The World First Group prides itself on offering the highest levels of security, transparency and integrity when it comes to protecting our clients' interests.
This policy applies to information that the World First Group may collect about visitors to our website, companies and individuals who register for our services and continue to make use of our services and any other person who corresponds with us over the phone or in writing. It's purpose is to set out the policies and practices of the World First Group in respect of protecting personal privacy in accordance with applicable laws.
Our aim is to give you reassurance that any personal information will be used fairly and only for the purposes for which it was collected.
- only information which is necessary for adherence to the regulations and/or improvement of our service is collected;
- personal information is collected fairly; and
- personal information is stored securely.
When companies in the World First Group collect, process and store personal information they will only do so in accordance with the internal policies of the group. In order to create a group standard when collecting, storing and processing personal information these policies, in addition to considering any domestic or local requirements, take into account requirements under the UK’s Data Protection Act, 1998 (“DPA”). Therefore, in respect of customers of World First Asia, the Personal Data (Privacy) Ordinance (“the Privacy Ordinance”) will apply if there is a conflicting provision between the DPA and the Privacy Ordinance.
If you have any further questions about data protection with the World First Group please don’t hesitate to get in touch with your dedicated dealer or our Data Protection Officer who can be contacted at firstname.lastname@example.org and we will do our best to alleviate any of your concerns.
We use your information for the following purposes:
How do we collect information about you?
We collect information about you when you visit our website, register for an account (whether online or by completing our paper based forms) or when you correspond with us over the phone, via email or in writing.
When you register for an account with us we collect, process, hold, store and use information including (but not limited to): your name, postal address, email address, telephone numbers, date of birth and identity card or passport information. Once your account is fully set up and you begin to transact with us we will collect, process, hold, store and use financial and transactional information.
What do we use your information for?
The law says that personal information shall be obtained, used and disclosed fairly. We use your personal information to allow us to process your registration, process any transactions you may book through us and to maintain the accuracy of information on your account.
Registration and administration
We use your information to enable you to register with us. Once you have an account with us we will use your details to contact you and to reply to any queries or requests. We may use your information in the administration of your account, which includes us contacting you in order to update your account details (this assists us with keeping our records as up to date as possible) or in order to notify you of changes or improvements to our products or services that may affect our service to you.
Our products and services
We use your information in order to supply our products and services to you and to meet our contractual obligations to you. Additionally we may need to notify you of any changes relating to our products and services.
Prevention and detection of crime
We are subject to strict anti-money laundering and counter-terrorist financing regulations which requires us to undertake due diligence on our customers. This may include the use of electronic verification tools. As part of our verification requirements we may require copies of identification documents and proof of address. We may require additional documentation and information from time to time throughout the course of our business relationship with you to ensure we comply with our anti-money laundering and counter-terrorist financing obligations.
We may need to pass your information on to Governmental departments, regulatory bodies (including the Hong Kong Customs and Excise Department), Inland Revenue Department, the police/law enforcement agencies or to a court of law. This would be done, for example, to assist in the prevention of a crime (money laundering/fraud), to meet legal requirements or for other lawful purposes.
We may use your information to keep you up to date concerning our products and services. The relevant marketing services, products and other subjects are set out in more detail in the personal information collection statement in the agreement in our t&c’s which govern our business relationship.
You will be able to update your marketing preferences at any time by logging into your WFO account or by following the unsubscribe link contained in the marketing communication.
In case you joined our User Panel and aren't a client, you'll only receive communication regarding the Panel and will always have the option to unsubscribe.
We record all our telephone calls for security and training purposes.
Information security / storage
We have physical, electronic and procedural safeguards that protect your information. We store all data electronically. Data is stored on servers located in the UK and which are protected by actively maintained firewalls. We make use of up-to-date anti-virus software and the servers have restricted physical access.
If you provide paper based documentation we may retain the paper documents in addition to saving copies in an electronic format.
Transmission of data on the internet, including the sending of emails, can never be completely secure. We do not and cannot guarantee security of information collected or transmitted electronically however, we take reasonable care to safeguard your personal information.
World First Group Companies
We may share your information with other companies in the World First Group in order to provide you with access to our services. While other World First Group companies are based outside of Hong Kong we ensure that data protection measures are consistent across the World First Group.
We may need to share your information with domestic and international regulators including: the UK Financial Conduct Authority, HM Revenue and Customs, the Hong Kong Customs and Excise Department, and Inland Revenue Department or with law enforcement agencies.
We may need to share your information with third parties in order to process your transactions e.g. our banking counterparties.
Additionally owing to the nature of our business we may need to share your information with people or organisations outside of Hong Kong such as intermediary or beneficiary banks: e.g. you request us to make a USD payment to China the funds would be cleared through an intermediary bank in the USA before reaching China. We are required to include certain information on the payment which may include your name and address.
We will not disclose your personal information to any third party unless we have your consent, are required to by law or have previously informed you. We may share your information with anyone that you have given us permission to, any person acting on your behalf or with a co-branded WorldFirst partner who may have introduced you to us.
We may share your information with trusted companies providing services to us under confidentiality agreements or to companies that assist us in providing our services to you e.g. card transaction processing. These companies do not have any rights to share your information with other third parties (unless required by law) or to market other services to you.
Further detail as required under the Hong Kong Privacy Ordinance is contained in the personal information collection statement in our t&c’s which govern our business relationship.
We do not sell any personal data that we hold about you.
How do I request information?
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 which we share your information. You also have the right to require us to correct any inaccuracies in the personal data which we hold about you.
We may charge you an administration fee for providing this information. Requests for access to data or correction of data should be made in writing to the Data Protection Officer at email@example.com for further information.
How long is personal information retained?
WorldFirst will only retain your information for as long as is necessary but usually no more than 6 years after the end of the business relationship.
How is this policy updated?
We may amend this policy from time to time. If we make any substantial changes to the way we use your personal information we will notify you by posting a prominent notice on our website.