Your trust and confidence in how BlueX Trade, Inc. (BlueX Trade or we) collect, use, and share information about you is a priority. This Privacy Notice applies to our websites, our mobile applications, our branded social media sites or pages, and other online, mobile or other services that link to or from or expressly reference this Privacy Notice as well as any interactions you may have with our digital advertising campaigns (collectively, the Sites/Services). This Privacy Notice also explains how we collect, share, use, and protect information when you visit or use the Sites/Services. We advise you to read carefully this Privacy Notice in its entirety, including the jurisdiction-specific provisions in the appendix to this Privacy Notice, which will apply to users in certain jurisdictions. By using the Sites/Services, you agree to this Privacy Notice.
As you review this Notice, here are a few important things to keep in mind:
- This Site and our Services are for business entities and are not for natural persons.
- This Site is not intended for children under 13 years of age, and we do not knowingly solicit information from, or market to, children under 13 years of age. Rather our targeted market is business entities.
- Wireless service providers, Internet service providers, device manufacturers and/or social media platforms may have their own privacy notices that are different from this one for the information they may access through your use of the Sites. We encourage you to read their privacy notices because the collection, uses and sharing of information by those third parties may be different than ours.
- Our mobile, social media, or other services, sites, pages or materials may have additional terms about the privacy or use of your information. Please review the privacy notice for the specific Site/Service you are using.
We collect two types of information: Personal Information and Other Information.
Personal Information is any information:
- that identifies or can be used to identify you, especially as that information relates to information, we collect on business entities and their representatives and beneficial owners;
- that relates to, describes, is capable of being associated with, or could reasonably be linked (directly or indirectly) with you, especially as that information relates to information, we collect on business entities and their representatives and beneficial owners;
- that can be used to authenticate you or provide access to a business entity account or service that has been established with us by or on behalf of a business entity; that relates to you and that might be sensitive (such as social security number, driver’s license information or passport information).
Other Information is any information:
- that does not and cannot reveal an individual's specific identity, such as information that has been de-identified or aggregated. This Other Information is more specifically described in the Use of Information section below.
For at least the past 12 months, we have collected the following categories of Personal Information from the following sources:
Through the Sites/Services
What we collect: We collect from you (which, for the purposes of this section, refers to you and the business entity for whom you represent) through the Sites/Services Personal Information that identifies you as an individual or relates to identifying information about you, including identifiers such as your name; business title; business addresses; residence address; business telephone number; mobile phone number; business email; personal e-mail; and other information.
Depending upon the Services requested, we may collect additional Personal Information such as: alias; mother's maiden name; gender; race; age; date of birth; information from a birth certificate or death certificate; relationship status; Social Security number; information that appears on your driver's license; green card; national ID; State ID; or Passport/Visa; your citizenship and military status; information about your education, employment and employment history, and property; biometric information; and other personal identification numbers.
We, or companies we work with, collect from you: other Internet or other electronic network activity information such as browser and device information; usage data through BlueX's mobile apps; information collected through cookies, web beacons and other technologies; demographic information; applications you submit; and aggregated information about your visits to, or use of, our Sites/Services. While that information alone may not reveal your specific individual identity, we may associate this usage and Other Information we collect with Personal Information about you.
If you have access to a BlueX account, we also collect and maintain account and transaction information including: your user ID; account holder name; account PIN and password; security question(s) and word(s); signature; loyalty program information (when applicable); merchant name and contact information; merchant category code; transaction data/history; your photo (when provided); image documentation; and your voice recordings (when provided). We also collect from third parties account identifiers used in transfers of funds.
Our business purpose for collecting this information: reviewing and processing applications for our Services; intake of new customers; account maintenance and servicing; providing customer service; improving our Sites/Services; performing research and business analytics, and identifying usage trends; engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; performing reviews and audits; verifying requests made pursuant to this Privacy Notice; tailoring marketing communications from our affiliates as well as from selected third parties; managing our business effectively; and developing new products and services.
Through your browser or device
What we collect : Certain information is collected from you by Internet browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version.
We may also collect from you various attributes associated with your device (such as IP address, installed fonts, language and browser settings, and time zone) in order to create a device fingerprint or identifier so that we can recognize your device, along with the time of your visit and the page(s) visited.
