Basis Analytics HK Limited ("we", "us", "our"), a company incorporated in Hong Kong SAR, respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the BASIS platform and services (collectively, the "Service"). We process personal data in accordance with applicable data protection laws in the jurisdictions where we offer our Service, including the Hong Kong Personal Data (Privacy) Ordinance (PDPO), the Singapore Personal Data Protection Act, the Malaysia Personal Data Protection Act, the Philippines Data Privacy Act, the Indonesia Personal Data Protection Law, the Thailand Personal Data Protection Act, Vietnam's data protection regulations, and, where applicable, the General Data Protection Regulation (GDPR).
1.1. Basis Analytics HK Limited is the Data Controller for the purposes of this Privacy Policy.
1.2. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy or our data protection practices, please contact our DPO at:
**Data Protection Officer**
Basis Analytics HK Limited
Hong Kong SAR
Email: [email protected]
2.1. **Personal Data You Provide:**
2.1.1. **Account Information:** Name, email address, password, and username.
2.1.2. **Billing Information:** Payment details, including payment card information and billing address. Payment processing is handled by our third-party payment processor and merchant of record; we do not store full payment card details.
2.1.3. **Profile Information:** Information you choose to add to your profile, such as a profile picture or biography.
2.1.4. **Communication Data:** Information you provide when you contact us for support or other purposes.
2.2. **Data Collected Automatically:**
2.2.1. **Usage Data:** Information about how you interact with the Service, including pages visited, features used, and time spent on the Service.
2.2.2. **Device Information:** IP address, browser type and version, operating system, device type, screen resolution, and similar technical data.
2.2.3. **Log Data:** Server logs that record activity on the Service, including timestamps, request URLs, and response codes.
2.2.4. **Cookies and Tracking Technologies:** Information collected through cookies and similar technologies (see Section 6 for details).
We use your information for the following purposes:
3.1. **Service Delivery:** To provide and maintain the Service, including processing your transactions and managing your account.
3.2. **Communication:** To send you technical notices, updates, security alerts, support messages, and other service-related communications.
3.3. **Service Improvement:** To monitor usage patterns, analyze trends, and improve the Service.
3.4. **Fraud Prevention:** To detect, prevent, and address fraud, security, or technical issues.
3.5. **Marketing:** To send you promotional communications about our products and services, where you have consented to receive such communications. You may opt out of marketing communications at any time.
3.6. **Legal Compliance:** To comply with applicable laws, regulations, and legal processes.
We process your personal data on the following legal bases, depending on the requirements of applicable law:
4.1. **Contractual Necessity:** Processing is necessary for the performance of the contract we have with you (the Terms of Use).
4.2. **Legitimate Interests:** Processing is necessary for our legitimate interests, which include: (i) improving and enhancing the Service; (ii) ensuring network and information security; (iii) understanding how users engage with our platform to develop new features; (iv) protecting against fraud and misuse. You have the right to object to processing based on legitimate interests.
4.3. **Consent:** Processing is based on your explicit consent, where you have provided it (e.g., for marketing communications). You may withdraw consent at any time.
4.4. **Legal Obligation:** Processing is necessary for compliance with our legal obligations under applicable laws.
We retain your personal data for the following periods:
5.1. **Account Data:** While your account is active and for a reasonable period after account closure to comply with legal obligations and resolve disputes.
5.2. **Financial Records:** Financial transaction records are retained for a minimum of 7 years to comply with tax and accounting requirements.
5.3. **Usage Data:** Anonymised usage data may be retained indefinitely. Anonymised data is data that cannot be re-identified, and we commit not to re-identify it. Pseudonymised usage data is retained for up to 36 months, based on our product improvement cycle.
5.4. **Marketing Data:** Retained until you withdraw consent or request deletion.
5.5. **Session Cookies:** Essential session cookies are stored only for the duration of your browser session and are deleted when you close your browser.
5.6. **User-Generated Content:** Data related to your watchlists and portfolios is retained for as long as your account is active and you have not deleted such content. You may delete this data at any time through the Service.
5.7. Upon account deletion, we will delete or anonymise your personal data, except where we are required to retain it for legal compliance or legitimate business purposes.
We use cookies and similar tracking technologies to enhance your experience.
6.1. **Essential Cookies:** Required for the Service to function. These cannot be disabled. They include session cookies that are deleted when you close your browser.
6.2. **Analytics Cookies:** Help us understand how you interact with the Service (e.g., Google Analytics).
6.3. **Functional Cookies:** Remember your preferences and settings.
6.4. **Your Choices:** You can control cookies through your browser settings. Disabling certain cookies may affect your ability to use certain features of the Service.
