Marathon Corporate Services Limited
Marathon Corporate Services Limited (the company) has adopted this Privacy Statement to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our Sites or use our Services. This Privacy Statement applies to your Personal Data when you visit Sites or use Services and does not apply to online websites or services that we do not own or control, including websites or services of third-party companies or Members.
This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services. Please note that our Service offerings may vary by region.
We have defined some terms that we use throughout the Privacy Statement. You can find the meaning of a capitalized term in the Definitions section.
Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Statement.
2. What Personal Data Do We Collect?
We collect information about you visit our Sites or use our Services, including the following:
Registration and use information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.
Transaction and experience information – When you use our Services or access our Sites, for example, to make purchases from merchants, to receive money, to process payments, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.
• Participant information – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction.
• Send or request money: When you send or request money through the Services, we collect Personal Data such as name, postal address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.
• Pay or request someone else to pay a bill: If you use our Services to pay a bill for the benefit of someone else, or if you request a Third-party to pay a bill for you, we collect Personal Data from you about the party such as name, postal address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid.
• Add value to your accounts: If you use our Services to add value to your Account or any other account you may have, or if you ask a Third Party to add value to any of these accounts, we may collect Personal Data from you about the Third Party, or from Third Party about you to facilitate the request. For example, if you use our Services to reload a mobile phone, or to request value be added to your mobile account, we may collect Personal Data and other information including a mobile account number from the Third Party.
• Information about your friends and contacts –if you choose to connect your contact list information with your Account. If you establish an account connection between your device or a social media platform and your Account, we may use your contact list information (such as name, address, email) to improve your experience when you use the Services.
Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection if the use of that information differs from the uses disclosed in this Privacy Statement.
If you are an Account holder and choose to engage in a transaction with a third party who is an account holder with the Company, we will collect information about the transaction and may associate it with your Account. If you are not an Account holder and choose to receive payment an account with the Company, we will collect and store all information you provide and use and share such information in accordance with this Privacy Statement.
• Information about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
• Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
3. Why Do We Retain Personal Data?
We retain Personal Data to fulfil our legal or regulatory obligations and for our business purposes. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.
4. How Do We Process Personal Data?
We may Process your information for the following reasons:
• To operate the Sites and provide the Services, including to:
• initiate a payment, send or request money, add value to an account, or pay a bill;
• authenticate your access to an Account;
• communicate with you about your Account, the Sites, the Services, or The Company;
• create an account connection between your Account and a third-party account or platform;
• perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes; and
• keep your Account and financial information up to date.
• To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we may analyze Member behaviour and perform research about the way you use our Services.
• To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. The Company’s risk and fraud tools use Personal Data, Device Information, Technical Usage Data and Geolocation Information from our Sites and websites that offer The Company Services to help detect and prevent fraud and abuse of the Services.
• To market to you about The Company payments and financial products and Services and the payments and financial products and services of unaffiliated businesses. We may also Process your Personal Data to tailor the marketing content and certain Services or Site experiences to better match your interests on The Company and other third-party websites.
• To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.
• To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.
• To make it easier for you to find and connect with others, we may use the information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
• To respond to your requests, for example, to contact you about a question you submitted to our customer service team.
5. Personal Data Sharing
We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Statement.
We may share your Personal Data or other information for the following reasons:
With other members of the Company corporate family: We may share your Personal Data with members of the Company family of entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of The Company products, Services, and communications.
With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.
With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product, such as Banks, and Payment Gateway or service providers in connection with payments made to or charged against credit and debit cards and/or Bank or other financial institution accounts as required to facilitate payments and or charges on your account. These financial institutions may only use this information to market and offer Company-related products unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.
With the other parties to transactions when you use the Services, such as Third Parties, merchants, and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes third Parties you are sending or receiving funds from, and merchants, and their service providers. The information might include:
• Personal Data and Account Information necessary to facilitate the transaction;
• information to help other participants (s) resolve disputes and detect and prevent fraud, and
• aggregated data and performance analytics to help merchants better understand Members and to help merchants enhance Members’ experiences.
