Privacy Policy


How we collect, store, use and protect personal data

Please read this statement before disclosing any personal data.

It is often necessary for Clients to provide data in connection with the opening of accounts and setting up facilities or other services. Failure to provide such data may result in failure to open accounts or facilities or provide other services.

Data can collected from Clients in the ordinary business conditions and data may be exchanged in the context of a business relationship between Client and Company.

Providing personal data to the Company through electronic (e-mail, Internet or recording systems) cannot be guaranteed to be secure. the Company will not be responsible for damages suffered by Clients if they send information to the Company using electronic devices, or if the Company sends information through electronic devices on request of the Client. Clients should take be diligent of potential vulnerabilities and communicate personal data with caution.

The Company will not collect any personal data identifying a visitor to the Company Website unless specifically requested by the Client. Your visit to the Website will only record the Domain Name Server, your email address and a log of pages visited. This information will only be used to prepare general statistics on usage patterns of the Website.

The purposes for which personal data relating to Clients may be used are as follows:
  • (i) daily operation of services and facilities provided to Clients;
  • (ii) conducting KYC and credit checks;
  • (iii) assisting other financial institutions to conduct checks;
  • (iv) ensuring credit worthiness of clients;
  • (v) designing financial services products for clients' use;
  • (vi) marketing of financial services products;
  • (vii) determining level of indebtedness owed to or by clients;
  • (viii) meeting the disclosure requirements of any legal or regulatory requirement or court order.
  • (ix) any purposes relating to the above.
Use of Personal Data in Marketing:

The Company intend to use or transfer the Clients data to related companies of the Company for direct marketing, the Company require the consent of the Client for that purpose. In connection with this, please note:

  • (a) name, contact details, products and services, portfolio information, transaction patterns, financial background, demographic data. May be held by the Company and used by the Company for direct marketing;
  • (b) the following services, products or subjects may be marketed:
  • (i) securities, investments, commodities and related services or products;
  • (ii) reward, loyalty and privilege programmes referred to in clause b(i);
  • (iii) donations and contributions to charitable or non-profit purposes.
  • (c) Any Client who doesn't wish the Company to use or transfer the Client's data for direct marketing may without charge exercise the right to opt-out.
  • Personal Data held by the Company relating to a Client will remain confidential but the Company may provide information to the following parties:
  • (i) an agent, contractor or 3rd party service provider providing administrative, computer, financial, cash, securities, telecommunications, trade execution or contracts, clearing, settlements or other services to the Company in connection with business operations;
  • (ii) any person or group in a role of confidentiality to the Company who has undertaken to keep information confidential;
  • iii) financial institutions or dealers with which the Client have dealings;
  • (iv) a credit reference agency in the event of default or debt collection;
  • (v) any actual or proposed assignees of the Company or participant or transferee of the rights of the Company in respect of the Client;
  • (vi) any exchange, agency, regulatory, entity or government body if required by law or pursuant to court orders or regulations to which the Company is subject. The Company is usually under duty of secrecy and won't be able to notify a Client or seek consent in relation to a release of information.
  • In accordance with the terms of the Personal Data Ordinance, an individual has the right to:
  • (i) check whether the Company holds data about them and the right to access such data;
  • (ii) require the Company to correct data relating to them which is inaccurate;
  • (iii) ascertain the Company's policies and practices relating to data and be informed of the type of personal data held by the Company.
Any person who requests access to personal data or the correction of data or information regarding policies and practices and types of data held should be addressed to the following:

Castleton Rose
21/F, One Island East
18 Westlands Road, Quarry Bay.
Hong Kong.

In accordance the Personal Data Ordinance of the Laws of Hong Kong, the Company has the right to charge a fee for processing any data request.

In addition to the Company's duty of confidentiality to Clients, the Company shall observe these privacy principles and Ordinance of Hong Kong SAR in collecting, using and maintaining the personal data of Clients.

This Policy may occasionally be revised, supplemented or amended by the Company.