7.1. **We do not sell your personal information.**
7.2. We may share your information with the following categories of recipients:
7.2.1. **Service Providers:** Third parties that assist with payment processing, data hosting, email delivery, analytics, and the aggregation of Financial Data from official regulatory filings, stock exchange feeds, and institutional partners. These include:
- **Data Aggregators:** Providers that collect and normalise financial data from official sources.
- **Payment Processors and Merchant of Record:** Our third-party payment processor and merchant of record, together with ancillary payment service providers where required.
- **Cloud Infrastructure:** Amazon Web Services (AWS) or similar cloud providers.
- **Email Service Providers:** For sending service and marketing communications.
- **Analytics Providers:** Google Analytics or similar for usage analysis.
7.2.2. **Legal Compliance:** When required by law, regulation, or legal process.
7.2.3. **Business Transfers:** In the event of a merger, acquisition, or asset sale.
7.3. We require all third-party sub-processors to comply with applicable data protection laws and to provide appropriate safeguards for your data.
8.1. Your data may be transferred to and processed in countries outside Hong Kong and the European Economic Area (EEA), including Singapore and other jurisdictions where our service providers operate.
8.2. We take appropriate safeguards to ensure your data is protected in accordance with this Privacy Policy and applicable laws. These safeguards include:
- **Standard Contractual Clauses:** Where required, we use EU-approved Standard Contractual Clauses as the legal mechanism for data transfers to countries without an adequacy decision.
- **Data Protection Agreements:** We enter into data protection agreements with our sub-processors.
- **Compliance with Local Transfer Requirements:** We comply with cross-border data transfer requirements under applicable local laws, such as those in Indonesia, the Philippines, and Thailand, including any required notices or registrations.
8.3. If you are located in the EEA, your personal data will be transferred and processed in accordance with these safeguards.
Depending on your location and applicable law, you may have the following rights:
9.1. **Right of Access:** You have the right to request a copy of the personal data we hold about you.
9.2. **Right to Rectification:** You have the right to request correction of inaccurate or incomplete personal data.
9.3. **Right to Erasure (Right to be Forgotten):** You have the right to request deletion of your personal data, subject to certain exceptions.
9.4. **Right to Restriction:** You have the right to request restriction of processing of your personal data.
9.5. **Right to Data Portability:** You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
9.6. **Right to Object:** You have the right to object to processing of your personal data for direct marketing purposes or based on legitimate interests.
9.7. **Right to Withdraw Consent:** Where processing is based on consent, you have the right to withdraw consent at any time.
9.8. **Right to Lodge a Complaint:** You have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.
9.9. **Exercising Your Rights:** To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond within 30 days (or such shorter period as required by applicable law). We may verify your identity before processing your request. Certain rights may be subject to limitations under local law.
10.1. BASIS uses automated scoring algorithms to generate the BASIS Score and other analytical outputs. The BASIS Score is a statistical percentile ranking derived solely from peer comparison within a sector. It does not represent an investment rating, recommendation, valuation, or eligibility determination, and is provided strictly for informational, research, and educational purposes.
10.2. We do not make automated decisions that have legal or similarly significant effects on you. Your investment decisions are your own and are not subject to automated decision-making by our Service.
10.3. If you have concerns about automated processing, please contact our Data Protection Officer at [email protected].
11.1. We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These include:
- **Encryption:** Data in transit is encrypted using TLS (Transport Layer Security).
- **Secure Storage:** Data at rest is encrypted using industry-standard encryption.
- **Access Controls:** Strict access controls limit who can access your personal data.
- **Security Assessments:** Regular security assessments, vulnerability scanning, and penetration testing.
11.2. No method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.
11.3. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and any relevant supervisory authority in accordance with the timeframes and procedures required by applicable data protection laws (for example, within 72 hours where required by the GDPR or the Philippines Data Privacy Act).
12.1. The Service is not intended for individuals under the age of 18. By using the Service, you confirm that you are at least 18 years of age or have obtained parental consent if required by local law.
12.2. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently received personal data from a minor, we will delete it promptly.
12.3. If you are a parent or guardian and believe we have collected personal data from a minor, please contact us at [email protected].
13.1. We may update this Privacy Policy from time to time. We will notify you of material changes by email or through a notice on the Service.
13.2. What constitutes a material change will be determined at our sole discretion. Non-material changes may be made without prior notice.
13.3. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the revised Privacy Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:
**Basis Analytics HK Limited**
Hong Kong SAR
**Data Protection Officer:**
Email: [email protected]
**General Inquiries:**
Email: [email protected]
**To exercise your data subject rights, please use:**
Email: [email protected]
We will respond to all legitimate requests within 30 days (or such shorter period as required by applicable law).