If you have access to a BlueX Trade account or registration, we also collect and maintain account and transaction information including: your user ID; account holder name; account PIN and password; security question(s) and word(s); signature; assets in the account; bank SWIFT code; bank account number; bank name; bank address; IBAN; loyalty program information (when applicable); merchant name and contact information; merchant category code; transaction data/history; your photo (when provided); image documentation; and your voice recordings (when provided). We also collect from third parties account identifiers used in transfers of funds.
Our business purpose for collecting this information : reviewing and processing applications for our Services; intake of new customers; account maintenance and servicing; providing customer service; improving our Sites/Services; performing research and business analytics, and identifying usage trends; engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; performing audits; verifying requests made pursuant to this Privacy Notice; tailoring marketing communications from our affiliates as well as from selected third parties; managing our business effectively; and developing new products and services.
Through your use of our BlueX Trade apps
What we collect: When you download and use one of the BlueX Trade apps, we may collect your cookie ID, device IP address, email address, search history and geolocation data.
We may also collect and/or track your app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to or presented through the app.
If you have access to a BlueX Trade account, we also collect and maintain account and transaction information including: your user ID; account holder name; account PIN and password; security question(s) and word(s); signature; assets in the account; bank SWIFT code; loyalty program information (when applicable); merchant name and contact information; merchant category code; transaction data/history; your photo (when provided); image documentation; and your voice recordings (when provided). We also collect from third parties account identifiers used in transfers of funds.
Our business purpose for collecting this information: reviewing and processing applications for our Services; intake of new customers; account maintenance and servicing; providing customer service; improving our Sites/Services; performing research and business analytics, and identifying usage trends; engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; performing audits; verifying requests made pursuant to this Privacy Notice; tailoring marketing communications from our affiliates as well as from selected third parties; managing our business effectively; and developing new products and services.
Using unique identifiers such as cookies, pixel tags, device profiling, and similar technologies
Our business purpose for collecting this information: operating, maintaining, and protecting our Sites/Services; reviewing and processing applications for our Services; intake of new customers; account maintenance and servicing; improving our products and services; improving your experience on our Sites; performing research and business analytics; understanding your interests and preferences; tailoring and sending you marketing communications for ourselves and for selected third parties; engaging in fraud monitoring and prevention; protecting our business and our customers against illegal activity; compliance with applicable laws and regulations.
Drawing Inferences from Personal Information
What we develop: We may create user profiles based upon inferences from the Personal Information about you that we have collected (please see the Online Advertising section below for more information on our online advertising practices). In some instances, we may combine Other Information with Personal Information where permissible by law and applicable industry guidelines. In addition to Personal Information, you provide directly to us, we may collect Other Information about you, including acquiring and using services provided by other parties who collect and analyze customer data.
Our business purpose for drawing these inferences: using these inferences for our internal business and operational purposes, such as to: provide customer service and support; improve our products and Sites/Services; performing research and business analytics; and better tailoring marketing communications from our affiliates as well as from selected third parties. For more information, please see the Online Advertising below.
Third Party Sources
What we collect: We may collect information about you from certain third-party sources, including, for example, financial institutions and government sources.
Our business purpose for collecting this information: engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; reviewing and processing applications for our Services; intake of new customers; managing our business effectively; account maintenance and servicing.
International Data Transfers
If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of service providers to help us do so.
We use the Personal Information and Other Information we collect from and about you to:
- Authenticate you so that you can access the Sites and conduct account transactions on behalf of a business entity that has an account or registration with BlueX Trade;
- Recognize you, your device or your browser when you use the Sites/Services so that we can facilitate navigation, display information more effectively, store your preferences and otherwise personalize your experience and enhance the use of the Sites;
- Process the applications and transactions you are making on behalf of a business entity that has an account or registration with BlueX Trade;
- Respond to your inquiries, fulfill requests and request your feedback;
- Service the account and market to the business entity you represent, including advertisements and other communications tailored to the business entity, on our Sites/Services and third-party sites, as well as offline (please see the Online Advertising section for more information on our online advertising practices);
- To track responses to our e-mails and advertisements and to measure the success of our marketing campaigns;
- Provide account information to you regarding the business entity you represent, as well as information regarding our events;
- Facilitate social sharing functionality, where appropriate;
- For our business purpose and other lawful purposes, such as for data analysis, audits, fraud monitoring and prevention, information security, improving the Sites, developing new products and services, managing our business effectively, identifying usage trends, and expanding our business activities;
- Review statistical information about use of the Sites in order to improve their design and functionality, to understand how they are used, and to assist us with resolving questions about the Sites; and
- Ensure that the Sites function properly and otherwise administer the Sites.
