Privacy and Policy


The objective of this Privacy Policy is to set out in an accountable and transparent way the manner in which H2OEX collects and uses your Personal Information.

This Privacy Policy covers H2OEX and all companies affiliated to H2OEX. We take all appropriate steps to protect our customers' personal information. In the course of providing our services, we need to collect and maintain personal information as defined by regulation in Hong Kong (e.g. in the Personal Data (Privacy) Ordinance – CAP 486). As a rule, we never disclose any personal information about our customers to any non-affiliated third parties, except as described below.

When you apply for, open, or maintain an account with us or post a comment or message on our site, subscribe to our newsletter, we may collect and retain the following information: the data you provide online and on applications or other forms, or through discussions we have with you or your representatives, such as your name, address, state authority issued identification number, date of birth, income, employment information, and any information about your personal goals or objectives with regard to cryptocurrencies; any data about your transactions with or through us, such as your account balance, trading activity, and account history, if applicable; any data you provide us about your external bank or financial services accounts in order for us to provide you with the most efficient service. In accordance with the existing regulations, all data that is not directly related to our business or upon fulfillment of the purpose for which it was retained will be deleted. You may, however, visit our site anonymously.

Personal Information we collect may be used in one of the following ways:


To personalize your experience (your information helps us to better respond to your individual needs);

To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you);

To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);

To process transactions (your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested);

To send periodic emails (the email address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.);

To meet regulatory and/or compliance obligations (we are required to verify your identity and obtain additional information when your account transacts in fiat currencies).


Disclosure of Information

Consent is required for the collection of Personal Information and the subsequent use or disclosure of Personal Information. The form of consent may vary, depending upon the circumstances and the type of Personal Information obtained. In the case of H2OEX, your agreement with the Terms of Service constitutes your consent to the collection and use of Personal Information as described in this Privacy Policy. Sometimes, H2OEX may reach out to you for consent to obtain and then use further information, and H2OEX reserves the right to do so. In exceptional circumstances, as permitted by applicable law, H2OEX may collect, use and disclose Personal Information without your knowledge or consent.

If you decide to withhold certain information, it may limit our ability to provide you with the services or products you requested. We do not disclose personal information about former customers to anyone, except as permitted by law or to cooperate with regulators or law enforcement authorities.

We may disclose your personal information to the following entities: our affiliated companies; companies that service, maintain, or process your transactions and accounts (e.g., companies and financial institutions that provide administrative, telecommunications, computer, trade execution, payment or clearing, prepare and mail account statements and transaction confirmations and other services in connection with the operation of our business); non-affiliated third parties as required by law, or to cooperate with regulators or law enforcement authorities (e.g., government and regulatory organizations, such as the Hong Kong Internal Revenue Department (IRD), the Hong Kong Customs and Excise Department (and other international data protection authorities), as well as self-regulatory organizations of which we are a member, and states we are registered with and to parties under court order or subpoena that request this information); non-affiliated third parties at your direction or for which you have provided your express consent (e.g., any banking or financial institution from or to which you have or propose to have money transfers).

We may also share US residents’ personal information with other financial institutions as authorized under Section 314(b) of the US Patriot Act, and with law enforcement or tax authorities, including the US Internal Revenue Service (pursuant to the Foreign Account Tax Compliance Act, "FATCA") and the US FinCEN. FATCA reporting to the IRS may also apply to US nationals residing abroad.

We require that commercial entities (as described above) with which we share your personal information agree to keep your information confidential. We also prohibit those entities from using or disclosing your information except for a limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted or required by law. Service providers to whom we disclose personal information must agree to contractual requirements consistent with our privacy and security policies. We prohibit our service providers from using personal information except for the specific purpose for which we provide it to them, and require them to comply with legal obligations applicable to the personal information at issue. Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.


We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Storage of Data

Generally, the personal information that we collect from you will be stored in Hong Kong and other countries, which may have different privacy laws and standards than those in your country of residence. Your personal information may be transferred to or processed in Hong Kong by us or a third party service provider working for us, or for one of our affiliates or suppliers. By submitting personal information via our website or other means, you agree to such storage, transfers and processing. We will take all steps reasonably necessary to treat your personal information securely and in accordance with this Privacy Policy.

It is important to note that some or all of your personal information provided to third party service providers may be held in countries other than your own, including in particular Hong Kong. You acknowledge and understand that your personal information will be subject to the applicable laws of each such jurisdiction, which may not provide for the same protection as your country of residence. For example, government entities in Hong Kong and other countries may have certain legislative rights to access your personal information. If you have questions about our policies and practices with respect to service providers outside your jurisdiction, including the collection, use, disclosure or storage of such personal information by our service providers worldwide, you may contact us by email at [email protected]

Protecting Your Personal Information

This Privacy Policy and the use of your Personal Information only applies to the information you provide. You are cautioned that if you disclose Personal Information or personally sensitive data through use of the Internet, such as through chat rooms, communities, bulletin boards, or other public online forums, this information may be collected and used by other persons or companies over which H2OEX has no control. It is your responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract. H2OEX is not responsible for the privacy statements, policies, terms, conditions, or other content of any website not owned or managed by H2OEX.

H2OEX does its best to protect and safeguard Personal Information, but there are protective measures you should take, as well. Do not share your Personal Information with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Information in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Information, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.

Use of Cookies

The Site may use a browser feature called a “cookie” to collect information anonymously and track user patterns on H2OEX. A cookie is a small text file containing a unique identification number that identifies a customer’s browser, but not the customer personally, each time that customer visits a websites using cookies. Cookies tell H2OEX which pages of the Site are visited and how many people visited each one. This helps enhance visitors’ online experience. Cookies also serve to identify your computer so that your preferences can be saved for future visits, and H2OEX may work with third parties that use these cookies to help us.

The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Site.

Using Personal Information:

H2OEX is committed to protecting your privacy. Internally, only employees with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. The Site’s systems and data are constantly reviewed to ensure that you are getting the best possible service and that leading security features are in place.

We must reserve the right to retain and share certain Personal Information in order to meet our regulatory requirements and further to our contractual agreements with partners and third parties.

H2OEX uses IP addresses to analyze trends, administer the Site, track user movements, and gather broad demographic information for aggregate use. For systems administration and detecting usage patterns and troubleshooting purposes, H2OEX’s web servers also automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within H2OEX on a need-to-know basis. H2OEX reserves the right to block access for any user accessing the Site via a proxy service intending to conceal originating identity. This includes access via the Tor anonymity network.

H2OEX reserves the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and, other aggregate data and information related to the cryptocurrencies traded on the Site.

Personal Information and other data may be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

Children’s Privacy

By policy and in compliance with the requirements of the US COPPA (Children’s Online Privacy Protection Act), our website is not targeted to children under the age of 13 and we do not intentionally collect personal information from children under the age of 13. If we discover that a child under the age of 13 has provided us with personal information through this website, we will take reasonable steps to delete the information. If you believe we may have accidentally received personal information from a child under the age of 13, please contact us immediately at [email protected]

Terms and Conditions

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at

By using our site, you consent to our privacy policy.

This policy has been last updated on April 14th 2018. In case of revision the link on our website will point toward the newly revised policy statement and we may make an announcement in the news section.