Licenced by SFC Type 1, 4 & 9 & MAS Capital Market Services
Notice to Customers relating to the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong)
Purpose of this notice:
This notice is made by the Company in compliance with the Ordinance. It is the policy of the Company to observe the data protection and privacy provisions of the laws of the HKSAR in the collection, maintenance and use of Personal Information and the purpose of this notice is to inform the Customers of the Company of the data privacy policies of the Company. This notice applies to Customers of the Company and includes any borrower, guarantor, third-party security provider, depositor, directors, shareholders, officers and managers of any corporate applicants/customers of other similar data subject. Nothing in this notice shall limit the rights of customers under the Ordinance.
“Data access request”, “data correction request”, “data subject”, “data user”, “direct marketing”, “matching procedures” and “personal data” used throughout this Notice shall have the meaning as defined in the Ordinance.
For the purpose of this Notice:
“Company” means Raffles Assets Management (HK) Co. Limited.
“Company Group” means any subsidiaries or affiliates or the holding company (together with the subsidiaries, affiliates and holding company of this holding company of the Company wherever located.
“Customers” means data subjects and include (but not limited to) existing and prospective clients of the Company.
“HKSAR” means the Hong Kong Special Administrative Region.
“Ordinance” means Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) as amended, supplemented, re-enacted or replaced from time to time, and includes all rules and regulations promulgated under the same.
“Personal information” means personal information and data relating to the Customer including, without limitation, the Customer’s name and address, details of employment, details of properties or other assets, information regarding credit standing, information obtained during the course of business and any other information in the public domain.
1. From time to time, it is necessary for customers to supply the Company with personal data in connection with the establishment or continuation of the business relationship, or the provision of products or services. Failure to supply such data may result in the Company being unable to establish or continue the business relationship, or provide products or services.
2. It is also the case that personal data are collected or received by the Company from and/or in respect of customers in the ordinary course of the continuation of the business relationship. From time to time, it is necessary for Customers to supply the Company with Personal Information in connection with the opening or continuation of accounts and the establishment or continuation of facilities or the provision of accounts and services and/or financial services or compliance with any laws or guidelines issued by regulatory or other authorities.
3. The purposes for which personal data of a customer may be used will vary depending on the nature of the customer’s relationship with the Company. Such purposes may include the following:
(a) processing, assessing and determining applications or requests made by customers for products and/or services;
(b) administering, maintaining, managing and operating products and/or services provided to customers;
(c) confirming customer’s identity and uniquely identifying customer;
(d) confirming the accuracy of the information collected;
(e) understanding customer’s financial situation better, evaluating customer application, assessing the risks the Company is assuming and reviewing claims submitted to the Company;
(f) any purposes in connection with any claims made by or against or otherwise involving
customers in respect of any products and/or services including but not limited to making, defending, analyzing, investigating, processing, assessing, determining or responding to such claims;
(g) providing investment management services, dealing and advisory services, custody services (where applicable) and other services under the terms and conditions of the accounts a customer holds with the Company;
(h) performing any functions and activities related to products and/or services including but not limited to marketing, audit, reporting, research, analysis, reinsurance, and general servicing and maintenance of online and other services;
(i) researching and/or designing products and/or services for customers, and promoting, improving and furthering the provision of products and/or services;
(j) conducting matching procedures (as defined in the Ordinance, but broadly includes a comparison of two or more sets of the data subject’s data, for purposes of taking actions adverse to the interests of the data subject, such as declining an application);
(k) making disclosure under and/or complying with the requirements of any law, rules,
regulations, codes of practice, guidelines or guidance binding on or applicable to the Company or any member of the Company Group (whether within or outside Hong Kong) including but not limited to making a disclosure to local or foreign regulators, governmental bodies, industry-recognized bodies (whether within or outside Hong Kong) such as federations or associations of insurers, credit reference agencies or auditors;
(l) complying with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry-recognized bodies (whether within or outside Hong Kong) that is assumed by or imposed on the Company or any member of the Company Group by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry-recognized bodies;
(m) for operational purposes, credit assessment, credit scoring models or statistical analysis (including in each case, behavior analysis and evaluation on the overall relationship with the Company Group which includes using such data to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Company Group and/or other use of data and information in accordance with any the Company Group-wide programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities), whether on the data subjects or otherwise;
(n) exercising any rights the Company may have in connection with the provision to customers of products and/or services;
(o) conducting identity and/or credit checks;
(p) determining any amount of indebtedness owing to or from customers, and collecting and recovering any amount owing from customers or any person who has provided any security or undertaking for customers’ liabilities;
(q) enabling an actual or proposed assignee, transferee, participant or sub-participant of the rights or business of the Company or any member of the Company Group to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;
(r) purposes specifically provided for in any particular service or product offered by the Company;
(s) any purposes relating to the above (including seeking professional advices) or any other purposes in accordance with the general policies of the Company or any member of the Company Group in relation to insurance, investment funds, wealth management services and other financial products and services as set out in notices, circulars, or other terms and conditions made available by the Company or any member of the Company Group to customers from time to time.
