Privacy Policy.

1. Introduction

Startex Trading Limited, a company incorporated in Hong Kong with Business Registration No. 81013072, is committed to protecting personal data. References to “Startex”, “we”, “us” and “our” in this policy mean Startex Trading Limited.

This policy applies to personal data received through our website, enquiries and communications concerning international payments, receipt of fiat funds and cryptocurrency, and settlement to designated accounts. It covers information about visitors, business contacts and individuals involved in a requested transaction.

It is our policy to handle personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) and other applicable privacy requirements. Personal data means information relating to an individual who can be identified from that information, alone or together with other information.

2. Personal Data We May Collect

The information needed depends on your enquiry, the service requested and the parties involved. We seek information relevant to those purposes and may collect the following categories when you or an authorised party provide them.

Contact and business information

• Your name, business role, company name, email address, telephone number and preferred contact details.
• Company registration details, business address and information explaining your relationship with the business or transaction.
• Messages, instructions, questions and records of communications with us, including documents you choose to provide.

Payment and settlement information

• The requested service, payment amount and currency, relevant countries, intended timing and the purpose of the payment.
• Names and contact details of senders, recipients and account holders, and the account details or payment instructions needed for the requested destination.
• Invoices, contracts, payment references and information about the underlying business transaction or source of funds, where relevant to assessing or handling the request.
• Receipt confirmations, transaction status, settlement records and communications about amendments, reconciliation or unsuccessful payments.

Where verification is reasonably required for a particular request or an applicable legal obligation, we may request supporting identity or company documents. The nature of the information requested will depend on the circumstances and the requirements of the relevant service providers.

Cryptocurrency transaction information

For a cryptocurrency-related request, relevant information may include the asset, blockchain network, public wallet addresses, transaction hashes, amounts and the intended fiat or account settlement destination. A wallet address or blockchain record may constitute personal data when it can be linked to an identifiable individual. Information recorded on a public blockchain may also be accessible independently of our website.

Website and technical information

When you visit the website, the server may receive or record your IP address, browser and device information, requested pages, access times and referring pages. Browser technologies may also retain website preferences. We use relevant technical information to operate the website, investigate errors and protect it against misuse.

You may provide information about other people involved in an enquiry or payment. Please ensure that you are entitled to provide it and that those people have been informed of its intended use. We may also receive relevant information from a counterparty or service provider involved in your request.

Providing information is generally voluntary. If information is necessary to respond to an enquiry, assess a request or fulfil a legal requirement, insufficient information may prevent us from proceeding. We will explain the information needed in the context of the request.

3. How We Use Personal Data

We use personal data for purposes connected with our website, business communications and the services you request. These purposes may include:

• Responding to enquiries and discussing the scope, requirements and proposed arrangements for a service.
• Assessing and arranging international payments, fiat or cryptocurrency receipt, and settlement to the agreed accounts.
• Communicating payment instructions and relevant information to the parties and providers involved in your request.
• Providing status updates, confirming receipt or settlement, reconciling records and handling corrections or disputes.
• Maintaining appropriate business records and dealing with accounting, administrative and professional advice requirements.
• Performing relevant verification, preventing misuse and responding to applicable legal requirements or lawful requests.
• Operating and securing the website, diagnosing technical problems and maintaining website preferences.

We aim to use personal data only for the purposes for which it was collected or directly related purposes. Where a proposed use requires additional consent under applicable law, we will seek that consent before proceeding.

4. When We May Share Personal Data

Information may need to be shared to handle an enquiry, arrange a requested transaction or fulfil an applicable obligation. Depending on the circumstances, recipients may include:

• Website hosting, IT support, data storage and communications providers supporting our website and business operations.
• Banks, payment, cryptocurrency and settlement service providers, and other intermediaries involved in the requested transaction.
• The relevant sender, beneficiary or business counterparty where information is needed to confirm instructions or resolve a transaction issue.
• Legal, accounting and other professional advisers where information is necessary for advice or business administration.
• Courts, public authorities or other parties where disclosure is required by law or necessary to address a lawful request.

