Privacy Policy

Thank you for visiting the Polar Pay Limited ("Polar Pay") Website.

Our Commitment to Your Privacy

At Polar Pay, safeguarding your personal data is fundamental to our operations. This Privacy Policy details how we handle the information you entrust to us. We adhere fully to the requirements of the Personal Data (Privacy) Ordinance (Cap 486 of Laws of Hong Kong). As a licensed Money Service Operator (MSO), our staff are rigorously trained to uphold the strictest standards of security and confidentiality. Our aim is to ensure your experience with our services and Website is secure and worry-free. By accessing or using our Website, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy and our Terms of Use.

How We Collect Your Data

We collect data primarily to deliver and enhance our services, as well as to fulfill our legal and regulatory obligations. This occurs in two main ways:

Information Collected Automatically (Non-Personal Data)

When you browse our Website, we generally do not collect personal data directly. Like many online platforms, we automatically record non-personal information about your visit through technologies such as cookies. These small data files are sent to your device to recognize your browser during future visits and record your interactions. While typically harmless, disabling cookies via your browser settings may affect your ability to fully utilize certain Website features.

The types of non-personal data collected automatically may include: browser type and version, operating system, IP address, server domain name, pages visited, and time spent on pages. This aggregated information is used exclusively for compiling general statistics on Website visitor numbers and usage patterns, helping us to enhance our service delivery and analyze performance. No personal data is collected automatically through these technologies unless explicitly provided by you through another interaction (e.g., a form submission).

Information You Voluntarily Provide (Personal Data)

We collect personal data only when you choose to provide it to us for specific purposes or services. This may occur when you:

  • Make an inquiry or submit a request (e.g., via a contact form, email)

  • Register for an account or service

  • Apply for currency exchange or remittance services, requiring Know-Your-Customer (KYC), Anti-Money Laundering (AML), and sanctions screening checks

  • Initiate a transaction

  • Send us an email with questions, complaints, or feedback

The personal data we may collect includes, but is not limited to: your name, contact details (e.g., telephone number(s), email address, physical address), company details, identification information (e.g., identity card/ passport details), beneficial ownership information, source of funds, financial details (e.g., bank account details for transfers), and any other information necessary to process your request, verify your identity, perform due diligence, or deliver the requested service. This processing may involve the application of Artificial Intelligence (AI) technologies for enhanced KYC, AML, risk assessment, and fraud prevention.

Please be aware that due to our regulatory obligations as an MSO, refusal to supply required personal data, or the inability to complete necessary KYC, AML, or sanctions screening checks, will unfortunately prevent Polar Pay Limited from processing your request, providing services, or entering into a business relationship with you.

When you correspond with us via email for inquiries, complaints, or feedback, we record your personal data to address your communication, process your complaint, or ensure proper follow-up.

How We Use and Share Your Data

We use and share your data strictly to facilitate our services, fulfill our legal and regulatory obligations, and protect against financial crime.

Purposes of Use

The personal data you provide is used for the specified purposes stated at the time of collection. These purposes include, but are not limited to:

  • Processing service applications, executing remittance transactions, performing currency exchange.

  • Verifying identity, conducting Know-Your-Customer (KYC) procedures, performing Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) checks.

  • Screening against sanctions lists, politically exposed persons (PEPs) lists, and adverse media databases (via commercial compliance engines or similar IT platforms) for due diligence and risk assessment. This includes the application of Artificial Intelligence (AI) for advanced data analysis, pattern recognition, and risk scoring to enhance the accuracy and efficiency of our compliance and fraud prevention efforts.

  • Conducting statistical analysis.

  • Preventing fraud and detecting financial crime.

  • Managing other related operational and compliance matters.

Where personal data is provided, we may occasionally send you promotional materials about our products and services. If you prefer not to receive these, you may opt-out by emailing us at info@polarpay.com. Please allow a reasonable period for your request to be processed.

