December 1, 2020
EFH Privacy Policy
Welcome to EquitiesFirst.com, operated by EQUITIES FIRST HOLDINGS (“EFH,” “we,” “us,” “our”). This Privacy Policy covers our website (EquitiesFirst.com), content, software products, mobile applications, mobile and web-based services, or any other EFH materials or services that refer to this policy (collectively, the “Site”). This Privacy Policy is intended to help you understand how we collect and use the personal and confidential information you decide to share or provide through use of the Services. This Privacy Policy sets forth our privacy practices and the possible uses of the information that we gather via the Site.This Privacy Policy applies to the Site, regardless of the medium in which it is accessed (e.g., mobile browser, computer browser, etc.).
THE SITE AND ACCESS TO ALL CONTENT ON THE SITE ARE INTENDED ONLY FOR PERSONS OF THE LEGAL AGE BASED ON YOUR LOCATION WHERE THE SITE AND ITS SERVICES ARE BEING ACCESSED OR VIEWED.
IF YOU DO NOT AGREE TO ABIDE BY THIS OR ANY FUTURE PRIVACY POLICY OR TERMS OF USE, DO NOT CONCLUDE OR ACCEPT THIS AGREEMENT, AND DO NOT VIEW, DOWNLOAD, OR OTHERWISE USE OR ACCESS (OR CONTINUE TO USE OR ACCESS) THE SITE OR ANY SERVICES MADE AVAILABLE VIA THE SITE.
Scope
This Privacy Policy applies to your use of the Site, regardless of the medium by which the Site is accessed by you.
The Information We Collect
When you visit the Site and use any of the services provided via the Site, we may collect information as disclosed below.
Personal Information: We collect personal information to provide the information or services requested by an individual. “Personal information” refers to any information relating to an identified or identifiable individual who is the subject of the information. We collect the following Personal Information.
- Name, email address, telephone number, address, any other personal or preference information that is necessary to comply with the local regulations or company bylaws or to perform adequate due diligence such as criminal history and relationship to government officials, passport information (number, issue date, issuing country and expiry date), other citizenship related information, position and title, some personal credit/financial information including the number of shares held and bank and securities account number and the purpose of funding, personal signature or registered seal.
Usage Information. When you use and navigate the Site, we may collect additional information from you that may not by itself reasonably identify you as the source (collectively, “Usage Information”). We collect the following Usage Information.
- Information on your mobile telephone, your computer, your IP address, the type of Internet browser you are using, the location from which you are visiting the Site, or the areas of the Site you visited and the actions you performed on the Site.
How We Collect Information
Directly from You. We collect Personal Information from you when you voluntarily provide Personal Information to us by, for example, by completing various forms, or requests for information.
Through Your Use of the Site. We record Usage Information that your browser transmits when you visit our Site. We also collect Usage Information about how you access and interact with the Site through the use of automated tracking technology, such as “cookies” and “web beacons.” A cookie is a small data file that is transferred to a web browser, which enables our Site to remember and customize your subsequent visit. Most Internet browsers automatically accept cookies. You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept cookies from our Site. Please refer to your Internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Site may be limited, and you may not be able to participate in several of the Site’ features. Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Site that allow us to gather information about your browsing activities on the Site.
Other Technologies: When you use the Site, or when you contact us, we may also collect other information about you as disclosed below. This information may be gathered for all Site users.
– We may collect certain information from your activity using other tracking technologies like tags, pixels, clear pixels, gifs, bugs, beacons, and other similar technologies, some of which may enable EFH or our service providers to identify you and collect information about you across devices and Site.
– We may collect information about your interactions with our customer service, such as the date, time and reason for contacting us, feedback you share with us, transcripts of any chat conversations, and if you call us, your phone number and call recordings.
How We Use Information
We process your Personal Information to carry out the purposes below and otherwise where we can rely on a legal ground for such processing. Where required by law, we will ask you for your prior consent.
Provision of the Site: The Site is a medium for interaction between you and us. We use and share the information we collect from you for the purposes described below. If you use our Site, we use your information to process and respond to your applications, requests, comments, inquiries, and other forms you submit through the Site.
Improving our Site: We use your information to enhance our understanding of our users’ preferences and improve our Site accordingly
Service Providers: We may employ third party service providers to perform functions on our behalf. They may have access to personal information needed to perform their functions but may not use it for other purposes.
Legal Obligations: From time to time, we may be required to share personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or related to an alleged unlawful activity.
Protection of EFH and Others: We may release your information when we believe release is appropriate to comply with the law or any rule, regulation, government or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of EFH, our affiliated companies, our users, or others. However, this does not include selling, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the terms set forth in this Privacy Policy.
Sale or Acquisition: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if EFH is transferred to another company, we may disclose and/or transfer your information as part of the transaction. If the surviving entity is not EFH, your information may be used pursuant to the surviving entity’s privacy policies, which may be different from this Privacy Policy.
Other Legitimate Interests: We will use and disclose your information when necessary for our legitimate interests, as long as such interests are not overridden by our users’ interests, rights, and freedoms with respect to their Personal Information.
