Last Updated: 18 December 2023

1. Introduction

Cross-Border Worldwide (CBW) is committed to protecting the privacy of our clients. This Privacy Policy explains the type of personal data we collect, why we collect it, and how we use it in providing our services to you. It also explains the rights and choices you have with regards to your personal data.

By providing your personal data to us, you acknowledge and agree that we will only use it in accordance with this Privacy Policy. CBW acts as both the Data Controller and Data Processor of any personal data collected from you, third parties, or through our website and other communication platforms.

We encourage you to read this Privacy Policy carefully, together with any other privacy notice we may provide from time to time, to be fully informed about how we are using your personal data. This Privacy Policy applies to all clients, whether current or former, and covers our website, external communication platforms, and internal processes.



2. Basis for processing personal data

Personal data is any information that can (or could be used to) identify a living person. In this section, we explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.

To enter into and perform contracts with you: We process your personal data to provide services to you, including the personal information we need to perform those services. If you choose not to provide us with your personal data, you will not be able to use our services. The legal basis for processing your personal data in these circumstances is to perform a contract with you.

To make our website better: We process your personal data to provide you with a more tailored experience when you visit our website. This includes using your personal data to tailor our website to be displayed effectively on the device you are using. We also use third-party cookies to help us improve our website, but we will not share your personal data with these providers. We process your personal data to make our website more secure, administer our website, and for internal operations such as troubleshooting, data analysis, testing, research, and statistical and survey purposes. The legal basis for processing your personal data in these circumstances is our legitimate interest to provide you with the best possible website we can, and to ensure that our website is kept secure.

For user research: We process your personal data to contact you in relation to your experience of using our products and services. We will use any feedback provided to tailor and improve our services. We may also conduct research to develop new products and services where input from users' experience would inform our approach. The legal basis for processing your personal data in these circumstances is our legitimate interest to improve our products and services.

For CBW marketing purposes: We may contact you for marketing purposes if your recent activity suggests you might want to hear from us. We process your personal data to form a view on what services, promotions or offers we think you may be interested in. Our communications always include an unsubscribe link. You can also let us know you would prefer not to be contacted by emailing general@crossborderworldwide.com and clearly stating that you wish to be removed from our marketing list. The legal basis for processing your personal data in these circumstances is our legitimate interest to promote our services.

To create anonymised data sets: We may convert your personal data into an anonymised format to create statistical analysis and identify general trends. We may use this information for press publications, such as to show the age range of our customers or geographical areas where we provide a high volume of service. Anonymised data is not personal data.

In the event of transfer of ownership: In the event that we buy or sell any business or assets, we will transfer your personal data to a third party, in accordance with all applicable data protection laws. If CBW or substantially all of its assets are acquired by a third party, personal data held by CBW about its customers will be one of the assets transferred to the purchaser. The legal basis for processing your personal data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser.



3. Information we collect from you

Information we collect from you
The following data will be collected and processed about you by CBW:

Information you give us: This information includes details that you provide to us when filling out forms on our website, communicating with us via phone, email or other means, placing an order for a product or service, or reporting issues with our website. The information can consist of your name, address, email address, phone number, financial and credit card information, as well as other details related to your assets. Please note that we do not store credit card details or share financial details with third parties.

Information we collect about you: When you visit our website, we will automatically collect technical information such as your IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform. Additionally, we collect information about your visit including the URL, clickstream to, through and from our website, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Cookies: We use cookies to enhance your browsing experience and improve our website. Cookies are small files containing information that are stored on your browser or hard drive if you consent. Our website uses strictly necessary cookies that enable you to log into secure areas, use a shopping cart, and access e-billing services. We also use analytical/performance cookies to count the number of visitors, track their movement around the website, and improve the website's functionality.

Do Not Track: We utilise your "Do Not Track" status to determine whether or not to activate tracking scripts, such as affiliates and Google Analytics.

Uses of Information: We combine the information you provide us with the information we collect about you to serve the purposes outlined above, depending on the type of information we receive.



4. Personal Data Storage

All information that you provide to us is stored on secure servers. If you have a password that enables you to access certain parts of our website, it is your responsibility to keep it confidential, and you should not share it with anyone.

Storage Duration: If you register on our website and provide personal data but do not complete the process of creating your document, we will keep your data to help you with any questions or feedback you may have about our services. If you complete a document using our service, we will store your data indefinitely to protect against legal claims and provide supporting information if your will is contested.



5. Your Rights under Data Protection Laws

Right to Object: You have the right to object to the processing of your personal data by us, where we process it based on our legitimate interests. If you ask us to stop processing your personal data, we will do so unless we can provide compelling reasons for continuing the processing in accordance with data protection laws.

Right of Access: You have the right to receive confirmation of whether we are processing your personal data and other information relating to its use. You also have the right to access the personal data we are processing.

Right to Rectification: You have the right to ask us to rectify any inaccurate personal data we hold about you. You can also provide a supplementary statement to us to complete any incomplete personal data we hold about you.

Right to Restriction: You have the right to restrict the processing of your personal data in certain circumstances, including when:

  • You dispute the accuracy of your personal data.
  • We are processing your personal data unlawfully, but you do not want it to be erased.
  • We no longer need your personal data, but you want to keep it for legal purposes.
  • We are processing your data based on our legitimate interest, and you object to the processing. In this case, you may request that the processing of your personal data be restricted until it is determined whether our legitimate interest overrides yours.

If you exercise your right to restriction, we will only process the relevant personal data with your consent, for storage purposes, and for legal claims.

Right to Data Portability: You have the right to receive your personal data in a structured, standard machine-readable format, and to transfer it to another controller.

Right to Erasure: You have the right to request the erasure of your personal data in certain circumstances, including when:

  • We no longer need your personal data for the purposes for which it was collected.
  • Our processing of your personal data was based on your consent, and you have withdrawn your consent.
  • You object to our processing, and we have no overriding legitimate interest.
  • Your personal data was processed unlawfully.
  • The erasure is required to comply with a legal obligation.

If you have any concerns or queries about the use of your personal data, please contact us at general@crossborderworldwide.com. If we cannot resolve the issue informally, you have the right to lodge a complaint with the Privacy Commissioner for Personal Data in Hong Kong.



6. Exercising Your Rights

You can exercise your rights by contacting us at general@crossborderworldwide.com. We may ask you to confirm your identity before acting on your request.



7. Links on Our Website

Our website may contain links to other websites, which have their own privacy policies. We are not responsible for these policies or websites, so please check their policies before submitting any personal data.



8. Changes to Our Privacy Policy

We may update our privacy policy from time to time, and any changes will be posted on this page. Please check back frequently for updates. If we make significant changes to our policy, we will inform you.



9. Contact Us

If you have any questions or comments regarding this privacy policy, please contact us at general@crossborderworldwide.com.