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        Privacy policy and personal data collection statement


        1. Moomoo Financial Singapore Pte. Ltd. ("Moomoo Singapore", "we", 「our」 or "us") is committed to provide clients with the excellent brokerage services. Based on the service needs, we shall collect and use client's personal data. We understand that clients are extremely concerned about the use and confidentiality of their personal data. Moomoo Singapore is serious about ensuring and maintaining the security and privacy of personal data that we collect and process. Therefore, we have established this Policy to explain how we collect, use and disclose personal data, and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulations (「PDPA」). In this Policy, 「personal data」 shall have the meaning ascribed to it in the PDPA.

        2. Where our operations may be subject to data privacy legislation other than that of Singapore, this Policy shall apply insofar as the requirements in this Policy impose a higher standard of personal data protection than the foreign laws. For the avoidance of doubt, nothing herein shall require Moomoo Singapore to act in breach of applicable Singapore laws.

        3. This Policy applies to any personal data that we collect from you, or that you provide to us. Please read the following carefully to understand our policies and practices regarding your personal data and how we process it. By interacting with us, submitting information to us, or requesting that we provide you with products or services, you agree and consent to the collection, use and/or disclosure of your personal data, in the manner set forth in this Policy.

        4. Please note that this Policy may be amended from time to time without prior notice to ensure that it is consistent with our future developments, industry trends and/or changes in legal or regulatory requirements. Any changes to this Policy will become effective when we post the revised Policy on our website. Please check back regularly for updated information on the handling of your personal data. Subject to your rights at law, you agree to be bound by the revised Policy.

        5. In the event of any inconsistency between different versions of this Policy, the English version shall prevail.


        Collection and Use of Personal Data

        6. Moomoo Singapore collects the personal data of our clients for the purpose of and in connection with the provision of our products and services. Moomoo Singapore may also collect personal data of other individuals who provide the information to us voluntarily or who visit our website. When you visit our website, we may collect technical information such your Internet protocol (「IP」) address as well as other information regarding your activity on our website. For additional detail, please refer to our Cookies Policy .

        7. The personal data we collect from you may include, but is not limited to:personal particulars (e.g. name, age, occupation, marital status, email address, telephone number, personal identity information, electronic signature, address and other contact information);

          a. financial information (e.g. credit history, source of wealth, risk tolerance, investment experiences and objectives, transaction records, account balance and securities portfolio);

          b. electronic information (e.g. IP address, browser type and version, time zone settings, browser plugin types, operating systems or platform or device data (including the IMEI number of your mobile device, wireless networks and general network data).

        8. We may also collect your personal data from other sources such as public databases and data sources (e.g. news articles, government records, etc.), joint marketing partners, and social media platforms.

        9. Generally, we may collect, use and/or disclose your Personal Data for any of the following purposes:Provide you with our products or services;

          a. Open, administer, maintain and/or manage your account;

          b. Communicate with you, including to inform you of changes and updates to our policies, terms and condition, and other administrative information;

          c. Verify your identity as part of initial and on-going Know-Your-Client (KYC) due diligence processes and to fulfill our obligations under applicable AML laws and regulations;

          d. Authenticate and certify your electronic signatures (if any) in accordance with the Electronic Transactions Act (Cap 88) or other similar laws;

          e. Assess and process applications, instructions or requests from you for services and/or facilities offered by us;

          f. Perform credit check, verification procedures, data verification, due diligence and risk management;

          g. Assist other financial institutions to conduct credit checks and collect debts;

          h. Ensure that you and/or your guarantor maintains a reliable credit;

          i. Maintain you and/or your guarantor’s credit history and records for current or future reference;

          j. Design and develop financial services and/or products for your use;

          k. Provide you with marketing, advertising and promotional information, materials and/or documents relating to financial products and/or that may be of interest to you or for which you may be eligible;

          l. Determine the amount of you and/or your guarantor’s indebtedness to us;

          m. Enforce obligations owed to us;

          n. Comply with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities;

          o. Enable any actual or proposed assignee or transferee, participant or sub-participant of our rights or obligations to evaluate any proposed transaction;

          p. Any purposes allowed by applicable laws;

          q. Establish, exercise or defend a legal right or to participate in any legal or administrative proceedings;

          r. Attend and respond to your questions, complaints and feedback; and/or

          s. Purposes that are reasonably related to the foregoing.

        10. Please note that we may require your personal data for the purposes of providing certain products and services to you. If you choose not to provide any personal data whenever required by us, we may not be able to provide the services and/or products requested by you.


        Use of Personal Data for Marketing Purposes

        11. Moomoo Singapore may use your personal data to provide you with information and other marketing materials on our products and services that may be interest to you. We may also use your personal data to invite you to participate in marketing research, surveys and other similar activities. Your mobile information (including name and mobile phone numbers) under messaging service will not be shared or sold to third parties (other than any Moomoo Singapore's affiliates) for their marketing and/or promotional purposes.

        12. You can choose to receive marketing and other promotional materials through various modes including but not limited to email, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In respect of sending telemarketing messages to your Singapore telephone number via short message service, telephone calls (voice or video), facsimile and other mobile messaging services, we will do so only if:You have provided your clear and unambiguous consent in writing or other recorded form for us to do so;

          a. You have not indicated to us in our ongoing relationship that you do not wish to receive telemarketing messages sent to your Singapore telephone number and you have not registered that number with the National Do Not Call Registry.

        13. If you no longer wish to receive marketing or promotional materials from us, you may at any time opt-out by using the 「Unsubscribe」 link that would always be contained in the marketing email, or request that we stop contacting you for marketing purposes.