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for the Company’s business purposes or as permitted or required by law, including:
if we need to do so to comply with a law, legal process or regulations;
law enforcement, regulators, government officials, or other third parties (in Hong Kong or elsewhere or elsewhere) in relation to a subpoena, court order, or other legal process or requirement under Singapore law or regulation, or the laws and regulations of other jurisdictions that are applicable to the Company or one of its affiliates; when we need to do so to comply with such law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a Member agreement;
• to protect the vital interests of a person;
• to protect our property, Services and legal rights;
• to facilitate a purchase or sale of all or part of The Company’s business;
• in connection with shipping and related services for purchases made using a Service;
• to help assess and manage risk and prevent fraud against us, our Members and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants, such as eBay, Inc.;
• to banking partners as required by card association rules for inclusion on their list of terminated merchants;
• to credit reporting and collection agencies;
• to companies that we plan to merge with or be acquired by; and
• to support our audit, compliance, and corporate governance functions.
With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.
In addition, The Company may provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Members visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.
6. How Do We Work with Other Services and Platforms?
A significant benefit and innovation of The Company’s Services is that you can connect your Account with third-party accounts or platforms. For the purposes of this Privacy Statement, an “account connection” with such a third-party is a connection you authorize or enable between your Account and a non-Company account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, The Company and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:
• linking your Account to a social media account or social messaging service;
• connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
• using your Account to make payments to a merchant or allowing a merchant to charge your Account.
• If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service.
o For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.
• Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices.
• Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection.
o For example, Personal Data that The Company shares with a third-party account or platform such as a social media account may, in turn, be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
This page is designed to help you understand more about these technologies and our use of them on our sites and in our services, applications, and tools. Below is a summary of a few key things you should know about our use of such technologies. You can review the contents of our full Member Cookie Notice below.
Where possible, security measures are set in place to prevent unauthorized access to our cookies and similar technologies. A unique identifier ensures that only we and/or our authorized service providers have access to cookie data.
Service providers are companies that help us with various aspects of our business, such as site operations, services, applications, advertisements and tools. We use some authorized service providers to help us to serve you relevant ads on our services and other places on the internet. These service providers may also place cookies on your device via our services (third party cookies). They may also collect information that helps them identify your devices, such as IP-address or other unique or device identifiers.
What are cookies, web beacons, and similar technologies?
• Like most sites, we use technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools.
• The specific names and types of cookies, web beacons, and other similar technologies we use may change from time to time. In order to help you better understand this Policy and our use of such technologies we have provided the following limited terminology and definitions:
• Cookies – Small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:
• Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
• Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
• First-party cookies are set by the site you are visiting.
• Third-party cookies are set by a third-party site separate from the site you are visiting.
• Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options.
• Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites, services, applications, messaging, and tools, that typically work in conjunction with cookies to identify our Members and Member behaviour.
Similar technologies – Technologies that store information in your browser or device utilizing local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers, and in some instances may not be fully managed by your browser and may require management directly through your installed applications or device. We do not use these technologies for storing information to target advertising to you on or off our sites.
We may use the terms “cookies” or “similar technologies” interchangeably in our policies to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
Our cookies and similar technologies have different functions. They are either necessary for the functioning of our services, help us improve our performance, give you extra functionalities, or help us to serve you relevant and targeted ads. We use both session and persistent cookies and similar technologies.
Generally, these technologies allow our sites, services, applications, and tools to store relevant information in your browser or device and later read that information in order to identify your device to our servers or internal systems. Where applicable, we protect our cookies and other similar technologies to help ensure that only we and/or our authorized service providers can interpret them by assigning them a unique identifier that is designed for interpretation only by us.
Our uses of such technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.
Any personal information that we collect and store through the use of these technologies for categories 2 through 4 above are based on your consent, obtained through a conspicuous disclosure on our website during your first visit. You can withdraw this consent through your browser settings as explained below.
For browser-specific information on how to adjust cookie configurations on the following browsers, please click on the relevant link below:
• Internet Explorer
• OSX/Mac OS
Use of these technologies by authorized third-party service providers
We may work with third-party companies, commonly known as service providers, who are authorized to place third-party cookies, web beacons, or similar technologies for storing information on our sites or in our services, applications, and tools with our permission. These service providers help us to provide you with a better, faster, and safer experience.
With the exception of the use of such technologies by our service providers or other authorized third-parties, we do not permit any third-party content on sites (such as item listings, member-to-member communications, classified listings, comments, reviews, etc.) to include or utilize any cookies, web beacons, local storage, or similar technologies for tracking purposes or to collect your personal information. If you believe a listing or other third-party content might be collecting personal information or using tracking technologies on one of our sites, please report it to firstname.lastname@example.org
Ad networks and exchanges operated by authorized third parties for interest-based advertising
Though we do not currently, we may use third parties, such as advertising networks and exchanges, to allow us to serve you advertisements. These third-party ad networks and exchange providers may use third-party cookies, web beacons, or similar technologies to collect information about your visit to our site and elsewhere on the Internet. They may also collect your device identifier, IP address, or identifier for advertising (IDFA). The information that these third parties collect may be used to provide you with more relevant advertising on our sites or elsewhere on the web. Third-party cookies are covered by the third-parties’ privacy policies.
