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Personal Information Collection Statement and Privacy Policy Statement

1. General

The Company is committed to protecting the personal data of individuals and therefore it is the Company’s policy to ensure its policies and practices in relation to the collection, use, transfer, retention and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance, Cap.486 (the “Ordinance”).

2. Types of Personal Data Collected

For the purpose of provision of mortgage and loan referral services by the Company, customers may be requested to provide personal data including but not limited to the name, contact details (including but not limited to telephone number, fax number, email and/or correspondence address), identification document number and copy of any document which may contain the personal data of the customers, such as identity card, passport, bank statements and utility bills. Failure to supply such personal data may result in the Company being unable to provide mortgage and loan referral services.

3. Use of Personal Data

The personal data provided by the customers may be used by the Company for the purpose of:

  1. provision of mortgage and loan referral services;
  2. direct marketing of the mortgage and loan referral services of the Company;
  3. direct marketing of the services, reward and/or promotional programmes and/or events provided by the institutions or individuals listed in paragraph 6 below (the “Third Parties”) in relation to the classes of marketing subjects specified in paragraph 5 below (the “Services”);
  4. compliance with the applicable laws, rules and regulations as well as the guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company;
  5. collection of outstanding debts from customers; and/or
  6. legal proceedings and/or enforcement of judgments and/or orders.

4. Use of Personal Data for Direct Marketing

The Company intends to use the name and contact details (including telephone number, fax number, email and/or correspondence address) of the customers for direct marketing of the mortgage and loan referral services provided by the Company.

5. Transfer of Personal Data for Direct Marketing

The Company intends to transfer the name and contact details (including telephone number, fax number, email and/or correspondence address) of the customers to the Third Parties for use in direct marketing of the following Services and the Company may derive gain as such:

  1. real estate agencys;
  2. financial planning;
  3. wealth management;
  4. insurance;
  5. property valuation;
  6. immigration consultancy;
  7. banking;
  8. legal services; and/or
  9. reward and/or promotional programmes and/or events

6. Transfer of Personal Data

Personal data of customers held by the Company may be transferred to the following parties for use in direct marketing as stated above:

  1. service providers of the Company offering rewards and/or promotions;
  2. law firms, banks, financial institutions, insurers, service providers for estate agency, financial planning, property valuation, immigration consultancy and/or wealth management;
  3. government agencies, regulatory bodies and/or other lawful authorities;
  4. courts, tribunals and/or parties to the legal proceedings;

7. Request to Cease the Use of Personal Data for Direct Marketing

Even if customers have given consent to the Company on the use and/or transfer to the Third Parties of their personal data for direct marketing, customers may still have the right, at any time without charge, to request the Company to cease to use and/or transfer their personal data to the Third Parties for direct marketing. Customer may write to the Data Protection Officer of the Company at [email protected] or 17/F, OTB Building, 160 Gloucester Road, Wanchai, Hong Kong for making such request. The Company will cease using their personal data for such purpose.

8. Security and Retention of Personal Data

The Company has implemented internal control measures to ensure the security of personal data and to prevent unauthorized or accidental access, process, erasure, loss or use of personal data. Personal data of customers will be retained by the Company for 7 years or such longer period as prescribed by applicable laws, rules and regulations as well as guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company.

9. Access to and Correction of Personal Data

Under the Ordinance, customers have the right to access and/or correct their personal data. Accordingly, customers may at any time write to the Data Protection Officer of the Company at [email protected] or 17/F, OTB Building, 160 Gloucester Road, Wanchai, Hong Kong. In accordance with the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.

10. Enquiries

All enquiries about this statement or personal data shall be addressed in writing to the Data Protection Officer of the Company at [email protected] or 17/F, OTB Building, 160 Gloucester Road, Wanchai, Hong Kong

The Company reserves the right to change this Statement and/or any part thereof.

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