Legal notice

1. Introduction

Thank you for visiting UKey.com (the “Website”) or using the UKey application (the “App”).

This Privacy Policy is issued by UKEY LIMITED , with its registered address at 19/F, Hip Shing Hong Centre, 55 Des Voeux Road Central, Central (hereinafter referred to as “UKey,” “we,” “us,” or “the Company”). UKEY LIMITED acts as the data controller under this Privacy Policy.

As the data controller, UKey provides this Privacy Policy (the “Policy”) to explain how we collect, store, use, disclose, and otherwise process personal data (as defined below).

By accessing or using the Website, related application interfaces, or the App, you acknowledge that:
(a) you have the authority, capacity, and authorization to accept this Privacy Policy;
(b) you have read and understood this Privacy Policy; and
(c) you agree to the practices described herein.

Please read this Privacy Policy carefully to understand how your data is handled.

This Policy explains what data we collect, why we collect it, how it is used and stored, how it is shared, your rights, and how to contact us. If you do not agree with the data practices described in this Policy, you should not use the Website or the App.

2. Definitions

  • Digital Asset: Refers to digital assets based on cryptographic protocols, also known as virtual financial assets, convertible virtual currencies, cryptocurrencies, digital currencies, digital commodities, or digital payment tokens. These may be centralized or decentralized, open-source or closed-source, and may function as a medium of exchange and/or a store of value.

  • Personal Data: Refers to any information that, alone or in combination with other information, can directly or indirectly identify an individual, such as name, email address, username, contact details, identification number, location data, IP address, and device ID. The applicable scope depends on the laws of your place of residence.

  • Sensitive Information: Refers to personal data relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual orientation, criminal history, biometric data, or health information.

3. Personal Data We Collect and Its Sources

UKey collects, processes, and stores your personal data when you use our services or provide your consent. Such data may include contact information, copies of identification documents you provide, information obtained from public databases, your government-issued identification number, and information related to your device or network services (such as IP address).

When you register on the UKey Website or go through onboarding processes (whether completed, interrupted, or abandoned), we collect the information you provide. We also collect personal data when you contact customer support, subscribe to marketing communications, communicate with us via phone, email, or other channels, or conduct transactions on the Website.

UKey may actively or automatically collect, use, store, or transmit your personal data, including but not limited to:

  • Personal identification information, such as name, email address, phone number, nationality, date of birth, address, and government-issued identification;

  • Corporate information, such as legal entity name, registration details, government registration number, proof of identity and legal existence, address, business description, and ultimate beneficial owner information;

  • Commercial information related to transactions conducted on the UKey Website;

  • Financial information, such as credit/debit card numbers and bank account details;

  • Communication information, including records of interactions with customer support and user feedback from surveys;

  • Information required by regulatory authorities, such as national or local licensing bodies and consumer protection agencies;

  • Other identifying information, such as device fingerprint data, IP address, and geolocation information.

UKey may also obtain your personal data from third parties, including electronic verification service providers, referral partners, marketing agencies, or liquidity providers. In such cases, we take reasonable steps to ensure these third parties comply with applicable privacy laws.

In addition, UKey may use third-party services to analyze Website traffic, which may involve the use of cookies. Information collected through such analysis is not anonymous.

We do not collect sensitive information unless we have your consent or where permitted or required by law. Such exceptions include circumstances where collection is necessary to investigate suspected unlawful activity or serious misconduct.

If you do not provide the required personal data, UKey may be unable to provide you with full services or adequately meet your needs.

UKey operates across multiple jurisdictions and collects personal data in compliance with applicable data protection laws. Where applicable, personal data processed in those jurisdictions will be protected in accordance with relevant legal requirements.

 

4. How We Use Your Personal Data

UKey may use your information in the following ways and for the following purposes:

  • To Provide UKey Services
    We use your personal data to deliver our services. For example, when you place an order through our official store, we require your identity information, contact details, and address for billing, shipping, data analysis, and service notifications.

We may also use your information for troubleshooting, data analysis to improve our products and services, identifying additional features or services that may be relevant to you, handling support requests, detecting and preventing security issues, fraud, and violations, optimizing marketing operations (such as analyzing commonly used features), and sending important communications (such as security alerts).

  • To Comply with Legal and Regulatory Requirements
    UKey processes your personal data to comply with anti-money laundering and related security laws. When you use UKey Card services, we may, as required by law, work with service providers to request additional information to verify your identity or address.

We also use your personal data to detect, prevent, and mitigate fraud and misuse of our services, and to protect the security of your account and assets.

  • For Our Legitimate Business Interests
    In certain circumstances, it is necessary to process your personal data to pursue our legitimate business interests, including but not limited to:

    • recruitment and workforce management;

    • quality control and employee training;

    • enhancing security, monitoring, and identity or access verification to prevent spam, malware, or other security risks;

    • research and development purposes;

    • improving your experience when using our services and Website;

    • facilitating corporate transactions such as acquisitions, mergers, or other business activities.

