Privacy and Data Protection Policy

FastLane Group
Last updated: October 13, 2023
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1. Introduction

FastLane Group (hereinafter, “FastLane”, “we”, “us” or “our”) is dedicated to safeguarding the privacy and security of personal data in full compliance with the Personal Data (Privacy) Ordinance (PDPO) and other relevant laws and regulations in Hong Kong. This Privacy and Data Protection Policy outlines our dedication to protecting your information while complying with the principles of data protection, including those based on the European General Data Protection Regulation (GDPR).

This Privacy Policy serves to provide you with insights into how we manage, gather, utilize, reveal, and process your personal data. Any updates to this Privacy Policy become effective once posted on our website www.fastlane-global.com. We recommend periodic visits to this page for ongoing awareness.

2. Your Consent

The Privacy Policy applies to you, our valued customers, and outlines our practices regarding personal data. It also applies to all employees, contractors, and third-party vendors who may handle your personal data on our behalf.

This Policy is an integral component of the terms and conditions, if applicable, that govern your particular association with FastLane (“Terms and Conditions”). It is essential to read this Policy alongside the Terms and Conditions. If any conflict or inconsistency arises between the terms of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall take precedence to the maximum extent permitted by law.

By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and consent to the collection, use, processing and disclosure of your personal data as described in this policy.

The provision of your Personal Data is voluntary. However, if you do not provide your Personal Data, we will not be able to process your Personal Data for the purposes outlined in this Policy and may cause us to be unable to provide our products and/or services to or accept payments from you.

FastLane does not assert any ownership over the information you provide through our application. You retain all rights to the information you submit via our application.

FastLane owns all copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights associated with us. Usage of these copyrights, trademarks, domains, logos, trade dress, patents, and other intellectual property rights requires our express permission.

3. Definitions

Affiliates means any entities which are engaged by FastLane for the provision of any types of services.

Authorised Intermediary means the natural person and/or Entity which has been authorised by a Company to represent them and to instruct us with regards to the administration and provision of services to that Company.

Company means the Entity which has instructed us, or through the Authorised Intermediary to represent them to instruct us, and to with regards to administration and provision of services to that Company from time to time.

Entity means a company or other body corporate, partnership, limited partnership, or trust as the context requires.

FastLane, We, Our and Us means Fastlane Consulting Limited and any of its subsidiaries, affiliates and associates from time to time.

Personal Data encompasses any information that can directly or indirectly identify an individual, including but not limited to names, identification numbers, contact information, and related information as defined in applicable Data Protection Law which is disclosed or made available to FastLane by or on behalf of the Company in connection with the Services..

Privacy Policy means the Privacy Policy (as amended from time to time) and available at
www.fastlane-global.com.

Professional Business Affiliates means affiliates, professional advisors, service providers or agents, engaged by FastLane at the discretion of FastLane from time to time.

Regulation means the Personal Data (Privacy) Ordinance of the Hong Kong SAR and the European General Data Protection Regulation.

Sensitive Documents refer to any documents containing sensitive personal information, which may include passports, ID cards, bank statements, or any documents obtained during provision of services, compliance checks and KYC procedures.

Platforms include our website, FastLane Group, and any other electronic platforms maintained by us.

Products and/or Services means the services of whatsoever nature to be provided by Us shown on FastLane website, as updated from time to time.

Service Agreement means any agreement in writing (including any agreement evidenced by or contained in application forms) between FastLane and You relating to the Services.

You and Your means the Party or Parties to these Conditions, other than Us.

4. What Personal Data We May Collect

We collect various categories of Personal Data from you, which may include:

4.1. Contact data: Name, username, residential/office address, email address, telephone number(s), and other contact details.

4.2. Personal identification information: Date of birth, gender, tax identification number, passport information, identity card details, country of domicile, nationality, politically exposed person (PEP) status, and sources of wealth.

4.3. Compliance data: Information required for customer/client due diligence obligations, including international sanctions, restrictive measures, and information about relevant and significant litigation.

