In this Statement, the following terms shall have their respective meanings:
(a) "FLOW AI" means FLOW AI PTE. LTD. (the "ROCKFLOW", "Company", "we" or "us").
(b) "data subject", in relation to personal data, means the individual who is the subject of the data;
(c) "personal data" means any data:
(i) relating directly or indirectly to a living individual;
(ii) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
(iii) in a form in which access to or processing of the data is practicable;
(d) "non-personal data" means any data not falling within the meaning of "personal data";
FLOW AI is committed to providing its clients with excellent securities services. Based on your service needs, we will collect and use different types of your personal data and non-personal data. We treat the use and confidentiality of our clients' personal data and non-personal data seriously.
The security and privacy of our clients' personal data and non-personal data is a matter of utmost importance for FLOW AI. We are committed to protecting the privacy, confidentiality, and security of our clients' personal data and non-personal data.
Where our operations are also subject to privacy legislation, we will seek to comply with all such applicable laws and regulations to the extent that it is possible for us to do so. Where there is a conflict between different systems of laws, we will, in most cases, comply with the system of law that imposes a stricter standard on us.
Please note that this Statement may be amended from time to time, with prior notice to you. Nevertheless, you are advised to check the latest version of this Statement on our websites on a regular basis.
FLOW AI may collect personal data provided voluntarily by visitors to this website/application.
Individual clients (which includes you) may be required to provide us with the following data:
(a) their personal data, including name, age, occupation, marital status, email address, telephone number, personal identity information, biometric data, photograph and video, electronic signature, address and other contact information, location data, financial information, credit history, source of wealth, risk tolerance, investment experiences and objectives;
(b) transaction records;
(c) account balance and securities portfolio;
(d) IP address, browser type and version, time zone settings, browser plugin types, operating systems or platform and device data (including where the IMEI number of mobile device, wireless networks and general network data);
FLOW AI may also obtain your personal data from publicly available sources of information, recording telephone conversations and/or communications by using electronic media, or from third party risk intelligence applications.
Your personal data and non-personal data will be recorded when you visit this website/application, used for the purposes of data analysis, including analyzing the number of visitors to the website/application. For further information on how we make use of cookies, please refer to our Cookie Policy.
We will only use the personal data we collect for the purposes set out in this Statement. If you do not supply the personal data requested, we may not be able to provide or continue to provide our services to you, including without limitation, providing you with trading services in respect of certain markets and/or products. Your personal data (whether individually, or aggregated with the personal data of other people) may be used for the following purposes:
(a) Providing you with our products or services (including the provision of financial advice);
(b) Verifying your identity as part of the initial and on-going Know-Your-Client (KYC) due diligence process and otherwise for the purposes of complying with anti-money laundering laws and regulations which we are subject to;
(c) Conducting matching procedures (which broadly includes comparison of two or more sets of your personal data, for the purpose of taking actions adverse to your interests, such as declining an application);
(d) Conducting or arranging for you certification services for client identity verification purposes;
(e) Dealing with service applications submitted by you, your guarantors or your security providers;
(f) Performing credit checks, verification procedures, data verification, due diligence and risk management processes;
(g) Assisting other financial institutions to conduct credit checks and collect debts;
(h) Assessing your and your guarantors' and security providers' credit worthiness;
(i) Designing financial and other related services and products for your use;
(j) Promoting and marketing certain services and products to you (please refer to the section entitled "Use of Data in Promotion and Direct Marketing" below for further details);
(k) Determining the amount of debt owed to us by you, your guarantors and/or your security providers ;
(l) Collecting debts from you, your guarantors and your security providers;
(m) Complying with any applicable laws, rules, regulations, court orders or the requests or requirements of any regulatory body;
(n) Enabling any of our actual or proposed transferees / assignees to assess any proposed merger, re-organization or other similar process;
(o) Any purposes allowed by applicable laws;
(p) Defending our rights or participating in any legal or administrative proceedings;
(q) Conducting marketing research, surveys and other similar activities;
(r) Generating unique internal identification numbers for organizational and reporting purposes and other forms of statistical analysis;
(s) Generating anonymised statistics, information and reports in relation to, or for the purpose of, the design of our financial products and services and/or the marketing or provision of our services； and
(t) Any functions related to the foregoing.