We limit disclosures to information relevant to the purpose of the disclosure. When a provider handles personal data on our behalf, our policy is to require appropriate confidentiality, security and restrictions on its use. Some transaction participants may handle information under their own legal duties and privacy policies.

Website enquiries are forwarded to our email inbox through FormSubmit, a form delivery provider. FormSubmit processes the submitted fields to provide that delivery service and maintains a submissions archive for 30 days under its published retention arrangements.

FormSubmit privacy information

5. International Transfers

International payments and cryptocurrency-related arrangements may involve recipients, service providers or systems outside Hong Kong. Personal data may therefore be processed or stored in another jurisdiction when this is relevant to your enquiry, the payment route or the requested settlement destination.

Our policy is to take reasonable steps to protect personal data in such arrangements, including appropriate contractual terms or other safeguards where applicable. We consider the purpose of the transfer, the information required and the recipient’s handling of it. Transfers remain subject to applicable data protection requirements.

6. Security, Accuracy and Retention

We take reasonable technical and organisational measures to protect personal data against unauthorised or accidental access, processing, loss or misuse. Our approach includes limiting access to people who need the information for their duties and applying appropriate controls to the systems and providers used to handle it.

We seek to keep information accurate and relevant to its purpose. Please let us know if contact details, payment instructions or other information you have supplied change. Where appropriate, we may ask you to confirm details before relying on them for a requested service.

Retention depends on the purpose of the record. We consider whether an enquiry is still active, whether a transaction or issue remains unresolved, and whether business, accounting or applicable legal requirements call for continued retention. We do not apply one fixed period to every category of information.

When personal data is no longer needed for the relevant purposes and continued retention is not required, our policy is to delete it, dispose of it securely or render it no longer identifiable. Public blockchain records are maintained by the relevant network and are not records that Startex can alter or remove.

7. Access, Correction and Privacy Enquiries

You may request access to and correction of your personal data held by us in accordance with Hong Kong’s Personal Data (Privacy) Ordinance. You may also contact us with questions about this policy or the handling of information connected with your enquiry or transaction.

Please send your request to the email address or registered office in Section 11. Describe the information concerned and the access or correction you are requesting so that we can locate the relevant records.

We may request information to verify your identity or your authority to act for another person. We use that information to protect personal data and handle the request. If a request is unclear, we may ask for clarification before responding.

Requests will be handled in accordance with applicable law, including any permitted limitations on access or disclosure. If you ask us to stop a particular use or remove information, we will consider the request in light of the purposes for which it is held and any continuing legal or transaction-related requirements.

8. Cookies and Similar Technologies

Cookies and similar browser technologies may be used to support website functionality and remember preferences. For example, browser storage can retain your chosen display theme so that it is available on later visits. Where information associated with these technologies constitutes personal data, it is handled under this policy.

You can manage cookies and other stored website data through your browser settings, including clearing existing data and restricting future storage. The available controls depend on your browser. Restricting or clearing storage may reset your preferences or affect functions that depend on those settings.

9. Third-Party Websites and Services

Our website or communications may refer you to a third-party website or service relevant to an enquiry. This policy applies to Startex’s handling of personal data; a third party’s independent collection and use of information is governed by its own privacy arrangements.

Please review the relevant privacy information when you provide personal data directly to another organisation. Where we share information with a provider for a requested service, Sections 4 and 5 describe the principles that apply to that disclosure or transfer.

10. Changes to This Policy

We may update this policy to reflect changes to our website, services, data handling or applicable requirements. The current version is published on this page with its last updated date. Where a change requires further information or consent under applicable law, we will provide that information or seek consent as appropriate.

11. Contact Information

For privacy enquiries and requests relating to personal data, contact Startex Trading Limited using the details below.

Startex Trading Limited
Business Registration No. 81013072

Email: StartexTradingLtd@gmail.com