1. Who we are

This privacy notice applies to all Personal Data processing activities carried out by Bullish (GI) Limited and its affiliates (collectively, “Bullish”, “we”, “us” or “our”).

Bullish acts as the data controller for your Personal Data unless a different affiliate is named in a separate privacy notice, or we have identified a different data controller for a particular processing operation.

We respect an individual’s rights to privacy and are committed to protecting the privacy of your personal information. This Privacy Notice explains how we demonstrate this commitment, including: 

(a) the types of information we collect through your use of our products and services including our exchange software and mobile applications, and your navigation of our Websites;

(b) the manner in which we use and the information, and why;

(c) the circumstances in which your information may be transferred to another country;

(d) the rights you may have under relevant privacy or data protection laws;

(e) cookies that we use or used by our service providers; and

(f) whom you can reach out to regarding this Privacy Notice. 

This Privacy Notice complies with and constitutes the requisites found in Article 12 of the General Data Protection Regulation and DPP1(3) and DPP5 under the Personal Data (Privacy) Ordinance, Cap. 486. Where a law or regulation in the applicable jurisdiction requires us to provide you with a notice or other explanation of the information about you that we collect and process, our use of your Personal Data, and your rights, the purpose of this Privacy Notice is to satisfy that requirement.

2. Acceptance to this Privacy Notice

We are committed to protecting your privacy. By accessing Bullish Services you acknowledge and fully understand Bullish’s Privacy practices described in this Privacy Notice.

By accessing and using our Service, you signify your acceptance to the terms of this Privacy Notice. If you do not agree with or you are not comfortable with any aspect of this Privacy Notice, you should immediately discontinue access or use of our Services.

3. Purpose of this Privacy Notice

The purpose of this Privacy Notice is to explain how we collect and use Personal Data in connection with our business. In this Privacy Notice, “Personal Data” means any information relating to an identified or identifiable natural person as may be collected or processed by us in connection with the Data Sources. This is a broad definition that encompasses the specific types of personal data listed below. It excludes information that cannot be used to identify a specific individual, such as a company’s registration number.

The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Notice.

4. Scope

This Privacy Notice applies to your use of, access to, or participation in any of the following sources (collectively, our “Data Sources”):

(i) our products, services, applications or software offered through the Bullish Website or mobile application, including any communications with you about our Services (our “Services”), unless a separate privacy policy is expressed to apply in respect of such Service; 

(ii) any Bullish website (URL: www.bullish.com) or subdomains regardless of the medium in which the websites are accessed by a user (e.g., via a web or mobile browser) and any apps owned by Bullish (the “Websites”);  

(iii) any events hosted by us, whether such events are open to the public or by invitation (collectively the “Events”); and 

(iv) subsections of social media platforms (e.g. LinkedIn) controlled by us. 

5. Personal Data We Process

We process the Personal Data we collect about you when you use, gain access to, or participate in our Data Sources. 

Personal data or personal information refers to any information that identifies or can be used to identify an individual. This is a broad definition that encompasses the specific types of personal data listed below. It excludes information that cannot be used to identify a specific individual, such as a company’s registration number.

A “data subject” is a person who can be directly or indirectly identified by personal data.

Typically, this is done by referencing an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a natural person.

Personal data also includes separate pieces of information that, when combined, can lead to the identification of a particular individual. It excludes information from which the identity has been removed. (anonymous data).

We collect Personal Data through:

• Your use of or participation in our Data Sources. For example, we may collect Personal Data from you when we onboard you as a client. A third party’s use of our Data Sources relating to you, for example where a third party may manage a Service or Event on our behalf. 
• Direct or unsolicited interactions, such as when you voluntarily provide your information to us by contacting us, submitting requests and comments, subscribing to our newsletters, submitting job applications, or otherwise engaging with us through our Data Sources. For example, we may collect Personal Data from you when you sign up for a marketing newsletter.
• Indirectly, such as through public or media Websites or government Websites when conducting user identity verifications and reviews.

You must ensure that all information provided by you to us is accurate, comprehensive, and current. Inaccurate or insufficient Personal Data you provide may have a negative impact on how we interact with you in the course of our business.