Personal data held by FLOW AI will be kept confidential, but may be disclosed to the following persons for one or more of the purposes
(a) Any of our officers, employees, agents, contractors or third party service providers who provide administrative, credit data, debt collection, telecommunications, client verification, due diligence, computing, payment, promotional, marketing or other services related to our business operations to us (e.g. IT vendors, electronic storage vendors, biometric authentication service providers);
(b) Any member of the FLOW AI;
(c) Any of your guarantors and security providers or prospective guarantors and security providers;
(d) Any financial institution trading with or intending to trade with you, or any of your counterpart ies in a trade;
(e) Credit data service institutions or debt collecting institutions (where you owe us money or where there has been an event of default (howsoever described));
(f) Any actual or proposed assignee or transferee of FLOW AI, or participant or sub-participant or transferee of FLOW AI in respect of our rights against you;
(g) Any person or entity or data recipient who has already established or intends to establish any business relationship with FLOW AI;
(h) Any certification authority;
(i) Any agencies for compliance with applicable laws, regulations, rules or guidelines regarding the automatic exchange of financial account information or the Foreign Account Tax Compliance Act promulgated by the United States; and
(j) Any local or foreign legal agency, regulatory body, government, tax authority, law enforcement agency, administrative or statutory agency, stock exchange or clearing house, or other self-regulatory agency or industry organization.
FLOW AI may transfer your personal data to other places in accordance with this Statement.
FLOW AI may use your personal data to send you information about products, services and other marketing materials that we think you might be interested in.
You can choose to receive direct marketing materials by email, direct mail and/or other means. If you do not wish to receive such direct marketing materials, you may elect to opt-out at any time by contacting us. FLOW AI intends to use your personal data for direct marketing purposes, for which we have to obtain your consent (which includes an indication of no objection). In this regard, please note that:
In this regard, please note that: (a) Your name, contact details, product and service, investment portfolio information, trading patterns and conduct, financial background and statistics held by FLOW AI from time to time may be used for direct marketing; (b) The following categories of services, products and subjects may be marketed to you:
(i) Finance, insurance, securities, commodities, investment and related services and products and facilities;
(ii) reward, loyalty, co-branding or privileges programmes and related products and services;
(iii) financial or banking products and services offered by our business partners (the names of such partners will be provided to you); and
(iv) donations and contributions for charitable and/or non-profit making purposes;
(c) The above services, products and subjects may be marketed by FLOW AI and/or the following persons:
(i) Any member of the FLOW AI;
(ii) Third-party financial institutions, underwriters, securities, commodities and investment service providers;
(iii) Providers of third-party reward, loyalty, co-branding or privileges programme (the names of such co-branding partners will be provided to you);
(iv) Our business partners;
(v) Charitable and/or non-profit organizations;
(d) In addition to promoting the above services, products and subjects, FLOW AI may provide the personal data mentioned above to any of the persons as mentioned above for the purpose of promoting their services, products and subjects. In order for us to do so, we need to obtain your written consent (which includes an indication of no objection) for this purpose;
(e) If you do not wish FLOW AI to use or provide your personal data to other persons for the direct marketing purposes, please notify us; and
(f) We may receive money or other property in return for providing your personal data to the other persons and, when requesting your consent or no objection we will inform you if we will receive any money or other property in return for providing the personal data to the other persons.
FLOW AI implements protective measures to safeguard and secure personal data to ensure it is protected against unauthorised or accidental access, processing, or erasure. These measures include the following:
(a) Access or use of such data is limited to authorized staff or agents on a “need to know” basis and such data is accessed utilizing secured methods (e.g. personal data is encrypted when necessary);
(b) We do not distribute your personal data to other persons except to the classes of transferees set out in this Statement and for the purposes set out in this Statement;
(c) The use and transfer of your personal data between members of the FLOW AI is subject to strict internal security standards, confidentiality policies, privacy laws and other applicable laws;
(d) We ensure that our employees fully comply with such standards, policies and laws;
(e) We provide training to our staff on the proper handling of your personal data; and
(f) We will not share or sell the U.S. person's mobile information (including the name and phone numbers) to any external parties not under FLOW AI regarding the external parties' marketing and/or promotional purposes.
As we further develop new products and services, we will continue to make every effort to ensure that your personal data is properly used and protected.
You have the right to:
(a) obtain information regarding the processing of your personal data and access the personal data which we hold about you;
(b) request that we rectify your personal data if it is inaccurate or incomplete; and
(c) lodge a complaint with the Privacy Commissioner for Personal Data if you think that any of your data privacy rights have been infringed by us;
You may ask that we erase some or all of your personal data, but please note that we are under no legal obligation to do so, and it may not be legally or operationally possible for us to do so.
If there is a change to any of the personal data that you have provided to us, please contact us.
You should send requests for access to, and correction of, your personal data to us at:
Address: FLOW AI 13 / F, AVIC I. F. TOWER, Chaoyang District, Beijing Email: findus@rockflow.ai
*Please indicate your name, RF account No. and contact number for us to follow up with your request. You may be asked to provide additional information to authenticate your identity in order for us to follow up your request.
Note: In case of any discrepancy between the English and Chinese versions of this Privacy Policy Statement, the English version prevails.
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