Provision of Personal Information to Third Parties
We provide your personal information as described below. In case trasferred to foreign countries, the applicable personal information is transmitted through electronic means immediately after it is collected.
| Recipient (country) | Items of Personal Information to be Provided | Purposes of Use by Recipients | Period of Retention of Use by Recipient | Contact Information of Information Manager |
| EFH affiliates (For detailed information, please visit here) | Title, name, last name, company, email address, phone number | To identify readers of EFH articles and their location and send marketing materials and information on products/services | Up to 7 years | privacy@equitiesfirst.com |
| Nasdaq(United States) | Title, name, last name, company, email address, phone number | To identify readers of EFH articles and their location | Up to 7 years | privacy@nasdaq.com |
Delegation of Processing of Personal Information
We delegate the processing of your personal information as described below, and the delegatees may process your personal information according to the purpose of the delegation:
| Delegatee | Scope of Delegation |
| SalesForce.com | Maintenance of sales and marketing data base |
| Kim & Chang | Draft relevant transaction documents |
Data Transfers to Another Country
We transfer your Personal Information overseas as follows:
| Recipient (Contact Information of Information Manager) | Country to which Your Personal Information is to be Transferred | Date and Method of Transfer | Types of Your Personal Information to be Transferred | Purposes of Use by Recipients | Period of Retention of Use by Recipient |
| EFH LLC (jlapoint@equitiesfirst.com +13172500200) | USA | When there is a transaction transferred by email or SalesForce.com | Name, email address, telephone number, address, passport and other citizenship related information, certain personal credit and financial information including account information | For processing transaction application and KYC procedures | 7 years |
| EFH Hong Kong Limited(+852 3958 4500) | Hong Kong | When there is a transaction transferred by email or SalesForce.com | Same with above | Internal management and strategic planning | 7 years |
| SalesForce.com(privacy@salesforce.com) | USA and other countries where the servers are located | Electronically submitted to SalesForce system when applicable data is provided to EFH | Same with above | Maintenance services for EFH sales and marketing database | 7 years |
Period of Retention and Use of Personal Information
Your personal information will be retained and used for 7 years. However, if any personal information is required to be retained under applicable law, such information will be retained for the period and purpose as prescribed by law
Security
We take reasonable precautions to protect the information that is either available from or collected by this Site. We have taken steps designed to safeguard the Site’s integrity, its telecommunications, and computing infrastructure, including but not limited to, authentication, monitoring, auditing, and encryption. Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be completely secure. As a result, we cannot ensure or warrant that Personal Information will be completely secure from misappropriation by hackers, nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network.
Process and Method of Destruction of Personal Information
Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be processed, will be destroyed in an irreversible way, unless we are required to retain them for a longer period under applicable laws. Personal information stored in electronic files will be deleted in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating. Furthermore, in compliance with applicable laws, measures will be taken to destroy or segregate the personal information of the users and customers who have not used our services for a period of one year.
Rights of Data Subjects and Methods to Exercise Such Rights
You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. in writing or via email, fax, phone, etc. pursuant to applicable laws. You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise such rights. However, in this case, you must submit a power of attorney to us in accordance with applicable laws. Upon your request, we will take necessary measures without delay in accordance with applicable laws. You can also withdraw your consent or demand a suspension of the personal information processing at any time.
Links
This Site may contain links to or information about other websites that are outside our control or custody. We are not responsible for the content or privacy practices of other websites and suggest you review their privacy statements to understand how your information is used or shared by those other websites. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within a page of our Site.
Modification
This Privacy Policy was last modified on the date first printed above.
We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in our business practices. If we revise the Privacy Policy, we will notify you by posting the updated Privacy Policy Statement on the Site. Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy on the Site. Your continued use of the Site after any change has become effective will constitute your acceptance of any change.
Other Provisions
Additional Terms. This Privacy Policy may be supplemented by other terms and conditions with respect to your personal information. For example, if you reside in a particular country, there may be policies specifically applicable to you (see below). This Privacy Policy will supplement any other privacy statements provided by EFH, or its subsidiaries, affiliates, and the like.
Your California Privacy Rights. California law provides that California residents have a right to request businesses to tell them how their personal information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the contact information listed below.
Do Not Track. Certain web browsers and other devices you may use to access the Site may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Site does not respond to “Do Not Track” signals.
Children Under 13. We do not market to and do not knowingly collect any Personal Information from or about a child under the age of 13 without the consent of the child’s parent or legal guardian. If we discover that we have inadvertently collected information from a child under
Comments and Questions
If you have any questions or comments about the Privacy Policy, if you need to report a problem, or if you would like us to update, amend, or request deletion of the information we have about you, please contact our Chief Privacy Officer at:
CPO
Name: Albert Seunglip Lee
Department and Title: Head of Operations/Director
Telephone Number: 0263705186
E-mail: alee@equitiesfirst.com
Privacy Policies Applicable to Specific Jurisdictions
Your jurisdiction may have specific requirements with respect to how EFH and its subsidiaries treat your personal information. For EFH’s full privacy policies in certain jurisdictions, please use the links below:
