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Personal Information Collection Statement
This Personal Information Collection Statement (“PICS”) is issued pursuant to the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and applies to individuals whose personal data is collected by Paywatch Hong Kong Limited (“Paywatch”) in connection with the provision of our earned wage access and related services (“Services”) in Hong Kong.
1. Purposes of Collection
The personal data we collect from you may be used for the following purposes:
Processing your application for, and providing you with, earned wage access and related financial services;
Verifying your identity and conducting know-your-customer (KYC) and anti-money laundering checks as required under applicable Hong Kong laws;
Administering and managing your account and our ongoing relationship with you;
Complying with our obligations under applicable Hong Kong laws and regulations, including but not limited to the PDPO, the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), and any directions or requirements of regulatory authorities;
Conducting credit assessments and managing credit risk;
Preventing, detecting, and investigating fraud, money laundering, and other unlawful activities;
Providing you with information about Paywatch’s products and services that may be of interest to you, subject to your consent where required; and
Any other purpose directly related to the above or otherwise required or permitted by applicable Hong Kong law.
2. Classes of Persons to Whom Personal Data May Be Transferred
Your personal data may be transferred to, or accessed by, the following classes of persons for the purposes set out above:
Paywatch’s affiliates, subsidiaries, and holding companies within the Paywatch group;
Your employer and their authorized representatives, for the purpose of confirming your employment details and facilitating earned wage access transactions;
Financial institutions, payment processors, and banking partners involved in processing your earned wage access transactions;
Credit reference agencies, fraud prevention agencies, and debt collection agencies;
Government authorities, law enforcement bodies, regulatory bodies, and courts in Hong Kong and elsewhere, as required by law or court order;
Professional advisers such as auditors, legal counsel, and tax advisors retained by Paywatch; and
Third-party service providers engaged by Paywatch to support the delivery of our Services, including technology vendors and cloud service providers, who are contractually bound to maintain appropriate data security standards.
3. Transfer of Personal Data Outside Hong Kong
As part of providing our Services, your personal data may be transferred to, and processed in, jurisdictions outside Hong Kong, including Singapore and other countries where Paywatch operates. Where we do so, we take reasonable steps to ensure that such transfers are carried out in accordance with the PDPO, including ensuring that the recipient affords a level of protection of personal data at least comparable to that provided under Hong Kong law, or that the transfer is otherwise permitted under applicable law. By using our Services, you consent to such cross-border transfers of your personal data.
4. Voluntary Provision of Personal Data
The provision of your personal data to Paywatch is voluntary. However, if you do not provide certain personal data requested by us, we may not be able to process your application or provide you with the relevant Services.
5. Right of Access and Correction
Under the PDPO, you have the right to request access to, and correction of, your personal data held by us. Requests for data access or correction should be directed in writing to our Data Protection Officer at the contact details below. We may charge a reasonable fee for processing a data access request. We will respond to your request within the timeframe required by the PDPO.
6. Direct Marketing
Subject to your consent (which includes an indication of no objection), Paywatch may use your personal data — including your name, contact information, and transaction history — for direct marketing purposes. We may market financial and related services provided by Paywatch, our affiliates, and selected business partners. We will not use or provide your personal data for direct marketing purposes without your explicit consent. You may withdraw your consent to receive direct marketing communications at any time by contacting us at the details below or by following the unsubscribe instructions in any marketing communication. Your withdrawal of consent will not affect the lawfulness of any marketing carried out prior to your withdrawal.
7. Contact Details
If you have any questions about this PICS, wish to exercise your rights under the PDPO, or wish to make a data access or correction request, please contact our Data Protection Officer via the email below or send the letter to:
Data Protection Officer
Paywatch Hong Kong Limited
Address: Suite 2405, 24/F, Universal Trade Centre, No. 3 Arbuthnot Road, Central, Hong Kong
Email: dpo@paywatchglobal.com