4. Personal data of a customer held by the Company will be kept confidential but the Company may transfer such data to the following persons and/or entities (whether within or outside Hong Kong) for any of the purposes set out in paragraph 3 above:
(a) any person in connection with any claims made by or against or otherwise involving customers in respect of any products and/or services;
(b) any agent, contractor or third-party service provider who provides administrative, telecommunications, computer, information technology, payment, data processing or storage, marketing, mailing, printing, telemarketing, customer satisfaction analysis, or other services to the Company or any member of the Company Group in connection with the operation of the business, including any custodian, administrator, investment manager, investment advisor or distributor;
(c) any credit reference agencies or, in the event of default, any debt collection agencies;
(d) any financial institution with which the Company or any member of the Company Group has or proposes to have dealing on behalf of,in the interest of and/or under the authority of Customers (e.g. custodians holding Customers’ assets);
(e) any advisor (including his or her employees) or another intermediary (including their employees);
(f) reinsurers and medical service providers;
(g) employers of the customers;
(h) any person which has undertaken to the Company or any member of the Company Group to keep such data confidential;
(i) any actual or proposed assignee, transferee, participant or sub-participant of the rights or business of the Company or the Company Group;
(j) any member of the Company Group;
(k) any person to whom the Company or any member of the Company Group is under an obligation or otherwise required to make disclosure under the requirements of any law, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to the Company or any member of the Company Group including but not limited to any local or foreign regulators, governmental bodies, or industry-recognized bodies;
(l) any person to whom the Company or any member of the Company Group is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry-recognized bodies (whether within or outside Hong Kong) that is assumed by or imposed on the Company or any member of the Company Group by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, industry-recognized bodies.
PROVISION OF PERSONAL DATA FOR USE IN DIRECT MARKETING
5. The Company intends to use a Customer’s data in direct marketing with Customer’s consent (which includes an indication of no objection for that purpose). The following kinds of personal data of the customer may be used in such direct marketing:
(c) date of birth;
(d) part of identity card or passport number;
(e) contact information (including but not limited to phone number, fax number, email address,
correspondence address and residential address);
(f) information about the products and/or services the customer has purchased or applied, including the distribution channels (including their individual advisors or intermediaries) through which the products and/or services were purchased or applied for.
6. Under the Ordinance, a data subject has the right to:
(a) request access to his or her personal data;
(b) request correction of any of his or her personal data which is inaccurate;
(c) ascertain a data user’s policies and practices in relation to personal data;
(d) be informed of the kind of personal data held by the data user;
(e) be informed of the main purposes for which personal data held by the data user are or are to be used;
(f) make data access requests and data correction requests through the channel set out in paragraph 7 below.
7. In accordance with the provisions of the Ordinance, the Company has the right to charge a reasonable fee for processing any data access request. Requests may be made in writing to the Privacy Officer at:
Data Privacy Officer
Raffles Family Office
Unit 2306-2313, 23/F, The Centre
99 Queen’s Road Central
Tel: (852) 3108 8700
Fax: (852) 3108 8701