“Do Not Track”
As there currently isn’t an industry or legal standard for recognizing or honouring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
8. What Privacy Choices Are Available to You?
You have choices when it comes to the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.
• Choices Relating to the Personal Data We Collect
• Personal Data. You may decline to provide Personal Data when it is requested by The Company, but certain Services or all of the Services may be unavailable to you.
• Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and Member usage data that The Company may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
• Choices Relating to Our Use of Your Personal Data
• Personalized Services offered by The Company on third-party websites and services. You may manage your preferences for other The Company Services that are personalized and offered to you on third-party websites from your Account. We may also provide you with instructions and prompts on how to manage your preferences within the Service experience.
• Finding and connecting with others. If available, you may manage your preferences for finding and connecting with others from your account of the Service you use.
Choices Relating to Account Connections
• If you authorize an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.
• Choices Relating to Cookies
• You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options but doing so may prevent you from using many of the core features and functions available on a Service or Site.
You can learn more about our cookies and tracking technologies by visiting the Statement on Cookies and Tracking Technologies page.
• Choices Relating to Your Registration and Account Information
• If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you do not have an Account or if you have questions about your Account information or other Personal Data.
• Choices Relating to Communication
• Notices, Alerts and Updates from Us:
• Marketing: With your consent, we may send you marketing content about our Sites, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of The Company corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt-out of these marketing communications by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account Settings. For messages sent via push notifications, you may manage your preferences in your device.
• Informational and Other: We will send communications to you that are required or necessary to send to Members of our Services, notifications that contain important information and other communications that you request from us. You may not opt-out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.
9. How Do We Protect Your Personal Data?
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.
10. Can Children Use Our Services?
The Sites and Services are not directed to children under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.
11. What Else Should You Know?
Changes to This Privacy Statement.
We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date.
If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Members of the change using email or other means.
Transfers of Your Personal Data to Other Countries
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in the United States of America and elsewhere in the world. We will protect your information as described in this Privacy Statement if your Personal Data is transferred to other countries. By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.
12. Contact Us
You may contact us if you have general questions about our Privacy Statement and practices or questions about your Account information or Personal Data.
You have the right to request access to and the correction of Personal Data that we hold about you, which requests will be reviewed and processed in accordance with applicable law.
We want to make sure your questions go to the right place:
Our Data Protection Officer can be contacted at Marathon Corporate Services Limited 11th Fl Tower 2, Admiralty Centre,18 Harcourt Road, Admiralty, Hong Kong (SAR)
Account means a Company or Trust member account.
Device Information means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity).
Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.
The Company means The Company Hong Kong Limited and subsidiaries or affiliates. In this Privacy Statement, The Company is sometimes referred to as “we,” “us,” or “our,” depending on the context.
Personal Data means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID). Personal Data does not include information that does not identify a specific Member.
Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.
Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by The Company in connection with an Account or Third-Party payment.
Sites means the websites, mobile apps, official social media platforms, or other online properties through which The Company offers the Services, and which has posted or linked to this Privacy Statement.
Technical Usage Data means information we collect from your phone, computer or other devices that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.
Third-Party Means a party other than the Member who either receives a payment from or remits payment to the Trust on behalf of a Member Such third party would also include any party who provides a service to the member through or on conjunction with the Trust.
Member means an individual who uses the Services or accesses the Sites and has established a relationship with The Company (for example, by opening an Account and agreeing to the Membership Agreement) or otherwise uses the Services as a buyer, seller or other type of participant to a transaction, including a Third Party payment.
14. Additional Information
The information provided in this section may be specific to customers depending on your region or how you use the Services. This information is provided to The Company from third parties with whom you may interact with when using the Services.
Consumer Advisory – In Hong Kong since 2018, trust or company service providers must be licensed under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”). Marathon Corporate Services Limited (the “Company”) is a licensed Trust and Company Services Provider (“TCSP”) registered in Hong Kong (License Number: TC006228) Members in Hong Kong SAR are advised to read the terms and conditions provided for any product or service provided carefully.