4.4. Biometric data: Facial images to satisfy anti-money laundering laws and regulations.

4.5. Financial data: Income, expenditure, assets and liabilities, payment information, bank account details, transaction history, credit card information, and other electronic banking data.

4.6. Transaction data: Information about how you use our services, network usage, location when using our services, and interaction history with us.

4.7. User content: Content provided through our products or services, including personal information in documents created on our Platform.

4.8. Background information: Employment, education, family or personal circumstances, and interests where relevant.

4.9. Technical data: Information related to your device or connection, such as IP address, login data, browser types, operating systems, and data collected through cookies and other data collection technologies.

4.10. Preference data: Communication, marketing, and other preferences set up in your account or during surveys or questionnaires.

4.11. Statutory Register data: Information related to interests, offices held, or relationships with corporate entities, partnerships, trusts, or other vehicles.

4.12. Sensitive/Special Category data: Processed when permitted by law under a legal or regulatory obligation or when provided by you as necessary for the services we provide.

4.13 Cookies: Cookies are capable of transmitting information related to you and your utilization of our products and services. This information may encompass details like your browser type, search preferences, IP address, data associated with displayed or clicked-on advertisements, and the timestamp of your activities. Our website is configured to automatically gather anonymous data about our visitors, aiding us in comprehending our website’s audience and their browsing habits. This data is utilized for statistical analysis and to enhance our services.

4.14. Others: Any other data required by any members of FastLane Group and/or their respective contractors, sub-contractors, intermediaries, agents, business partners, or representatives from time to time for the provision of our services.

5. How and When Do We Collect Personal Data

We collect Personal Data through various methods, including:

5.1. Direct collection: You may provide Personal Data directly via phone/video calls, emails, in person, and our website.

5.2. Platform submissions: Information may be collected when you or your Authorised Intermediary submit data via third party platforms such as Dropbox and Google Drive.

5.3. Third-party sources: We may collect Personal Data from your Authorised Intermediary, advisors, related entities, business partners, and corporate clients when providing services.

5.4. Personnel, agents, and consultants: We collect data as necessary in the course of providing services, including order fulfillment and payment processing.

5.5. Other users: Information may be collected when a member of your organization registers an account on our Platform.

5.6. Publicly available sources: Data may be gathered from publicly available sources.

5.7. Recruitment processes: Data may be collected during recruitment.

5.8. Marketing and advertising events: Information may be collected when you respond to our online advertisement, promotions, and marketing initiatives.

5.9. Where we receive data about employees, customers, or other individuals from you, we ensure compliance with applicable data protection laws.

6. How We Use the Personal Data

We use Personal Data for the following purposes:

6.1. Performance of a service: Personal Data is processed to perform services including, but not limited to, accounting services, audit and taxation services, corporate secretarial services, incorporation services, and payroll services, provide customer support, process payments, and satisfy customer due diligence obligations.  To effectively deliver our products and services at FastLane, we rely on the personal data you provide. It is imperative that all personal data submitted to us is thorough, precise, and genuinely accurate.

6.2. Legitimate interests: Personal Data is used for marketing, data mining and analysis, research and development, business administration, legal rights protection, and more.

6.3. Legal obligations: Personal Data is processed to meeting and complying with any applicable laws, regulation, codes of practice or guidelines issued by regulatory authorities.

6.4 When collecting information for purposes beyond those initially disclosed or for objectives unrelated to the original data collection purpose, we will always seek your consent. We will also provide prior notification, unless you provide your express and voluntary consent. Should you wish to retract your previously given consent, you can do so by providing written notice.

7. How We Share the Personal Data

We may share Personal Data as follows:

7.1. Group companies: We may disclose your Personal Data to a parent company, any subsidiaries or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honour this Policy.

7.2. Third-party service providers: We share information with third-party service providers who act as our contractors, strategic partners, or licensors that assist us in providing and supporting our products and services.

