- "33 Finance," "the Company," "we," or "us" refers to 33 Financial Services Limited, a licensed Stored Value Facility (SVF) holder under the Hong Kong Monetary Authority (License No. SVF0010).

- "Website" refers to https://www.33finance.com/.

- "Platform" refers to the 33 Finance's website for Cardholder to login.

- "Service" includes but is not limited to, personal cards, gift cards, the Website, the Platform, the 33 eWallet mobile application ("33 eWallet"), and other related products and services provided by 33 Finance.

- "Ordinance" refers to the Personal Data (Privacy) Ordinance (Cap. 486), including its effective amendments.

• 1. We are committed to protecting your personal data and comply fully with the requirements of the Ordinance. To uphold this commitment, we enforce strict security and confidentiality measures for all staff handling your information.
  2. This Privacy Policy Statement ("Statement") outlines how we collect, use, store, disclose, and safeguard your data, as well as your rights concerning your personal information.
  3. By using our Services, you agree to the terms of this Statement. If you do not consent, please discontinue use immediately.
  4. We do not knowingly provide Services to or collect personal data from individuals under the 16 years of age.

• 5. For the purposes listed in Section [9] ("Purposes"), we may collect, use, store, and/or disclose the following categories of information (which, individually or collectively, constitute "Personal Data" as defined under the Ordinance):
     

     Category	Specifications	Primary Usage
     Personal Information	Name	- Account creation and management - Regulatory compliance - Transaction processing - Service provision - Identity verification - Service-related notifications - Marketing and promotions - Direct marketing (unless opted out)
     	Gender
     	Date of Birth
     	Nationality
     	ID Number
     	ID Expiry Date
     	ID Copies
     	Biometric Data* * Collected via e-KYC for identity verification in 33 eWallet.	- Account creation and management - Regulatory compliance - Service provision - Identity verification

     Image Information

     Video or photographic footage* *Recorded via office cameras for security.

     - Customer complaints - Investigate violations - Crime prevention - Regulatory compliance

     Contact Information	Residential Address	- Account creation and management - Regulatory compliance - Transaction processing - Service provision - Process transactions - Customer support - Identity verification - Service-related notifications - Direct marketing (unless opted out)
     	Contact Address
     	Contact Number
     	Email Address

     Know Your Customer (KYC) Information	Source of Funds (e.g., industry, occupation)	- Regulatory compliance
     	Usage of Cards

     Transaction Information	Transaction Records (Time, amount, currency, method)	- Transaction processing - Record maintenance - Regulatory compliance - Security verification - Customer support;
     	Counterparty Details
     	Balance
     	Other transaction related information

     Service Usage Information	Login records and activities logs	- Account maintenance - Service improvement - Customer support - Troubleshooting
     	Customer service interactions* * Collected and recorded during  communication with you

     Information via  Cookies *Cookies are small files sent from a website to your computer that may store information such as your browser version, device model, IP address, and other relevant data. These files help enhance your browsing experience by enabling the website to remember your preferences and improve functionality.	Device identifier (such as IMEI / MEID / IMSI / Android ID / IDFA / IDFV / OAID / SIM IMSI / ICCID.）	- Adaptive page display - No personal data stored
     	device model
     	IP Address
     	Browser Type/Version
     	Location	- Account creation and management - Service provision - Identity verification

  6. We collect personal data from the following sources:
     • (a) Direct interactions: Information you provide to us or that we collect during our interactions with you.
     • (b) Third parties: Partners, service providers, or publicly available sources (where legally permissible).
     • (c) Service usage: Data generated when you use our services, including logs, transactions, and analytics.
     • (d) Security measures: Surveillance systems in our offices (solely for security purposes, in compliance with applicable laws).
  7. If you provide another individual’s data to us, you must:
     • (a) Inform them about this Privacy Policy; and
     • (b) Obtain their explicit consent before sharing their data with us.
  8. Cookies and tracking technologies
     • (a) We use cookies and similar tools to enhance your experience. These are stored locally on your device.
       (b) You can manage or disable cookies through your browser/device settings.
       (c) We do not retain or store cookie-related data beyond your session.
  9. Use of Personal Data
     Your information may be used to: (a) process service applications and verify eligibility; (b) authenticate your identity for logins, transactions, or password resets; (c) provide and maintain our services, including customer support and notifications; (d) improve our services by analyzing usage patterns; (e) conduct direct marketing (only with your consent); (f) investigate violations of terms, laws, or policies; (g) comply with legal obligations and financial agreements; (h) assist in crime prevention and investigations; (i) resolve transaction disputes; (j) cooperate with law enforcement; and (k) fulfill other legitimate purposes related to these activities. The specific data used may vary depending on the situation.

• 10. We implement strict safeguards, including but not limited to, restricting access to authorized personnel only, encryption for data in transit and at rest, secure storage facilities and regular security audits.
  11. Our service providers (in Hong Kong or overseas) are contractually required to maintain confidentiality, prevent unauthorized access, and comply with data protection standards.

• 12. Your information may be stored in Hong Kong or overseas, depending on the operational needs.
  13. We retain data only as long as necessary for its intended purpose or as required by law, tax, or audit obligations.
  14. Unnecessary data is securely deleted unless legal or public interest requirements mandate retention.

• 15. For the purposes listed in Section 9, we may share your data with: (a) third-party service providers under confidentiality agreements; (b) merchants and payment processors involved in your transactions; (c) third parties you designate; (d) regulators, law enforcement, or financial institutions (where legally required); and (e) our affiliated companies.
  16. Non-identifiable information may be for analytics or research purposes.

• 17. We will only use your data for direct marketing with your explicit or implied consent, and you may opt out at any time.

• 18. You have the right to access, correct, or request deletion of your personal data, as well as without consent for marketing. Requests should be submitted to our Data Protection Officer at:Data Protection Officer
      33 Financial Services Limited
      710, 7th Floor, Ocean Centre, Harbour City, 5 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong
      Email: privacy@33finance.com
      Processing times may vary, and a reasonable fee may apply for excessive requests. We reserve the right to refuse unreasonable or unlawful requests.

• 19. This Statement is provided in English, Traditional Chinese, and Simplified Chinese; the English version prevails in case of discrepancies.

• 20. We may update this Statement periodically, with changes effective immediately upon posting. The latest version will always be available on our website Latest Updated on 25 April 2025.