Privacy Policy Statement

1. Introduction

This Privacy Policy Statement ("Policy") outlines how HONG KONG SINOSKY INTERNATIONAL HOLDINGS LIMITED ("Sinosky", "we", "us" or "our") collects, uses, stores, and discloses personal data in connection with our co-branded prepaid card services (the "Services") provided under the MasterCard Prepaid Card Co-Branded Agreement and UnionPay Prepaid Card Co-Branded Agreement (collectively, the "Agreements") with 33 FINANCIAL SERVICES LIMITED ("33FINANCE"). This Policy is governed by the laws of the Hong Kong Special Administrative Region ("Hong Kong SAR"), including the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

By using our Services or providing personal data to us, you consent to the practices described in this Policy.

2. Collection of Personal Data

We collect personal data directly from you when you:

• Apply for or purchase a co-branded prepaid card (the "Card").
• Reload funds onto your Card.
• Request Services or support.
• Provide feedback or engage in surveys.

Types of Data Collected:

• Identification details (e.g., name, date of birth, identity card/passport number).
• Contact information (e.g., address, email, phone number).
• Financial data (e.g., source of funds for reloads exceeding thresholds set by 33FINANCE).
• Transaction history and usage patterns.
• Other data necessary for compliance with anti-money laundering ("AML") laws and regulations.

Lawful Basis:
We collect data only with your explicit consent or as required by law (e.g., AML obligations).

3. Use of Personal Data

We use personal data for the following purposes:

• Processing Card applications, activations, reloads, and related transactions.
• Complying with regulatory requirements (e.g., KYC, AML).
• Providing customer support and resolving disputes.
• Monitoring and analyzing usage trends to improve Services.
• Communicating updates, promotions, or changes to the Services (with your consent).

4. Disclosure of Personal Data

We may disclose personal data to:

• 33FINANCE and its authorized agents for processing, compliance, or audit purposes.
• MasterCard/UnionPay and their respective networks to facilitate transactions.
• Regulatory authorities (e.g., HKMA) as required by law.
• Third-party service providers (e.g., payment processors, IT vendors) under strict confidentiality agreements.

We will not sell or transfer your data to third parties without your consent, except as permitted by law.

5. Data Security

We implement reasonable technical and organizational measures to protect personal data against unauthorized access, loss, or misuse, including:

• Secure storage of physical and electronic records.
• Restricted access to sensitive data.
• Compliance with 33FINANCE's and MasterCard/UnionPay's security standards.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy or as required by law. Expired or dormant Cards may be subject to fees until balances are redeemed.

7. Your Rights

You have the right to:

• Request access to or correction of your personal data.
• Withdraw consent to data processing (where applicable).
• Lodge a complaint with the Privacy Commissioner for Personal Data, Hong Kong.

To exercise these rights, contact us at [Insert Contact Information].

8. Changes to this Policy

We may update this Policy to reflect legal or operational changes. Revisions will be posted here, and material changes will be communicated to affected users.

9. Contact Us

For inquiries or concerns about this Policy, please contact:

[Insert Name]
[Insert Title]
[Insert Address]
[Insert Email/Phone]

10. Governing Law

This Policy is governed by the laws of the Hong Kong SAR. Disputes shall be resolved through the courts of Hong Kong SAR.

HONG KONG SINOSKY INTERNATIONAL HOLDINGS LIMITED

[Insert Company Seal]

[Authorized Signatory Name and Title]

[Date]