1. Purpose of Privacy Policy

The website www.fortukey.com (the “Website”) is operated by FortuKey Holdings Investment Limited (“fortukey we” or ours). FortuKey’s Personal Data Privacy Policy is formulated in accordance with the Personal Data (Privacy) Ordinance to protect customer rights.

While using customer data to provide quality services, FortuKey also attaches great importance to the arrangement of customer data usage. To this end, FortuKey ensures that its employees strictly adhere to legally mandated security and confidentiality standards.

2. Customer Consent

To ensure that customers have full confidence in FortuKey's handling of personal data, customers must read and understand the terms of the privacy policy in detail. In particular, once a customer logs into FortuKey's website, regardless of whether the customer registers on the website, the customer indicates to FortuKey that they accept, agree, promise and confirm:

1. The customer voluntarily discloses personal data to FortuKey with the required consent;
2. The customer will comply with all terms and restrictions of this privacy policy;
3. The customer agrees that FortuKey collects customer information through the customer logging into this website, registering on this website and/or using the services provided by FortuKey; the customer agrees to any future modifications to the privacy policy by FortuKey;

4. The customer agrees that FortuKey's subsidiaries, affiliates, and employees may contact the customer regarding products and services that may be of interest to the customer (unless the customer has indicated that they do not wish to receive such information).

3. Information Collected

1. When customers use this website, customers agree that FortuKey will begin using cookies to track every action of the customer and collect and remember all information left by the customer, including but not limited to the customer's IP address, geographic location, and other data.
2. If customers wish to use the services provided by this website, customers need to fill in and provide the following two types of information:
A. Identity Information. This information can help FortuKey verify whether customers are qualified to register as users of this website, including but not limited to the customer's name, residential address, mailing address, different certificates issued by the customer's country or government that have information proving the customer's identity, related numbers, and all other information that can help FortuKey verify the customer's identity (hereinafter collectively referred to as "Identity Information").
B. Service Information. This information helps FortuKey contact customers and successfully provide services to customers, including but not limited to the customer's phone number, fax number, valid email address, mailing address, and the customer's debit card information and/or other account information (hereinafter collectively referred to as "Service Information").
3. When customers use this website or its services, FortuKey may collect more necessary information through the email address exclusively owned by FortuKey published on this website or other methods that FortuKey considers compliant, in order to improve the functionality of this website, enhance the customer's experience of using this website and its services and their security, or according to orders from courts, applicable laws and regulations, or other government agencies with jurisdiction.

If customers visit any third-party website or any link to cooperating third parties on this website, customers should agree to and comply with the separate and independent privacy policy of that third party. FortuKey assumes no responsibility for the content and activities of these websites or partners.

4. Information Usage Purposes

FortuKey holds customer personal data, and with customer consent, FortuKey (subject to the provisions of this ordinance) may use such personal data for the following purposes:
1. Various personal data collected by FortuKey is only for FortuKey's business operations and other related activities;
2. FortuKey is committed to ensuring that its website is secure and complies with industry standards, and uses other data protection tools, such as: firewalls, authentication systems (passwords and personal identification numbers, etc.) and control mechanisms to control unauthorized system access to the website and data access;
3. FortuKey will store customer personal data confidentially and protect customer personal data from theft. FortuKey employees will also respect customer privacy and will never disclose any data to unauthorized persons;
4. Customers may review and change their personal data stored by FortuKey from time to time;
5. Customers agree that FortuKey will disclose all customer data (and other data) to regulatory authorities and other government agencies in accordance with any legal or regulatory requirements;
6. FortuKey may set and access Cookies on the customer's computer to assist FortuKey in analyzing and understanding the effectiveness of relevant marketing strategies. FortuKey and its employees may use Cookies to track customer browsing on FortuKey's website in FortuKey's products and services. The collected and shared data is anonymous and cannot be individually identified;
7. Customers agree that when FortuKey provides services to customers, FortuKey may authorize companies that are not affiliated with FortuKey to use customer personal data, including companies that assist FortuKey in providing convenient platform services to customers in the form of contracts, assist in preparing and mailing monthly statements, and perform necessary maintenance and development work. FortuKey requires these companies to keep relevant personal data confidential.

5. Account Deletion and Data Management

5.1 Right to Delete Account

Customers have the right to request deletion of their FortuKey account and related personal data at any time. FortuKey respects and protects customers' control over their personal information.

5.2 How to Request Account Deletion

Customers can submit an account deletion request through the following methods:

1. Send an email to FortuKey's official customer service email: market@fortukey.vip, with the subject line "Account Deletion Request";
2. Submit a deletion request through the customer service function within the FortuKey mobile application;
3. Contact FortuKey's customer service hotline, and customer service staff will assist with the deletion request.

5.3 Information Required for Account Deletion

To ensure account security and verify customer identity, when submitting a deletion request, customers need to provide the following information:

1. The phone number or email address used when registering the account;
2. The real name of the account holder;
3. The approximate time and location of the last login (if available);
4. Other identity verification information that FortuKey may require to ensure the legitimacy of the request.

5.4 Account Deletion Processing Procedure

1. FortuKey will confirm receipt of the application within 3 business days after receiving the customer's deletion request;
2. FortuKey will verify the customer's identity to ensure the authenticity and legitimacy of the request;
3. After identity verification is passed, FortuKey will complete account deletion processing within 30 business days;
4. After account deletion is completed, FortuKey will notify the customer via email or SMS.

5.5 Data Processing After Account Deletion

Once the account deletion request is confirmed and processed, FortuKey will:

1. Immediately stop collecting any new data related to the account;
2. Delete or anonymize the following personal data:
   · Account login information (username, password, etc.);
   · Personal identity information (name, address, contact information, etc.);
   · Deletable application usage records and preference settings;
   · Device information and IP address records (to the extent permitted by law);
   · Other personal information that identifies the customer.

5.6 Data Required to be Retained by Law

In accordance with applicable laws and regulations and financial regulatory requirements, FortuKey may need to retain certain data, including but not limited to:

1. Transaction records and financial data (for audit, tax and anti-money laundering compliance);
2. Records necessary to fulfill legal obligations or resolve disputes;
3. Anonymized statistical data that cannot identify individuals;
4. Other data explicitly required to be retained by regulatory authorities.

This data will be securely stored and retained only for the period required by law, and will be securely deleted after the retention period expires.

5.7 Partial Data Deletion

In addition to completely deleting the account, customers can also request deletion or modification of specific types of personal data, including:

1. Update or correct personal identity information;
2. Delete browsing history within the application;
3. Revoke consent for certain data uses (such as marketing promotions);
4. Export a copy of the customer's personal data.

Customers can manage this data through the account settings function within the application or by contacting customer service.

5.8 Consequences of Account Deletion

Customers should be aware that after account deletion:

1. Customers will no longer be able to use the account to log in to any FortuKey services;
2. All data and settings related to the account will be permanently deleted and cannot be recovered;
3. If there are uncompleted transactions or unwithdrawal funds in the account, customers must complete the transactions and withdraw the related funds before applying for deletion;
4. If customers need to use FortuKey services again in the future, they will need to re-register a new account.

5.9 Contact Us

If customers have any questions about account deletion, data management, or this privacy policy, please contact FortuKey through the following methods:

· Customer Service Email: market@fortukey.vip
· Email Subject: Please indicate: Privacy Policy Inquiry / Account Deletion Request
· FortuKey will respond within 5 business days after receiving customer inquiries.

This privacy policy was last updated: December 2024