Halcyon Securities Limited

Data Privacy Policy of Halcyon Securities ("HSL")

1. At HSL, we want to provide the best service possible to our customers.

2. One way that we do this is by using customer information to provide our customers with convenient access to the right products and services. We also recognize that our customers have important expectations regarding the use of that information.

3. Safeguarding customer information is a matter that we take seriously. That is why we at HSL have set forth the following principles to affirm our long-standing commitment to confidentiality.

4. From time to time, it is necessary for customers who are individuals to supply HSL with data which are personal data (“Data”) for the purposes of the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong). The purposes for which Data (and other information) relating to customers may be used are as follows:

the daily operation of the services and facilities provided to customers;

conducting credit checks;

assisting other institutions to conduct credit checks;

ensuring customers’ ongoing credit worthiness;

designing financial services or related products for customers’ use;

marketing financial services or related products to customers (please see further details in clause 6 below);

determining the amount of indebtedness owed to or by customers;

meeting the requirements to make disclosure under the requirements of any law or regulations; and

any purposes relating to any of the foregoing.

5. Data (and other information) held by HSL relating to customers will be kept confidential but HSL may disclose, and it is a condition of HSL providing services, products and information to customers that each customer consents to the disclosure of all Data (and other information) to:

any officer, employee, agent, contractor or third party who provides administrative, credit information, debt collection, telecommunications, computer, payment or other services to HSL in connection with the operation of their business;

any financial institution with which the customer has or proposes to have dealings;

regulatory or judicial authorities and other relevant government or statutory bodies:

any other person under a duty of confidentiality to HSL including a company within HSL which has undertaken to keep such information confidential.

We share information regarding customers among HSL only in accordance with strict internal security standards and confidentiality policies and with applicable law.

We hold our employees fully accountable for adhering to those standards, policies and laws.

We do not share information about our customers with other companies except in order to conduct our business, comply with applicable law, protect against fraud or make available special offers of products and services that we feel may be of interest to our customers. We may also provide information to regulatory authorities and law enforcement officials in accordance with applicable law.

We have established high standards for protecting information regarding our customers from unauthorized alteration or destruction.

6. USE OF DATA IN DIRECT MARKETING
We intend to use your personal data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. The specific requirement regarding your consent (which includes an indication of no objection) is introduced in Part VIA of the Personal Data (Privacy) Amendment Ordinance 2012. In this connection, please note that:

a. your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by HSL from time to time may be used by HSL in direct marketing;

b. the following classes of services, products and subjects may be marketed:

i. financial, insurance, securities, commodities, investment and related services and products and facilities;

ii. reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to in clause 6b(i) above;

iii. services and products offered by HSL'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) in relation to the class of marketing subjects as referred to in clause 6b(i) above; and

iv. donations and contributions for charitable and/or non-profit making purposes;

c. the above services, products and subjects may be provided or (in the case of donations and contributions) solicited by HSL and/or:

i. any member of HSL;

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

iii. third party reward, loyalty, co-branding or privileges programme providers;

iv. co-branding partners of HSL (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

v. charitable or non-profit making organisations;

d. in addition to marketing the above services, products and subjects itself, HSL also intends to provide the data described in clause 6(a) above to all or any of the persons described in clause 6(c) above for use by them in marketing those services, products and subjects (in respect of which HSL may or may not be remunerated), and HSL requires your written consent (which includes an indication of no objection) for that purpose;

If you do not wish HSL to use or provide to other persons your data for use in direct marketing as described above, you may exercise the opt-out right by notifying HSL in writing to the address provided below in clause 9 of this notice.

7. HSL may, in accordance with the Personal Data (Privacy) Ordinance and any other applicable law,

a. match, compare or exchange any Data or other information provided by, or in respect of, a customer with Data (or other information) held by HSL or any other person for the purpose of.

credit checking;

Data (and other information) verification;

otherwise producing or verifying Data (and other information) which may be used for the purpose of taking adverse action against the customer or any other person at any time;

b. transfer such Data (and other information) to any place outside Hong Kong (whether for the processing, holding or use of such Data (and other information) outside Hong Kong).

8. Under and in accordance with the terms of the Personal Data (Privacy) Ordinance each customer has a right to:

a. check whether HSL hold Data about the customer and the right of access to such Data;

b. require HSL to correct any Data relating to the customer which is inaccurate; and

c. ascertain HSL’s policies and practices in relation to Data and to be informed of the kind of personal data relating to the customer held by HSL.

9. Request for access and/or correct any data that customer has submitted shall be sent to the following address:

Halcyon Securities Limited

11/F, 8 Wyndham Street,

Central, Hong Kong

Attn: Customer Service Department

or phone to 3970 0918

10. In accordance with the terms of the Personal Data (Privacy) Ordinance, HSL has the right to charge a reasonable fee for the processing of any Data access request.

11. At HSL, information regarding our customers is used solely in the legitimate conduct of our business, to deliver superior service and to design products and special offers that demonstrate our understanding of our customers and their needs.

12. As we move forward in developing new products and services in an era of vast technological change, we will continue to maintain our dedication to assuring that customer information is properly used and appropriately safeguarded.