Privacy Statement

We take the privacy of our App users very seriously. We ask that you read this privacy statement ("Privacy Statement") carefully as it contains important information about how we will use your personal data. This Privacy Statement forms part of the Terms governing your use of the App (including any products and services that may be provided to you through the App).

  1. Data user

    The App is provided by More Champ Limited (trading as gini) (" we", "our" or "us "). Our registered office is 2/F, Henan Building, 90-92 Jaffe Rd, Wan Chai, Hong Kong.

  2. Collection of personal data
    1. We may collect and process personal data (as defined in the Personal Data (Privacy) Ordinance ("PDPO")) about you when you register for, install, download, access or use the App, or contact us in relation to the App. However, we will only use your personal data as set out below and always in accordance with the PDPO, and while we are not based in the European Economic Area ("EEA") nor do we actively offer our goods and services to, or monitor the behaviour of, individuals in the EEA, we also comply with the European Union's General Data Protection Regulation 2016/679 ("GDPR") as a matter of best practice:
      1. When you register for and use the App, we collect your email address and/or mobile number, date of birth, and track your device ID, which we use as follows:
        • to help us identify you and any accounts you hold with us;
        • to provide you with goods and services via the App;
        • to respond to communications from you;
        • to customise the App and its content to your particular preferences;
        • to advertise promotions or offers to you via the App – please see the section on 'Marketing and opting out' below for further information;
        • to accept or redeem any promotions or offers that you may choose to accept via the App;
        • to carry out research and statistical analysis and create market reports on an anonymised or aggregated basis (which means that we will not identify you individually for the purpose of such research, analysis or reports) to help us better understand our users, and to enhance and develop our App, its content, products and services; and
        • to notify you of any changes to the App or to our services that may affect you.
      2. You agree that all personal data provided by you to us may be used and retained by us for the purposes as stated in section 2.1.1 or as required by any applicable laws and regulations from time to time. If we intend to use your personal data for any new purposes not listed in section 2.1.1 above, we will inform you in advance and you will have an opportunity to refuse to allow us to do so.
      3. When you use the App to access or connect to your online accounts (including online banking accounts), we may collect and process details such as your bank account number, credit card number, transaction history, payment dates and names and addresses of goods and services providers that appear in your account, for the purpose of displaying the account information and transaction feed to you on the App. We or Salt Edge may collect and/or store your usernames, passwords or other authentication details for such online accounts ("Credentials") for the purpose of allowing the App to interface with information protected by your Credentials.
      4. When you accept or redeem any offers or promotions available through the App that result in a payment to be made to you, we will collect your name and bank account number for the purpose of performing the relevant bank transfer to you.
      5. We will not use your personal data for any unlawful purpose. We will not retain your personal data for longer than is necessary. We will keep your personal data while you make use of our services, which may include keeping your personal data for as long as is necessary to respond to any questions, complaints or claims that may be made by you or on your behalf, to show that we treated you fairly, and/or to keep records as required by law.
      6. We do not collect special category personal information as defined in the GDPR, i.e. personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, trade union membership, genetic and biometric data, or data concerning health, sex life or sexual orientation.
      7. We may seek your consent to this Privacy Statement and our use of your personal data in a number of ways depending on the medium in which you interact with us, such as via your signature to confirm you have read our Privacy Statement, verbal consent over the telephone, via an online checkbox or by registering an account for the App.
  3. Disclosure of your personal data
    1. We may disclose your personal data to:
      • other companies within our group, for the purposes set out at section 2 above; and
      • law enforcement and regulatory agencies as may be required by law,
    2. We may also disclose and transfer your personal data (whether in Hong Kong or abroad) to our agents, contractors or vendors (“Service Providers”), provided that they are under a duty of confidentiality to us and we have imposed contractual obligations to ensure they can only use your Personal Data to provide services to us and to you. Such Service Providers may provide administrative, data processing, research and marketing, distribution, telecommunications, shipping, financial, consultancy, professional or other similar services to us to enable us to better fulfil customer orders, manage, store and enhance customer data, and comply with postal regulations. We may also provide your personal data to actual or proposed assignees or transferees of our rights with respect to you in connection with a merger, sale or transfer (whether of assets or shares).
    3. In particular, software and services provided to us by Salt Edge Inc., a company duly incorporated and existing under the laws of Canada with its registered address at 40 King Street West, Suite 2100, Toronto, Ontario, M5H 3C2, Canada ("Salt Edge") are required for the functioning of the App. We may therefore disclose metadata to Salt Edge, and where such metadata includes your personal data, such disclosure will be solely for the purpose of Salt Edge providing the software and services required for the App, and for their related internal (support, management, audit) and regulatory compliance uses. Please note that when we process your personal data, we remain solely responsible for doing so and Salt Edge shall not be liable for any liabilities that may arise. Once you delete your account with us, we will no longer use the software and services from Salt Edge for the purpose of acquiring and/or accessing your Personal Data, and also procure the deletion of all links between your account and the relevant financial institutions.
    4. Other companies ("third parties") may also forward to us additional personal information, (such as, for example, names, mailing addresses and email addresses, as well as demographic and other usage information), when we have news or product offerings that may be of special interest to those individuals. We work to ensure that these third parties have obtained consent before they pass such personal information on to us. Please inform us if you believe we have acquired your personal data this way and you have not given your consent for the third parties to do so, as it is not our intent to make use of personal data which has not been legitimately acquired.
    5. We do not disclose your personal data (whether your name, email address, mobile number, date of birth, bank account or credit card numbers) to any other third parties. Whilst we may create market reports and provide them to third parties, the reports will only show and be based on anonymised or aggregated data so that users will not be personally identified in these reports. Please see the section on 'Marketing and opting out' below for further information.
  4. Storage of personal data
    1. We may store your personal data in the following locations:
      1. Amazon Web Services Singapore and Tokyo
      2. in accordance with Salt Edge's Privacy Policy (
    2. Your personal data may be held at our offices and the Service Providers as described above. Please note that we are (and some of our Service Providers may be) based outside of the EEA and your personal data may be transferred to locations which do not have the same standards of data protection law as within the EEA, but we will ensure the holding and transfer of your personal data complies with equivalent standards of data protection law as best we can to ensure the privacy and security of your personal data. Your consent to this Privacy Statement confirms that you agree that your personal data may be transferred outside of Hong Kong and outside of the EEA accordingly.
    3. We implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which it was collected. The retention period applied to various types of personal data that we hold varies dependent on the respective data collection/usage purpose and relevant legal requirements. We will keep your personal data while you make use of the App and while you have an account with us. Once you close your account with us, we will keep your personal data for as long as is necessary to respond to any questions, complaints or claims that may be made by you or on your behalf, to show that we treated you fairly, and/or to keep records as required by law.
  5. Marketing and opting out
    1. We intend to use your personal data for direct marketing (by email, text message, telephone or post) about our products and/or services, as explained in this section 4, but we cannot do so without your consent. You may be asked separately and clearly to indicate your consent by choosing to opt in.
    2. If you have indicated consent, we will be able to help you discover new financial products, and show you third party promotions and offers in your transaction feed displayed on the App. We refer to these promotions and offers as 'native advertisements' because they will generally relate to (and be displayed under) the same class of products, services, merchants and/or suppliers which are shown in your online account transaction history. For example, if your transaction history identifies a fashion merchant, we may show you promotions and offers available from that or other fashion merchants. Different classes of products, services, merchants and/or suppliers may include: health and beauty; banking and investment; computer software, hardware and accessories; e-commerce and cloud services; education; entertainment; electronics; fashion; food and beverages; gaming; household; music; sports; social media; technology; travel; and transportation.
    3. As stated in section 3.5 above, we do not disclose your personal data to any third-party advertisers but may provide them with reports based on anonymised or aggregated data. For example, if you redeem an offer advertised via the App, we will provide the advertiser with information that an individual has redeemed the offer as well as the date and amount of the transaction relating the offer redemption, but we do not provide the advertiser with your name or phone number.
    4. If you prefer not to receive any marketing communications, you can opt out at any time – please see the section on 'Your rights' below.
  6. Keeping your data secure
    1. We will use technical and organisational measures to safeguard your personal data, for example:
      • access to your account is controlled by your email or mobile phone number and a password that is unique to you;
      • we encrypt your personal data;
      • any personal data that we process or store is done on secure servers.
    2. All processing of your personal data shall be conducted according to the data protection principles as follows:
      1. personal data must be processed lawfully, fairly and transparently;
      2. personal data must be accurate and kept up to date with every effort to erase or correct;
      3. personal data must be processed in a manner that ensures the appropriate security.
    3. In addition, we have appropriate security measures in place to prevent personal data from being accidentally or unlawfully lost, used or accessed. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so or if there is a risk to your rights and freedoms.
  7. Information about other individuals

