Privacy Policy

Personal Information Collection Statement

This Statement is provided to the Customer as an individual Customer of the Company in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance, Chapter 486 of The Laws of Hong Kong (the “Ordinance”). Terms defined in this statement have the same meaning as in the Cash Client Agreement. 


A.Disclosure Obligation
Unless otherwise stated the Customer must supply the personal data requested on the Account Opening Information Form to the Company. If the Customer does not supply this data, it will not be possible for the Customer to open an Account with the Company as the Company will not have sufficient information to open and administer the Account.


B.Use of Personal Data 

All personal data concerning the Customer (whether provided by the Customer or any other person, and whether provided before or after the date the Customer receives the Cash Client Agreement containing this information) may be used by any of the following companies or persons (each, a “User”): 
i.The Company and/or any of its Associates (the “Group”);
ii.any director, officer or employee or agent of the Group;
iii.any person (such as lawyers, advisers, nominee, custodian etc.) authorized by the Group when carrying out the Customer’s Instructions and/or the business of the Group;
iv.any actual or proposed assignee of any rights and obligations of the Group in relation to the Customer; and
v.any governmental, regulatory or other bodies or institutions, whether as required by law or regulations applicable to any member of the Group.


All personal data concerning the Customer may be used by any User for the following purposes: 
i.carrying out new or existing client verification and credit checking procedures and assisting other financial institutions to do so;
ii.ongoing Account administration, including the collection of amounts due, enforcement of security, charge or other rights and interests;
iii.designing further products and services or marketing a Group product to the Customer;
iv.transfer of such data to any place outside Hong Kong;
v.comparison with the Customer’s personal data (irrespective of the purposes and sources for which such data were collected, and whether collected by a User or any other person) for the purpose of: (A) credit checking; (B) data verification; and/or (C) otherwise producing or verifying data which may be used for the purpose of taking such action that a User or any other person may consider appropriate (including action that may relate to the rights, obligations or interest of the Customer or any other person);
vi.providing on the terms of any other agreements and services relating to the Customer;
vii.any purpose relating to or in connection with compliance with any law, regulation, court order or order of any regulatory body; and
viii.any other purpose relating to the execution of the Customer’s Instructions or in connection with the business or dealings of the Group.


3.Rights of Access and Correction
The Customer has the right to have access to and correction of the Customer’s personal data as set out in the Ordinance. In general, and subject to certain exemptions, the Customer is entitled to: 
i.enquire whether the Company holds personal data in relation to the Customer;
ii.request access to the Customer’s personal data within a reasonable time, at a fee which is not excessive, in a reasonable manner and in a form that is intelligible;
iii.request the correction of the Customer’s personal data; and given reasons if a request for access or correction is refused, and object to any such refusal.


4.Use of Data in Direct Marketing
The Company intends to use Data Subjects’ data in direct marketing and the Company requires the Data Subjects’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that: 
i.the name, contact details, products, transaction pattern and behaviour, financial background and demographic data of Data Subjects held by the Company from time to time may be used by the Company in direct •marketing;
ii.the following classes of services, products and subjects may be marketed: 
• services and products offered by the Company’s or the Group Company’s co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be); and
• donations and contributions for charitable and/or non-profit making purposes.
iii.If any individual does not wish the Company to use or provide to other persons his/her data for use in direct marketing as described above, he/she may exercise his/her opt-out right by notifying the Company.


5.Contact Person
If the Customer wishes to request access to and/or correction of personal data concerning the Customer, the Customer should address the Customer’s request to the Data Protection Officer at the Company.