DogPay Privacy Policies
Last updated: July 14, 2025
INTRODUCTION
This Privacy Policy ("Policy") explains how Pooltech Limited ("DogPay") and its affiliates (hereinafter also referred to as "we", or "us") collect, use, and protect personal data provided by you.
By accessing or using our service (the "Services") (including but not limited to DogPay Card as defined in the DogPay Card Terms), you consent to the practices described herein. For regulatory compliance, DogPay acts as the "Data Controller" under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and relevant money service regulations.
1. REGULATORY COMPLIANCE
1.1 Legal Framework
This Policy complies with PDPO, AMLO, and all applicable Hong Kong laws governing money service operations.
2. PERSONAL DATA COLLECTION
2.1 Customer Due Diligence (CDD) Data
We collect personal data for anti-money laundering ("AML") and counter-terrorist financing ("CTF") and other purposes stipulated by Article 4, including but not limited to:
- Individuals: Full name, Hong Kong Identity Card/passport details, proof of address, date of birth，Email Address, Contact Phone Number.
- Entities: Business registration certificate, articles of association, identification of Ultimate Beneficial Owners ("UBOs") (where ownership exceeds 25%)，Contact Email of Authorized Representative、Business Contact Phone Number，Purpose of account opening.
- Transactions: Amount, purpose, beneficiary details, and geographic origin for transactions over HK$120,000 or suspicious activity.
2.2 Additional Information for AML/CTF
- Political Exposed Person ("PEP") status disclosures.
- Source of funds and business activity documentation.
- Sanctions screening data against UN Security Council lists and Hong Kong Monetary Authority restricted parties.
3. DATA COLLECTION METHODS
3.1 Directly Provided by You
- Registration information for executives, directors, employees, or legal representatives.
- Financial details (bank accounts, payment methods) for transaction processing.
- Updates to UBO information or business structure changes.
3.2 Automatically Collected
- Transaction metadata (amount, currency, IP address, device information).
- Service usage data (browser type, visit duration, clickstream patterns) for operational analysis.
4. USE OF PERSONAL DATA
We use data for:
- Performing contractual obligations and providing Services.
- Complying with AMLO, PDPO, and other regulatory requirements (e.g., CDD, sanctions screening).
- Detecting and preventing fraud, money laundering, or terrorist financing.
- Administering Services (troubleshooting, data analysis, system maintenance).
- Improving Service quality and delivering relevant product updates.
- Responding to legal requests or regulatory investigations.
- Conducting market research, surveys, promotions and contests, and analysing your preferences, interests and behaviour in relation to the Services.
5. DATA DISCLOSURE
5.1 Mandatory Regulatory Disclosures
- To the Joint Financial Intelligence Unit (JFIU) for suspicious transaction reports.
- To Hong Kong Customs and Excise Department for license compliance checks.
- To law enforcement agencies in response to court orders or legal processes.
5.2 Authorized Third Parties
- Our third party service providers who help us provide, operate, maintain, secure and improve the Services/Products (including but not limited to any “Know Your Client” or other blockchain analytics service providers, credit card networks, banks or financial institutions, payment processors, merchants, loyalty programs partners, and service providers that provide website hosting, data analysis, information technology, mailing, telecommunications, human resource, data processing, payments, credit references or other services).under confidentiality agreements.
- Any person or entity that is part of DogPay and its affiliates who is under a duty of confidentiality to the disclosing entity.
- Professional advisers of DogPay and its affiliates.
- Any person or entity that we engage or participate in for the purposes of marketing, advertising, or promoting our Services, such as social media platforms, online platforms, or third party websites.
- Any person to whom we are under an obligation or otherwise to make disclosure pursuant to legal process or pursuant to any foreign or domestic legal, tax, and/or regulatory obligation or request.
- Any person or entity that you authorize or consent to receive your Personal Data, such as your authorized representatives, agents, advisors, or beneficiaries.
- Any actual or proposed assignee or business transferee of DogPay and/or its affiliates.
6. DATA STORAGE AND TRANSFER
6.1 Storage Location
- Personal data is stored in Hong Kong or other jurisdictions with adequate data protection laws.
- Cross-border transfers comply with PDPO's requirements, using standard contractual clauses for data protection. Your consent to this Privacy and your submission of such information represents your agreement to that transfer and storage.
6.2 Security Measures
- Physical, technical, and organizational safeguards (e.g., encryption, access controls, staff training).
- Segregation of customer data from operational systems to prevent unauthorized access.
7. DATA RETENTION
- Transaction records and CDD documents are retained for at least 5 years as required by AMLO.
- Personal data is deleted when no longer necessary for regulatory compliance or service provision.
- Retention periods are outlined in our [Data Retention Policy](INSERT LINK). By accessing/using our Services you are giving a consent for us to retain your Personal Data.
8. YOUR DATA RIGHTS
Under PDPO, you have the right to:
- Request access to or correction of your personal data.
- Object to direct marketing or data processing for specific purposes.
- Withdraw consent for data use (where applicable).
- Transfer data to another service provider in a structured format.
To exercise these rights, contact our Data Protection Officer at [email protected].
9. COMPLAINTS HANDLI
- Submit data-related complaints to our Compliance Department at [email protected].
- We will acknowledge complaints within 5 business days and provide a written response within 30 days.
- Unresolved complaints may be referred to the Office of the Privacy Commissioner for Personal Data.
10. COOKIES AND TRACKING
While you access the Site, we may use the industry practice of placing a small amount of data that will be saved by your browser (“Cookies”). This information can be placed on your computer or other devices used to visit the Site. This information helps us recognize you as a customer, collect information about your use of our Services to better customize our services and better your experience.
- Analytical cookies to measure service usage (e.g., Google Analytics).
- Functional cookies to enhance user experience (e.g., session management).
- You may disable cookies through your browser settings, though this may affect service functionality.
11. POLICY UPDATES
We may update this Policy to reflect regulatory changes or service improvements. You agree that DogPay may update this Policy at any time by posting the amended version on our website and associated application program interface or mobile applications or sending the latest Policy to you via email. Your use or continued use of any Services after such amendment shall be deemed as your acceptance and agreement to the same.
12. CONTACT INFORMATION
For privacy-related inquiries: