Notice to Client Relating to the Personal Data (Privacy) Ordinance

 

This statement is made by Pinjin (Hong Kong) Asset Management Co. Limited (the “Company”) in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”). 

 

1.When you visit this website, the “cookies” allows website to recognize your browser for analysis on the number of visitors to this website and general usage patterns. “Cookies” may store your preferences and other information. The information collected by “cookies” is anonymous with no name or address information or any information that will enable anyone to contact you via e-mail, telephone or any other means. None of your personal data is stored in”cookies”. You can reset the browser to refuse all “cookies” or to indicate when a “cookies” is being sent. However, some features or services of this website may not function properly without “cookies”.

 

2.There may be instances where Clients elect to provide personal data to the Company through electronic means (such as Internet or voice recording system). Whilst the Company generally uses best endeavors to maintain the security and integrity of its systems, due to many unpredictable traffic or other reasons, electronic communication may not be a reliable medium of communication. Clients should take heed of such weaknesses and communicate personal data through electronic devices with caution.

 

3.From time to time, it is necessary for Clients to supply the Company with personal data in connection with the opening or continuation of accounts or provision of other advisory or investment services. If the Client does not provide such personal data, it will not be possible for the Client to open an Account with The Company as the Company will not have sufficient information to open and administer the Account.

 

4.Use of Personal Data

 

4.1 User

All personal data concerning the Client (whether provided by the Client or any other person) 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 of the Group; 

(iii)any agent, contractor or third party service provider who provides administrative, telecommunications, computer, legal, accounting, payment or securities clearing or other services to the Company and/or the Group in connection with the operation of its business;

(iv)any other person under a duty of confidentiality to the Company and/or the Group;

(v)any actual or proposed assignee of the Company or the Group or participant or sub-participant or transferee of the Company’s or the Group’s rights in respect of the Client; and

(vi)any person to whom the Company or the Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to the Company or the Group or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which the Company or the Group are expected to comply, or any disclosure pursuant to any contractual or other commitment of the Company or the Group with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside the Hong Kong and may be existing currently and in the future.

 

4.2 Purposes

Personal data held by the Company relating to a Client will be kept confidential. But all personal data concerning the Client 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 financial services or related products/services for the Client use;

(iv)marketing financial services or relating products /services for the Client use (please see further details in paragraph 5 below);

(v)comparison with the Client's personal data (irrespective of the purposes and sources for which such personal 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 personal 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 Client or any other person); 

(vi)providing on the terms of any other agreements and services relating to the Client; 

(vii)meeting the requirements to make disclosure under the requirements of any law regulations rules, codes binding on the Company and/or the Group;

(viii)any other purpose relating to the execution of the Client's Instructions or in connection with the business or dealings of the Group;

(ix)the Company may from time to time transfer the personal data relating to the Client to a place outside Hong Kong for the purposes set out above.

 

5. Use of Personal Data In Direct Marketing

5.1 The Company intends to use the Client’s personal data in direct marketing and the Company requires the Client’s consent (which includes an indication of no objection) for that purpose;

5.2 The name, contact details, products and services portfolio information, financial background and demographic data of the Client held by the Company from time to time may be used by the Company in direct marketing;

5.3 The Client’s Personal data will be used for direct marketing of the following products / services:

(i) asset management; 

(ii)other related investment opportunities; and 

(iii)any other financial or investment products or service.

5.4 The above products and services may be provided or solicited by the Company and/or

(i)any member of the Group; 

(ii)third party financial institutions, insurers, securities, commodities and investment services providers; and

(iii)co-branding partners of the Company and the Group (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).

5.5 If the Client does not wish the Company to use or provide to other persons his data for use in direct marketing as described above, the data subject may exercise his opt-out right by notifying the Company.

 

6.Rights of Access and Correction

The Client has the right to have access to and correction of the Client's personal data as set out in the Ordinance. In general, and subject to certain exemptions, the Client is entitled to:

6.1 enquire whether the Company holds personal data in relation to the Client; 

6.2 request access to the Client's personal data within reasonable time, at a fee which is not excessive, in a reasonable manner and in a form that is intelligible; 

6.3 request the correction of the Client's personal data; 

6.4 ascertain the Company and/or the Group’s policies and practices in relation to personal data and to be informed of the kind of personal data held by the Company and/or the Group; and

6.5 stop using or transferring the Client’s personal data for direct marketing.

 

7.If the Client requests for access to and/or correction of personal data , the Client should address the request as follows:- 

 

Pinjin (Hong Kong) Asset Management Co. Limited

Unit 1801,18/F,Infinitus Plaza, 199 Des Voeux Road Central, Hong Kong

Attn: Data Protection Officer

Fax No. : (852)2105 9800

 

Note: If there is any inconsistency between the English and Chinese version, the English version shall prevail.