We may use, or share with others (in anonymous or non-readable form where appropriate) your information in order to better recognize you when visiting the Site and to provide relevant advertising (for BlueX Trade or third party's products/services), based on the interests of the business entity you represent, on the Site, on other sites and apps and other channels including television, email and direct mail.
During at least the past 12 months, we have disclosed your Personal Information for the following business purposes:
- with our affiliates to the extent permissible under applicable law;
- with third parties, to permit them to send you marketing communications for the business entity you represent on our behalf;
- with our service providers, who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, processing transactions on behalf of the business entity you represent, e-mail delivery, auditing, and other services; and
- with a third party in the event of any proposed reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
We also may use and disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
Where appropriate, we will limit sharing of your Personal Information in accordance with the choices you have provided us in response to our Privacy Notice or other privacy choices that we may make available.
We may share de-identified or aggregated information with third parties to help deliver products, services, and content that are tailored to the users of our Sites and for other business purposes.
We may transfer information to BlueX Trade affiliated companies or other parties throughout the world to process transactions and provide products and services to the business entity you represent. Regardless of where we process your information, we still treat it in accordance with this Privacy Notice and applicable law.
BlueX Trade, as well as others, offers account aggregation services that allow the business entity you represent to consolidate the electronically enabled financial account information from the business entity you represent from different sources (such as the accounts of the business entity you represent with us or with other financial institutions) so that you can view all of the account information of the business entity you represent in one online location. When acting as an account aggregator, BlueX Trade or its aggregation service provider may request your account user credentials for third-party (non-BlueX Trade) financial accounts, including usernames and passwords, in order to access the account information of the business entity you represent as the agent of the business entity.
If you provide us access, as the agent of the business entity you represent, to your third-party account information we may use such information as well as the BlueX Trade account information where applicable, to provide the business entity you represent offers, suggestions and insights on the spending, savings and other financial behaviors of the business entity you represent. These insights are not investment, tax or legal advice and neither BlueX nor any of its affiliates are acting as a tax, legal or investment advisor in providing same.
You may on behalf of the business entity you represent cancel enrollment in BlueX Trade's aggregation service or delete accounts at any time. Upon cancellation or deletion of an account, we will delete and direct our service provider to delete this data from our and their respective records as permitted under applicable law.
With regard to aggregation services provided by a third-party, if you provide your user credentials or other Personal Information about the BlueX Trade accounts established by the business entity you represent to a third-party aggregation services provider, we will consider that you have authorized all transactions or actions initiated by such access information you provide, whether or not you were aware of a specific transaction or action. If you decide on behalf of the business entity you represent to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for BlueX Trade to ensure that the aggregation website cannot continue to access the account information.
We may, directly or through third parties, serve ads regarding products and services intended to be of interest to the business entity you represent on the Site and on third party sites or apps. We and others may use the online technologies described in the Use of Information section above to make inferences and predictions about the characteristics, interests and preferences of the business entity you represent based on your and its online interests and activities across other sites. We may also use technologies to associate and recognize your various mobile and desktop devices in order to deliver ads and other content in a consistent manner across the devices you use. Information we collect using the technologies described above may also be associated or linked with Personal Information, such as email or postal address, you provided directly to us or others. Alternatively, Personal Information may also be linked with characteristics or attributes about you or the business entity you represent, such as lifestyle interests, in support of our marketing efforts. If you opt out of interest-based advertising, as described in the Your Choices Regarding Your Personal Information section below, you will not receive such customized ads on the Site or in other places.
You have certain rights with regard to your Personal Information.
A. Your California Privacy Rights
If you are a California resident, you have the right to request and receive certain information about disclosure of your Personal Information to third parties for their direct marketing purposes. Because it is our policy not to share your Personal Information with third parties for third-party direct marketing purposes without your consent, we are exempt from the requirement to respond to such requests. If you have any questions related to our policy, please contact us using the information provided in the Contact Us section below.
