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Circular to Clients relating to the Personal Data (Privacy) Ordinance (“the Ordinance”)

(a) From time to time, it is necessary for clients to supply the Group with data in connection with the opening or continuation of accounts and the establishment or continuation of credit facilities or provision of securities brokerage, nominee and investment advisory service. At the same time, some of the data are collected pursuant to laws, regulations, rules or codes binding on the Group or any other companies of the Group.

(b) Failure to supply such data may result in the Group being unable to open or continue accounts or establish or continue credit facilities or provide securities brokerage, nominee and investment advisory services.

(c) It is also the case that data are collected from clients in the ordinary course of the continuation of the business relationship.

(d) The purposes for which data relating to a client may be used are as follows:-
(i) the daily operation of the services and credit facilities provided to clients;
(ii) conducting credit checks;
(iii) assisting other financial institutions to conduct credit checks;
(iv) ensuring ongoing credit worthiness of clients;
(v) designing financial services or related products for clients’ use;
(vi) marketing financial services or related products;
(vii) determining the amount of indebtedness owed to or by clients;
(viii) collection of amount outstanding from clients and those providing security for clients’ obligations;
(ix) meeting the requirements to make disclosure under the requirements of any laws, regulations, rules, codes binding on the Group or any other companies of the Group; and
(x) purposes ancillary or relating thereto.

(e) Data held by the Group relating to a client will be kept confidential but the Group may provide such information to the following parties within or outside Hong Kong to the extent permitted by law:-
(i) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or securities clearing, printing or other services to the Group in connection with the operation of its business;
(ii) any other companies of the Group;
(iii) any other person under a duty of confidentiality to the Group including a company of the Group which has undertaken to keep such information confidential;
(iv) any financial institution with which the client has or proposes to have dealings;
(v) any actual or proposed assignee of the Group or participant or sub-participant or transferee of the Group’s rights in respect of the client;
(vi) any other person when we are compelled to make disclosure under the requirements of any laws binding on the Group or any of the companies of the Group;
(vii) any person with the client’s express or implied consent;
(viii) any person where our interests require disclosure; and
(ix) any person where the public interest requires disclosure.

(f) Use of Data in Direct Marketing
The Group intends to use the Client’s personal data for direct marketing carried out by the Group. The intended kinds of personal data to be used and the intended classes of marketing subjects are specified below. However, the Group may not use the Client’s personal data and/or provide the Client’s personal data unless exempted by the Ordinance or the Group has received the Client’s consent.

For the above direct marketing use, the Group intends to:
(i) use the Client’s name, contact information and demographic information; and
(ii) market or promote the investment products or financial services of the Group.

The client can always opt-out free-of-charge by contacting the Group’s Data Privacy Compliance Officer if the client no longer wishes any of the Client’s personal data to be used in any of the described direct marketing purposes.

(g) In the course of performing our duties, the Group may, as permitted by law, match, compare, transfer or exchange any personal data provided by the client, or hereafter obtained, for these or any other purposes by the Group, with data held by government bodies, other regulatory authorities, corporations, organisations or individuals in Hong Kong or overseas for the purpose of verifying those data.

(h) Under and in accordance with the terms of the Ordinance, any individual:-
(i) has the right to check whether the Group holds data about him/her and the right of access to such data;
(ii) has the right to require the Group to correct any data relating to him/her which is inaccurate;
(iii) has the right to ascertain the Group’s policies and practices in relation to data and to be informed of the kind of personal data held by the Group.

(i) In accordance with the terms of the Ordinance, the Group has the right to charge a reasonable fee for the processing of any data access request.

(j) The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:-

The Group Data Protection Officer
Shenwan Hongyuan (H.K.) Limited
Level 19, 28 Hennessy Road, Hong Kong