When and With Whom We Share Your Data

Our general policy is to keep all personal data confidential, except when permitted or required by law, or when necessary to provide our money services, including currency exchange and global remittance, to you. We may disclose your personal data to the following categories of parties who assist us in delivering our services or fulfilling our legal and regulatory obligations, solely for purposes consistent with those specified:

  1. Polar Pay Group Entities: Other companies within the Polar Pay group for operational, administrative, and service delivery purposes.

  2. Financial Institutions & Payment Network Partners: This includes banks, remittance agents, payment processors, and correspondent financial institutions (such as SWIFT network partners), whose involvement is essential for processing your currency exchange and remittance transactions.

  3. KYC/AML and Sanctions Screening Providers: Third-party providers of KYC, AML, fraud prevention, and sanctions screening services, including commercial compliance database providers and specialized risk intelligence partners, to facilitate our due diligence and compliance obligations.

  4. Service Providers & Technology Partners: Any personnel, agent, adviser, auditor, contractor, or service provider who provides us with services and advice related to our operations (e.g., IT support, cloud hosting providers, data analytics providers). These third parties are contractually obligated to maintain the confidentiality and security of the personal data and are restricted from using it for any purpose other than providing services to Polar Pay.

  5. Regulatory & Law Enforcement Bodies: Parties to whom we are legally required to make disclosure under any applicable law, regulation, court order, or government request, whether in or outside Hong Kong. This also includes disclosures necessary to protect our rights, property, or safety, or that of our users or others (e.g., for regulatory reporting to the Hong Kong Customs and Excise Department, or investigations).

  6. Business Transfers: Disclosure may occur in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

Safeguarding Your Data

We are committed to protecting your personal data throughout its lifecycle.

Our Security Measures

We take the security of your personal data seriously. We implement reasonable administrative, technical, and physical safeguards designed to protect personal data from unauthorized access, use, disclosure, alteration, or destruction. While we strive to use commercially acceptable means to protect your personal data, it is important to acknowledge that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. We generally do not disclose personal data to third parties unless such disclosure is necessary for the provision of our services, required by law, or with your explicit prior consent. All personal data you provide us is secured on our systems with restricted access, limited only to authorized personnel who have a legitimate business need to access such data. We regularly instruct our staff on our Privacy Policy to ensure their strict compliance.

Data Retention Periods

Personal data you provide to us will be retained for such period as may be necessary to fulfill the specific purposes for which it was collected, as outlined in this Privacy Policy. This includes retention periods required to comply with our legal and regulatory obligations (e.g., anti-money laundering regulations, record-keeping requirements for a licensed MSO), resolve disputes, and enforce our agreements.

Your Data Rights

Under the Personal Data (Privacy) Ordinance, you have specific rights regarding your personal data:

  • You are entitled to be informed by us whether we hold your personal data.

  • You have the right to access such data.

  • You have the right to request correction of such data if they are inaccurate.

Any such data access or correction request must be made in writing and sent to us by e-mail to: info@polarpay.com. Please note that we may charge a reasonable fee for processing any data access request.

Important Considerations

External Links (Hyperlinks)

This Privacy Policy applies solely to this Website. Should you click on any advertisement or hyperlink leading to another website, you will leave our Website. Please be aware that we are not responsible for the privacy and security practices or the content of such external websites. We strongly advise you to review the privacy policy of every website you visit.

Third-Party Responsibility Disclaimer

You should also note that as we have no control over the actions of any third party, the privacy protection stated in this Privacy Policy does not apply to information which has been legitimately disclosed to any third party incidental to or in the course of our operation or in providing our services. We assume no responsibilities for the privacy protection against such third parties.

Policy Updates & Governing Law

Policy Updates

We reserve the right to revise, change, or modify this Privacy Policy from time to time at our sole discretion. Any updates will be effective immediately upon posting the revised Privacy Policy on this Website. We encourage you to visit this page periodically to review any amendments and their effect on your use of this Website. Your continued use of this Website implies your acceptance of such amendments.

Applicable Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People’s Republic of China.

Language Version

This Privacy Policy is written in English language with a Chinese translation. In the event of any discrepancy or conflict between the English version and its Chinese translation, the English version shall prevail.