        Disclosure of Personal Data

        14. Subject to the provisions of any applicable laws, rules and/or regulations, we may disclose your personal data for the purposes stated above, to the following persons (whether in Singapore or overseas):Our third party service providers and their respective officers, employees, agents or subcontractors who we have engaged to provide administrative, credit data, debt collection, telecommunications, computing, payment, information technology, data processing or other support services;

          a. Companies within the Futu group, including but not limited to holding companies or affiliated companies located in Singapore or other places;

          b. Any person who acts or intends to act as your guarantor;

          c. Other financial institutions and their respective officers, employees or agents;

          d. Credit data service institutions or debt collection institutions, as may be necessary;

          e. Any actual or proposed assignee or transferee of Moomoo Singapore, or participant or sub-participant of Moomoo Singapore;

          f. Any certification authority in respect of electronic signatures;

          g. Our professional advisers, including auditors, lawyers, tax advisors and other consultants;

          h. Relevant regulatory bodies, government, tax authorities, law enforcement agencies or other administrative, self-regulatory or statutory agencies, or stock exchange or clearing house;

          i. Relevant third parties as a result of any restructuring, sale or acquisition of any company within the Futu group; and

          j. Any other party to whom you authorize us to disclose your personal data to.

        15. Where we may disclose your personal data to any of the third parties mentioned above, we will disclose the personal data in accordance with applicable laws, rules and/or regulations and will use best endeavours to ensure that the third party keeps the personal data confidential and secure, and uses the personal data only for the original purposes for which they have been disclosed.


        Transfer of Personal Data Overseas

        16. Moomoo Singapore may transfer your personal data to countries outside Singapore where any of our group companies or service providers may be located. To the extent that we may need to transfer your personal data overseas, we will protect the personal data so transferred and ensure that we provide a standard of protection that is comparable to the protection under Singapore data privacy laws and regulations.


        Personal Data Security Measures

        17. Moomoo Singapore implements protection measures to safeguard and protect personal data against unauthorised or accidental access, processing or erasure:Access or use of personal data is limited to authorized staff or agents on a 「need to know」 basis and is disclosed or shared using secured methods (personal data is encrypted when necessary);

          a. We do not distribute personal data to other persons for purposes other than as mentioned in this Policy or as notified to you, except where we are required to do so under applicable laws;

          b. The sharing of personal data between the companies of Futu Group is subject to strict internal security standards, confidentiality policies, privacy laws and other applicable laws;

          c. We require that our employees fully comply with the relevant data privacy standards, policies and laws;and

          d. We provide regular training to our employees on the proper handling of personal data.

        18. As we further develop new products and services, we will continue to make every effort to ensure that personal data we collect is secure and protected.


        Data Privacy Requests

        19. You have the right to:request access to your personal data and obtain information about how we have used or disclosed your personal data. Please note that we may at our discretion charge a reasonable administrative fee for implementing your request;

          a. withdraw the consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data for a specific purpose without your consent, if a provision in applicable law permits us to;

          b. request that we rectify any inaccuracies or incomplete information in your personal data;

          c. request that we erase your personal data, except that we are not obligated to erase any personal data if it must be retained to comply with any legal obligations or to establish, exercise, or defend a legal claim, or if we have anonymized the personal data such that the information will not identify you individually;

          d. object to, and request that we restrict our processing of your personal data, except that we are not obligated to accede to such request if the purpose for which your personal data is processed is permissible to us under applicable laws; and

          e. lodge a complaint with the local data protection authority if you think that any of your data privacy rights have been infringed by us.

        20. If you would like to submit a data privacy request, please contact the Cilent Service Department of Moomoo Singapore at the contact details set out below.


        Accuracy of Personal Data

        21. We make reasonable efforts to ensure that your personal data is sufficiently accurate, complete and up-to-date. If the personal data that you have provided to us changes, please contact the Client Service Department of Moomoo Singapore at the contact details set out below.


        Retention Period of Personal Data

        22. We will retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as long as required or permitted by applicable law. When your personal data is no longer necessary for these purposes, we will delete it or remove the means by which the personal data can be associated with you.


        Right to Withdraw Consent

        23. You have the right to withdraw your consent to any or all collection, use or disclosure of your personal data as described in this Policy at any time upon giving us reasonable notice in writing of such withdrawal by contacting the Client Service Department of Moomoo Singapore at the contact details set out below. However, depending on the nature and extent of the withdrawal, you acknowledge that we may be unable to initiate or continue to provide products or services to you, or administer any account(s) or relationship(s) in place upon the withdrawal of your consent, therefore resulting in adverse implications on or the termination of any accounts, agreements and/or relationships you may have with us. Upon receipt of any notice to withdraw consent, we will inform you of the likely consequences of such withdrawal.

        24. All our legal rights and remedies are expressly reserved in the event of termination and any subsequent event. The withdrawal of consent shall not affect the lawfulness of any collection, use or disclosure of personal data by us that is based on consent obtained prior to its withdrawal, or our ability to collect, use or disclose your personal data for a specific purpose without your consent, if a provision in applicable law permits us to.


        Contacting Us

        25. If you have any questions or feedback relating to this Policy, or would like to withdraw your consent to any use of your personal data or to submit a data privacy request, please contact us via the following contact details:Attention: Client Service Department Moomoo Financial Singapore Pte. Ltd.

          a. Email: clientservice@sg.moomoo.com

          b. *Please indicate your name, Moomoo No. or contact number for us to follow up your request. You may be asked to provide additional information to authenticate your identity in order for us to follow up on your request.