7.3. Authorised Person: Any person authorised by you to give instructions or to provide information related to the products and services on your behalf.

7.4. Third-party software: We utilize third-party software to enhance our service processes and efficiency. In doing so, you may grant third-party software providers access to your account and information. We do not control the privacy practices of any third parties.

7.5. Links to third-party websites: Our website might contain links to websites operated by third parties. It’s important to understand that we are not accountable for the collection, usage, maintenance, sharing, or disclosure of data and information by these third parties. If you choose to provide information directly to these websites, please be aware that their respective privacy policies and terms of service will apply. We do not take responsibility for the data processing practices or privacy policies of such external sites.

7.6. Government and law enforcement: Information may be shared with government and law enforcement officials to comply with applicable laws and regulations.

7.7. Business transfers: Your Personal Data may be disclosed and/or transferred as part of any merger, acquisition, joint venture, debt financing, sale of business assets.

7.8. We do not sell, rent, or otherwise make personal information commercially available to any third party, except with your prior permission.

8. Consent

Unless permitted under PDPO, GDPR, or other applicable laws and regulations, we will not collect, use, or disclose your Personal Data without your knowledge and consent.

8.1. Your consent is obtained through provisions in agreements, application forms, or notifications on our Platform.

8.2. If collection, use, and disclosure of Personal Data are necessary for specific purposes, we reserve the right to decline the relevant relationship or services if consent is not given.

8.3. Your use of our Platform, attendance at our events, or submission of Personal Data implies your consent to the described data processing.

8.4. When providing Personal Data related to third parties, you confirm that you have obtained their consent for data collection, use, and disclosure.

8.5. For individuals under the age of 16 covered by the GDPR, explicit consent of the minor’s parent or guardian is required.

9. Cross-Border Data Transfers

We may transfer Personal Data to jurisdictions as necessary for the purposes described, including locations outside of Hong Kong or the jurisdiction in which you receive our services and our group operates, in compliance with applicable privacy and data protection laws and regulations.

10. Your Rights

You have the right to:

10.1. Access: Request access to your Personal Data held by us.

10.2. Correction: Request correction or updating of incomplete or inaccurate Personal Data.

10.3. Restriction: Request restrictions on processing of your Personal Data.

10.4. Objection: Object to processing of your Personal Data based on legitimate interests.

10.5. Withdrawal of Consent: Withdraw your consent for processing of your Personal Data.

10.6. Erasure: Request erasure of your Personal Data in certain cases.

10.7. Data Portability: Request a copy of your Personal Data in electronic form.

10.8. Non-Automated Decision Making: Avoid decisions based solely on automated processing.

11. Data Security

We employ technical and organizational measures to protect Personal Data from unauthorized access, use, disclosure, alteration, loss, or destruction, consistent with applicable data protection laws.

12. Data Retention

Personal Data is retained for as long as necessary for the purposes outlined in this Privacy Policy and applicable record retention policies, and any legal obligations we must meet.  We will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for those purposes.

13. Direct Marketing

We may use Personal Data for direct marketing purposes, subject to applicable laws and regulations. If you wish to opt out or resume receiving direct marketing materials, you may make a written request to our Data Privacy Team.

14. Links to Third-Party Services and Features

Our services may provide links to other online services and third-party features. The privacy practices of these third parties are subject to their respective privacy statements and policies. Review their policies before using their services.

15. Contact Us

For any inquiries, privacy policy-related issues, access, correction, or deletion requests regarding your Personal Data, please contact us at:

Email: hello@fastlane-global.com

16. Amendment

We reserve the right to revise, update, or amend the terms and conditions of this Policy at any time and as needed. These modifications, updates, or amendments will be made available on our website for your reference. Should you continue to engage with FastLane or use our products and services after such changes have been implemented, you are indicating your acknowledgment and acceptance of these modifications, updates, or amendments. Your continued interaction with FastLane implies your consent to abide by the revised terms of this Policy.

We thank you for your trust and assure you that we are dedicated to preserving your privacy and data protection.