For information regarding how to exercise your rights as a consumer under the California Consumer Privacy Act, please see Supplemental provisions for California residents in the Appendix to this Privacy Notice.
B. Cookies and Interest-Based Advertising
Both the Network Advertising Initiative and the Digital Advertising Alliance (to whose principles we adhere) provide information about and technologies to opt-out of receiving some or all interest-based advertising. You can also opt-out of interest-based advertising by clicking on the appropriate icon within an interest-based ad which will take you to tools to help you manage these choices. These technologies are browser and device specific; they must be adopted on each device you use. If you block or clear cookies, these technologies may not work. You will continue to see ads on the Site which reflect how you use the Site and our Services.
If you would prefer not to receive interest-based advertising, you can opt-out of this activity at the DAA website by visiting http://www.aboutads.info/choices/ (for U.S. residents).
You can choose whether to accept cookies through your browser settings. For example, most browsers allow you to automatically decline cookies or decline or accept a particular cookie (or cookies) from a particular site when browsing. If you decide not to accept cookies, some features of the Site may not work properly because we may not be able to recognize your device and associate you with your BlueX Trade account(s). In addition, the offers or content we provide when you visit our site or on third party sites may not be as relevant to you or tailored to your interests.
Local Shared Objects, sometimes referred to as flash cookies may be stored on your hard drive using a media player or other software installed on your device. Local Shared Objects are similar to cookies in terms of their operation, but may not be managed in your browser in the same way. Restricting acceptance of Local Shared objects may impede the functionality of some Flash applications, including those used in connection with the Site including animation and video presentations. Similarly, certain authentication features of the BlueX Trade apps may set a persistent token, similar to a cookie, on your mobile device. This token allows that device to be uniquely associated or bound with your account. This token will remain on your device until you un-enroll from those features or delete the app from your device.
C. Do Not Track
Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser do not track signals.
Keeping the account information on the business entity you represent accurate and up to date is very important. If the account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on the account statements, records, online or other account materials.
The security of your Personal Information is a priority. We seek to protect this information by implementing and maintaining reasonable physical, electronic, and procedural security measures and safeguards designed to protect Personal Information within our organization. We provide employee training in the proper handling of Personal Information. Unfortunately, no data transmission over the Internet or wireless network or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have access to with us has been compromised), please immediately contact us in accordance with the Contact Us section below.
A. Notice of Changes
We may change this Privacy Notice from time to time. Please take a look at the Last Updated legend at the beginning of this Privacy Notice to see when this Privacy Notice was last revised. When we do, we will post the revised Privacy Notice on this page with a new effective date. Any changes will become effective when we post the revised Privacy Notice on the Site. Your use of the Sites/Services following these changes means that you accept the revised Privacy Notice.
B. Third-Party Sites and Services
This Privacy Notice does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating any site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, usage, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other third-party app provider, social media platform provider, operating system provider, device manufacturer, or wireless service provider, including with respect to any Personal Information you disclose to other organizations through or in connection with the Site/Services.
C. Jurisdictional Issues
The Site is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Information about you may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you consent on behalf of the business entity you represent and yourself to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
If you have any questions about this Privacy Notice, please contact the account representative of the business entity you represent, or contact us at
11F, No. 132 Nanjing East Road
If you are contacting us from outside the United States, please refer to the BlueX Trade website in your country or use the contact details in the local privacy notice, if any, for your product. If you would like to submit a request pursuant to the California Consumer Privacy Act (CCPA), please let us know. If you wish to submit a request to have your Personal Information deleted (see section I.A.3 in the Appendix below) or wish to opt-out of the selling of your Personal Information, call us at the number above.
Requests. California residents have certain rights with respect to Personal Information under the California Consumer Privacy Act (CCPA). For purposes of this subsection, the terms consumer, categories of Personal Information, business purpose, third party, and sell have the meanings ascribed to them respectively in the CCPA. Terms defined under the CCPA may differ in meaning from the common usage of the same terms used elsewhere in this Privacy Notice.