5. Legal Basis for Processing Personal Data

For individuals located in the European Economic Area, the United Kingdom, or Switzerland at the time of data collection, we process your information in accordance with applicable data protection laws.

This means that we will only process your data under one or more of the following legal bases:

  • to comply with legal obligations;

  • to perform a contract with you or to take steps at your request prior to entering into a contract;

  • for our legitimate business interests;

  • to protect the rights or property of UKey or others;

  • or with your consent.

We will not use your personal data for purposes other than those disclosed to you without your permission.

6. Data Sharing

UKey may disclose your personal data in the following circumstances:

  • Group Entities
    To provide services and conduct business operations, UKey may share your personal data with its affiliated companies or subsidiaries, where applicable.

  • Service Providers
    We work with third-party service providers to deliver services, including hosting, maintenance, network management, cybersecurity, and technical support. These providers may access or process your personal data as part of their services. For example:

    • when you pay for services by credit card, your name, billing address, phone number, email address, and payment details may be shared with payment processors for verification and recurring payment management;

    • we use cloud service providers for data storage and disaster recovery;

    • we use enterprise communication tools;

    • we rely on network service providers to support system operations and optimize access speed;

    • we engage service providers to help prevent malicious activity and comply with legal obligations, such as restricting access from sanctioned regions or individuals.

  • Native Integrations
    You may choose to share data with other applications through native integrations. UKey does not share data from integrated applications with other services or customers.

  • Legal Requirements
    Where required by law, or where we believe in good faith that disclosure is necessary to comply with legal obligations, enforce our terms, address security or technical issues, or protect the rights, property, or safety of UKey, our users, third parties, or the public, we may disclose your personal data to law enforcement authorities, regulators, or other public bodies, or provide such data in legal proceedings.

  • Strategic Partners
    With your consent, we may share your personal data with strategic partners in specific circumstances, such as for marketing or promotional purposes.

  • Third-Party Platforms
    When you choose to interact with third-party services or platforms, your personal data may be disclosed to those third parties. For more information, please refer to the section on “Third-Party Links and Websites.”

7. Your Rights

The following outlines your rights in relation to the services provided by UKey. Please note that these rights may only apply in certain regions, countries, or states. In some cases, UKey may be unable to fulfill your request due to legal or other reasons, but we will inform you accordingly.

You have the following rights regarding the processing of your personal data:

  • Right of Access / Right to Be Informed
    You have the right to access the personal data held by UKey and to obtain information about how it is processed, including:
    (i) the purposes for which your personal data is processed;
    (ii) the categories of personal data held;
    (iii) the recipients with whom the data is shared;
    (iv) the retention period;
    (v) the source of the data, where it was not collected directly from you.

UKey will also inform you of your privacy rights and, where applicable, provide information regarding automated decision-making.

  • Right to Rectification
    You have the right to correct, update, or supplement any inaccurate or incomplete personal data held by UKey. UKey may also, at its discretion, correct or delete incomplete or inaccurate information.

  • Right to Erasure
    You may request that your personal data be anonymized, deleted, or otherwise removed. Where there is no legal basis for continued processing, UKey will delete the relevant data.

  • Right to Object
    You have the right to object to the processing of your personal data where such processing is based on legitimate interests or used for direct marketing purposes.

  • Right to Restriction of Processing
    In certain circumstances, you have the right to request that UKey restrict the processing of your personal data, except for storage.

  • Right to Data Portability
    Where processing is based on a contract or your consent, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, or to request that UKey transfer such data to a third party.

  • Right to Withdraw Consent
    You may withdraw your consent to the processing of your personal data at any time, free of charge. Withdrawal will apply to future processing and will not affect the lawfulness of processing carried out prior to withdrawal.

  • Right to Lodge a Complaint
    You have the right to lodge a complaint with a supervisory authority, including authorities in your country or region of residence, place of work, or where the relevant issue arose.

  • Right to Non-Discrimination
    UKey will not discriminate against you for exercising any of the above rights.

  • Right to Opt Out of Targeted Advertising or Data Sharing
    Where required by applicable law, you may request that UKey cease using your personal data for targeted advertising, sale, or sharing.

You may contact UKey through the methods listed in the “Contact Us” section to exercise your rights.

Please note that UKey may require you to verify your identity before processing your request. Where legally permitted, UKey may refuse a request and will provide the reasons for such refusal. Applicable laws may also impose exceptions or limitations on these rights.

Under certain conditions, you may authorize an agent to exercise your rights on your behalf. Where a request is submitted by an agent, written authorization must be provided. UKey reserves the right to refuse such requests if it cannot reasonably verify the validity of the authorization or your identity.

If you wish to appeal a decision by UKey regarding a data subject request, you may contact us at: [email protected]

8. Data Retention

We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as instructed by you, unless a longer retention period is required or permitted by law.

We may also retain your data for longer periods where necessary in connection with legal claims, complaints, litigation, or regulatory proceedings.