your information with payment providers or banking partners outside your immediate region (e.g., if you request a USD payment to China, funds may clear through an intermediary bank in the US before reaching the final destination in China).
For transparency, verification, and legal compliance, certain information is required on the payment, which may include:
- Your name
- Your date of birth
- Your address
- Beneficiary details
- Your national identity reference (e.g., passport)
Furthermore, if you utilize the services of one of our banking partners, and/or a banking partner requests specific data about you with your authorization, we may share your data to facilitate the provision of relevant banking services to you.
Trusted Partners
If you were introduced to XHUBS FINTECH LIMITED by one of our trusted partners, we may share your information to fulfill our contractual obligations with that partner.
We may also collaborate with trusted partners to provide financial services to you. To ensure suitable financial services are offered, we may share your data and information with these partners to assess your eligibility, creditworthiness, and credit. We impose strict confidentiality obligations on our trusted partners, prohibiting them from using your data for any other purposes. We also require them to implement sufficient technical security measures to protect your data.
Additionally, we may share your details with a trusted partner for marketing purposes if you have provided your explicit consent.
Other Third Parties
We may share your information with trusted companies providing services to us under confidentiality agreements, or with companies that assist us in meeting our obligations to you and our regulators (e.g., processing card transactions or verifying documentation). These companies are prohibited from marketing other services to you.
These trusted companies may be located outside your country of residence or the XHUBS FINTECH LIMITED entity you transact with (and if you are an EEA resident, potentially outside the EEA). XHUBS FINTECH LIMITED consistently ensures that any such company is based in a country with adequate data protections under its law, or that we impose contractual obligations or require them to be certified with a protection framework deemed suitable by XHUBS FINTECH LIMITED. We perform due diligence to ensure third parties comply with applicable legal and contractual requirements.
If you are a seller on an e-commerce platform, we may share information with those platforms to aid in the detection and prevention of fraud, money laundering, dealing in counterfeit goods, and other criminal or abusive behaviors. We provide information allowing such platforms to identify XHUBS FINTECH LIMITED accounts used by their sellers, and for these specific accounts, provide data about the account holder, associated individuals, outgoing payments, linked accounts, and indications of suspicious activity.
Furthermore, we may share your information with any person acting on your behalf, provided you have granted us permission to do so.
Regulators and Law Enforcement
We may be legally compelled to provide necessary information to governmental departments, regulatory bodies, law enforcement/tax/customs agencies, courts of law, or other third parties.
We will never sell any personal data we hold about you.
4. Data Retention Policy
XHUBS FINTECH LIMITED will retain your information only for as long as necessary to provide our services and will not hold or process your information beyond legal requirements. The criteria for determining appropriate retention periods include:
- Regulatory requirements applicable to XHUBS FINTECH LIMITED.
- The potential for legal claims to be brought against XHUBS FINTECH LIMITED.
- The necessity of the information to deliver our services to clients.
- The legal basis for processing your information (e.g., consent).
Information concerning connected parties and beneficiaries, who may not be XHUBS FINTECH LIMITED clients, is stored for a period necessary to comply with applicable legal obligations.
5. Communication Preferences
We communicate with you regularly via email and phone to provide exceptional customer service and fulfill requests.
Additionally, we use your email address, phone number, and postal address to:
- Provide notifications as part of the onboarding and trading lifecycle.
- Inform you of important changes to our products and services.
- Send notices and disclosures required by law.
Due to the service-oriented nature of these communications, you cannot opt out of receiving them.
Marketing Communications
XHUBS FINTECH LIMITED Group Companies would like to keep you informed about our products and services.
Once you become a client of XHUBS FINTECH LIMITED, XHUBS FINTECH LIMITED Group Companies may use your information to provide product information, and relevant rate and market updates tailored to you and/or your company.
We may also use your information (whether you are a registered XHUBS FINTECH LIMITED user or a website visitor) to keep you informed about general products, market updates, or rate movements.
If you wish to change your communication preferences, including which communications you receive or how you receive them, or if you decide you no longer wish to receive marketing communications, you can unsubscribe at any time by:
- Emailing our Privacy Office.
- Managing your preferences through the website: https://xhubs.tech, if you are a registered user.
- Clicking the unsubscribe link at the bottom of any marketing email you receive.
Opting out of marketing communications will not affect the service you receive from us, and you are free to change your mind as often as you like.
6. Your Data Rights
We acknowledge and uphold the rights outlined below. While some of these are legal requirements in certain jurisdictions and not others, we endeavor to comply with all such requests irrespective of jurisdiction. We will require proof of identity and sufficient information to locate relevant data and verify that the requestor is the account holder or acting with their permission.
Non-registered users (e.g., website visitors, connected parties, and payment beneficiaries) possess the same rights as registered users and can contact XHUBS FINTECH LIMITED to exercise them.
For more detailed information regarding your rights, please consult the website of your local data protection regulator.
Right to Rectification
If you identify any inaccuracies in the information held in your account, you may contact us, and we will implement necessary changes, subject to verification of the updated information.
Right to Erasure (Right to be Forgotten)
XHUBS FINTECH LIMITED will retain your information only for as long as necessary, based on our obligations and business needs, in line with our data retention policy. For more information, please refer to the "How long do we keep your personal information for?" section of this Policy. Additionally, you may request the deletion of your data, subject to our legal and contractual obligations.
We will retain a record of your erasure request but will not use this information for any other purpose.
Right to Access
You have the right to request details of the information we hold about you, a description of that data, the purposes for which it is being used, and any parties with whom we share your information. Where legally permissible, we may decline your request or part of it, but we will provide an explanation with our response.
Right to Object to Processing
If you request that we cease processing certain information, we will investigate if there is a compelling legitimate reason for continued processing and will discuss the outcome of our investigation with you.
You cannot object to processing that is a legal obligation or where we must process your information to satisfy a contract to which you are a party.
You can, however, object to marketing communications at any time. Please see the marketing section for more details.
Rights Related to Automated Decision-Making and Profiling
XHUBS FINTECH LIMITED prioritizes human oversight. There will be no scenarios in which profiling or automated decision-making will have a legal impact on you without a person reviewing or making a decision based on the outcome. If you believe you may have been unfairly impacted, please contact us for further discussion.
7. Data Security
We store all data, both electronic and physical, securely to protect its confidentiality, integrity, and availability. Data is stored on servers protected by actively maintained firewalls. We utilize up-to-date anti-virus software, and our servers have restricted access.
If you provide paper-based documentation for identity verification, these will be stored electronically, and the original will be securely destroyed or returned to you.
While the transmission of data over the internet can never be entirely secure, we do not and cannot guarantee the absolute security of information collected or transmitted electronically. However, we take reasonable care to safeguard your personal information.
8. Concerns and Complaints
Should you ever be dissatisfied with how we handle your information, you are welcome to lodge a complaint with us. For further details, please refer to our complaints policy.
While we would greatly appreciate the opportunity to resolve any issues directly with you, you also retain the right to raise any data protection concerns directly with your local data protection regulator if you are unhappy with our handling of your information.
9. Contact Us
For any inquiries or requests regarding this Privacy Policy or your data, please contact our Privacy Office by sending an email to: support@xhubs.tech.
10. Revisions to Our Privacy Policy
We may update this Privacy Policy periodically to reflect changes in legal, technical, or business developments. Any amendments to this Privacy Policy will be communicated by posting an updated version on our website. Once published on our website, the new Privacy Policy will become immediately effective.