Privacy Policy

This Privacy Policy is applicable to customers of Apus Technology Inc.

  1. Definitions

“Cookies” refer to small text files that are placed on your computer or mobile device when you browse websites.

“We,” “Us,” or “Our” refer to Apus Technology Inc. (“Apus Technology Inc.”).

  1. Introduction

This Privacy Policy, issued on 1 August 2025, forms a part of the legal agreement between you and us. The other components of this legal agreement include our Platform Agreement, our Anti-Money Laundering Policy, and the terms governing any additional services provided by us to you.

  1. Privacy Policy
    • Collection of Information
      • We understand the importance of protecting your privacy. In order to provide you with our services, we need to collect certain personal information from you and obtain your consent regarding the handling of such information. Upon request, you must provide us with all necessary information regarding your financial, business affairs, and identity, which may also be used for analytical or secondary purposes such as archiving, audits, and statistical or historical analysis.
      • In addition to personal data required for processing your interactions, we may also use this data to inform you about changes or additions to our services and provide information related to foreign exchange rates. Additionally, we collect non-personal data.
      • “Non-Personal Data” refers to statistical and analytical information gathered on an aggregate basis from all visitors to our website. This non-personal data includes information that cannot be used to identify or contact you, such as demographic information, clipped or anonymized user IP addresses, browser types, and other anonymous statistical data regarding website usage.
    • Use of Information
      • By using our services, you consent to our collection, use, disclosure, storage, and processing of your personal information in accordance with this Privacy Policy, our Terms and Conditions, and our Anti-Money Laundering Policy. We may also disclose and process your personal information to our affiliates and trusted business partners for processing based on our instructions and in compliance with appropriate confidentiality and security measures. For example, we may engage banking partners to facilitate payment services.
      • When providing personal data of living individuals, you must ensure that you have obtained due consent from the individuals regarding our collection, use, disclosure, and processing of their personal data in accordance with this Privacy Policy, our Terms and Conditions, and our Anti-Money Laundering Policy. We assure you that we will only use personal data as required by law or permitted under applicable data protection legislation.
      • In the case of corporate data provided solely associated with a corporate entity and not directly linked to personal data of living individuals (“Corporate Data”), we will fulfill our obligations regarding the acquisition and processing of such Corporate Data. You understand that we may use this Corporate Data for the following purposes:
    • Delivering payment services to you.
    • Promoting and marketing our services and those of our third-party partners to the corporate entities mentioned in the Corporate Data.
      • Identity Verification

To ensure a secure relationship, you will be required to provide evidence to verify your identity. If we are not satisfied with the information you provide, we may request additional details. We reserve the right to reject your application and withhold the full range of transaction services until satisfactory verification procedures have been completed.

  • Consent to Search Public Databases

You consent to our search of electronic databases and credit reference agencies to verify your identity and credit standing. We will retain records of these searches in accordance with applicable laws. Additionally, if deemed appropriate at our sole discretion, we may provide relevant information about you and your transactions to credit reference and law enforcement agencies.

  • Information Accuracy

You are responsible for ensuring that all information provided to us is accurate and up to date at all times. Any changes must be promptly communicated to us. You have the right to request a copy of your personal information, review it, and correct or modify it if necessary. We will respond to your request as soon as reasonably practicable.

  • Protection of Information

We collect and store information electronically, taking reasonable steps to protect it from unauthorized access, misuse, loss, or destruction. We are not liable for any loss or damage you may incur as a result of the loss or theft of information held by us.

  • Retention of Information

Any information collected by us, including telephone recordings or transcripts, may be retained or destroyed in accordance with applicable Data Protection Legislation or regulatory requirements as may be amended from time to time.

  • Recording Phone Conversations

Both parties (you and us) consent to the electronic recording of telephone conversations without an automatic warning tone. These recordings may be used as evidence in any dispute or anticipated dispute between the parties or related to any dealings between the parties.