You have the right to request, up to two times every 12 months, that BlueX Trade disclose to you the following: (i) the categories of Personal Information that BlueX Trade has collected about you; (ii) the categories of sources from which BlueX Trade has collected Personal Information about you; (iii) the business or commercial purpose for collecting or selling your Personal Information; (iv) the categories of Personal Information that BlueX Trade has sold about you in the last 12 months and the categories of Third Parties to whom the Personal Information was sold, by category or categories of Personal Information for each Third Party to whom the Personal Information was sold; (v) the categories of Personal Information that BlueX Trade has disclosed about you for our business purposes in the last 12 months and the categories of Third Parties to whom the Personal Information was disclosed, by category or categories of Personal Information for each Third Party to whom the Personal Information was disclosed; and (vi) the specific pieces of Personal Information that BlueX Trade has collected about you.
You have the right to request a portable copy of your Personal Information.
In response to verified requests pursuant to (i) or (ii) above, we will confirm receipt of the request within 10 business days of receipt of the request, and disclose and deliver the required information to you free of charge within 45 days of receiving a verifiable consumer request. We may extend this time period to provide once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.
You have the right to request that BlueX Trade delete Personal Information collected from you, subject to certain exceptions allowed under applicable law.
In response to verified requests pursuant to (iii) above, we will confirm receipt of the request within 10 business days of receipt of the request. Following verification of your request, we may require you to separately confirm that you want your Personal Information to be deleted
You have the right to opt out of the sale of your Personal Information to Third Parties by contacting us at the telephone number or email address provided under the Contact Us section of this Privacy Notice. The CCPA defines sale very broadly, covering both monetary and other consideration. BlueX does not sell personal information for money. However, we share some types of Personal Information.
BlueX Trade will not discriminate against you because you elect to exercise these rights, including by:
- Denying goods or services to you.
- Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of goods or services to you.
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
None of the foregoing, however, prohibits BlueX Trade from charging you a different price or rate, or from providing a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to BlueX Trade by your data.
Submission of Requests. You may exercise these rights by contacting us at the telephone number or email address provided under the Contact Us section of this Privacy Notice. If you wish to submit any type of CCPA request through an authorized agent, please follow the process in Section I.D. below.
Requests From Households. BlueX Trade cannot take action in response to a request to know or request to delete as it pertains to household specific pieces of personal information unless all of the following conditions are satisfied: All consumers of the household must jointly request access or deletion through the processes outlined in this Privacy Notice. We are able to individually verify (i) all members of the household; and (ii) that all individuals making the request are still members of the household.
CCPA Authorized Agent. CCPA permits consumers to designate authorized agents to submit requests on their behalf. Under CCPA, an authorized agent is a natural person or a business entity registered with the Secretary of State to conduct business in California that a consumer has authorized to act on their behalf subject to the requirements. If you would like to designate an authorized agent to submit a request to know or a request to delete Personal Information on your behalf, please contact us at the telephone number or email address provided under the Contact Us section of this Privacy Notice.
Please be advised of the following additional information that will be required:
We require a written power of attorney, executed by you, confirming the authority of the authorized agent with respect to your CCPA request(s). After you initiate a request with us by phone or email, we will provide you with a form of power of attorney. Prior to responding to any request made on your behalf by an authorized agent, we may require you to provide written confirmation directly to us that you have provided the authorized agent permission to submit such request(s) on your behalf. Once verified, your authorized agent may create a unique account for you through BlueX Trade and manage your requests through that account.
Verification. Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests under CCPA. Upon receiving a request in accordance with the appropriate section of this Privacy Notice, we will confirm receipt within 10 days and provide you with information about how we will verify and process the request. In order to verify your request, we will require you to provide your social security number, tax ID number or passport number and issuing country, in addition to your first and last name, email address and mailing address.
Do Not Call Policy. This notice is the BlueX Trade Do Not Call Policy under the Telephone Consumer Protection Act. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless the law allows. Our employees receive training on how to document and process telephone marketing choices. Consumers who ask not to receive telephone solicitations from us will be placed on the BlueX Trade Do Not Call list and will not be called in future campaigns.
Call Monitoring and Recording. If you communicate with us by telephone, we may monitor or record the call.
We are providing you this notice under state law. You may be placed on our internal Do Not Call List by contacting us by following the instructions in the Contact Us section of this Privacy Notice. Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702.486.3132; email: firstname.lastname@example.org; and the information in the Contact Us section of this Privacy Notice.
Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, unless the law allows. For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.