    If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

    • give consent on his/her behalf to the processing and transfer of his/her personal data; and
    • receive on his/her behalf any notices relating to data protection.
  8. Your rights
    1. You have the following rights, which you can exercise free of charge:
      • Access and rectification: you have the right to know whether we hold your personal data and to request access to and/or correct any inaccuracies of your personal data held by us.
      • Right to be forgotten: you have the right to require us to delete your personal data.
      • Restriction of processing: you have the right to require us to restrict processing of your personal data in certain circumstances, such as if you contest the accuracy of the data.
      • Data portability: you have the right to receive the personal data you provided to us in a structured, commonly used and machine-readable format and/or to instruct us to transmit that data to a third party.
      • Objection: you have the right to object at any time to your personal data being processed for direct marketing and in other certain circumstances, such as if we change our legitimate interests from the basis on which we initially collected and processed your personal data.
      • Not to be subject to automated individual decision-making: while we do not subject you to decisions based solely on automated processing that produces legal effects concerning you or otherwise significantly affecting you, should we ever engage in such processes, we will first notify you and you will have the right to object to such processing.
    2. If you wish to exercise any of the above rights, or make any related complaint or request in relation to your personal data, please contact us in writing at: or at gini, 2/F, Henan Building, 90-92 Jaffe Rd, Wan Chai, Hong Kong.
  9. Our contact details

    We welcome your feedback and questions. If you wish to contact us, please send an email to or you can write to us at gini, 2/F, Henan Building, 90-92 Jaffe Rd, Wan Chai, Hong Kong.

  10. Changes to this Privacy Statement

    We may change this Privacy Statement from time to time. Any changes will be posted on our website or notified by us to you (by email or post, for example).

  11. Questions

    If you have any questions regarding our Privacy Statement, please contact us and we will do our best to answer them.

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