  • Cookies

Our Cookies Policy provides detailed information about the cookies used on our website. Please note that our cookies do not store any personally identifiable information. You have the option to disable cookies by adjusting your internet browser settings. However, please be aware that disabling cookies may impact the performance of many websites, including ours.

  • Unsubscribe

If you wish to revoke consent for us to retain or use your information or if you want to revise or update your information, please contact us. We will remove or amend the information in accordance with applicable legislative and regulatory requirements.

  1. Legal basis and Purpose for Processing
    • We process your personal data only where lawful under the General Data Protection Regulation (GDPR).
      2. Our legal bases for processing include:
      4.2.1. Consent (Article 6(1)(a) GDPR)
      4.2.2. Contractual necessity (Article 6(1)(b) GDPR)
      4.2.3. Legal obligations (Article 6(1)(c) GDPR)
      4.2.4. Legitimate interests (Article 6(1)(f) GDPR)
      4.3. Purposes of processing include providing services, identity verification, fraud prevention, legal compliance, customer support, and service improvements.
  2. Categories of Personal Data and Recipients
    1. Categories of data collected:
    5.1.1. Personal identification details (e.g., name, date of birth, ID documents)
    5.1.2. Contact information (e.g., email, phone number, address)
    5.1.3. Financial and transactional information
    5.1.4. Technical data (e.g., IP address, browser type, cookies)
    5.2. Recipients of data:
    5.2.1. Affiliates and trusted business partners
    5.2.2. Payment and banking partners
    5.2.3. IT and service providers and hosting providers
    5.2.4. Regulators, law enforcement, or courts when required by law
  3. International Data Transfers and Safeguards
    1. Where we transfer personal data outside the European Economic Area (EEA) or the United Kingdom, we ensure appropriate safeguards are in place such as:
    6.1.1. Standard Contractual Clauses (SCCs)
    6.1.2. Binding Corporate Rules (BCRs)
    6.1.3. Reliance on an adequacy decision in accordance with GDPR Chapter V
    6.2. A list of transfers and the legal basis for such transfers can be provided on request.
  4. Data Retention
    1. We retain personal data only as long as necessary for the purposes set out in this Privacy Policy and in accordance with applicable legal and regulatory obligations.
    7.2. Specific retention periods depend on the nature of the data and our contractual and statutory requirements.
    7.3. Where possible, we set specific retention periods and regularly review data held.
  5. Your Rights under the GDPR
    1. As a data subject in the EEA/UK, you have the following rights:
    8.1.1. Right of access (Article 15 GDPR)
    8.1.2. Right to rectification (Article 16 GDPR)
    8.1.3. Right to erasure (‘right to be forgotten’) (Article 17 GDPR)
    8.1.4. Right to restriction of processing (Article 18 GDPR)
    8.1.5. Right to data portability (Article 20 GDPR)
    8.1.6. Right to object (Article 21 GDPR)
    8.1.7. Right not to be subject to automated decision-making, including profiling (Article 22 GDPR)
    8.2. To exercise these rights, please contact us at [Insert Contact Email]. We will respond without undue delay and in accordance with statutory time limits.
  6. Complaints and Supervisory Authority
    1. If you believe we have infringed your data protection rights, you have the right to lodge a complaint with your local Data Protection Authority.
    9.2. In the UK, the supervisory authority is the Information Commissioner’s Office (ICO).
    9.3. We also appreciate hearing from you first so that we can investigate and attempt to resolve your complaint.
  7. Automated Decision-Making and Profiling
    1. We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on individuals, unless we have a lawful basis and provide appropriate safeguards.
    10.2. Where such processing occurs, we will provide meaningful information about the logic involved and the possible consequences for you.
  8. How to Contact Us and Exercise Rights
    1. To exercise any of your rights or for any questions about how we process your personal data, contact:
    11.1.1. Apus Technology Inc.
    11.1.2. Email: complicance1@apustechs.com
    11.2. For matters related to transfers, data portability requests or deletion, please specify the request type in your email.