● any group website that links to this policy; or
● social media or group content on other websites.
Collection of Personal Data
Company by doing any of the following:
● when you register, log in or complete other online forms, including the related mobile application (if any); or
● when you respond to requests to submit personal information about yourself (if any); or
● when you otherwise contact us by phone, in writing, or by post, and we may keep a record of that correspondence; or
● based on any other information we receive about your transactions from our files, our affiliates or another source whether involved in your transactions or otherwise. The information that we collect may include:
● personal identification number and contact details such as your full name, date of birth, and Tax Reference Number (or equivalent), email address, home address, and telephone number;
● your marketing preferences;
● user names, passwords; and/or
● sensitive personal information (although we will always explain clearly when and why we need this information and the purpose for which we will use it).
Use of Personal Data
EFS International Limited ( the “Manager”) may collect and use information about visitors to the Website to conduct its business, including identifying your requirements, delivering services and information which you have requested, promoting other services which may be of interest to you and collating web user statistics. We may also use it to contact you for your views on our services and events and to notify you occasionally about important changes or developments to the Website or our services,
unless you have opted out of receiving such services as set out in the Managing your preferences section below.
Data Transfer and Consent
The personal information that we collect from you may be transferred by the Company to the Manager to and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us, a service provider, or business partner. The purposes and processing associated with any such
transfer will comply with all applicable data protection regulations, including the EU General Data Protection Regulations, and with our obligation to protect your personal information and keep it secure. Where required under applicable laws we will take measures to ensure that personal information handled in other countries will receive at least the same level of protection as it has in the EEA. By submitting your personal information, you agree to us transferring, processing, and
storing your personal information as described above. In certain circumstances, we may ask for your explicit consent to make an international transfer of your information.
Disclosure of Information
We take all reasonable care to prevent any unauthorised access to your personal information. We may disclose your personal information to:
● any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
● our affiliates or professional advisers; or
● where we need to send the information to persons or organisations who work on our
behalf to provide a product or services to you, but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose.
We may also share or sell, as permitted by law, information to other companies who we believe may have products and services of interest to you. If you do not wish to receive information from us or from other sources, or you wish to review your settings, please follow the instructions under the Managing your preferences section below. We may also share this information about our visitors, customers, or former customers to
companies that perform marketing services on our behalf or with whom we have joint marketing agreements.
How we Protect your Data
● required by law; or
● to protect the safety of our employees, the public or group property; or
● required to comply with a judicial proceeding, court order, or legal process; or
● in the event of a merger, asset sale, or other related transaction; or
● for the prevention or detection of crime (including fraud).
You should be aware that communications over the internet, such as emails, are not secure unless they have been encrypted. Wherever possible, the Company uses encryption, however, we cannot guarantee the security of your information absolutely and you acknowledge that we may be subject to breaches of security through no fault of our own.
Fraud Prevention and Detection
We may, as a matter of law, and without requiring notice or consent, obtain information about you from our third-party suppliers and other third-party databases to detect and prevent fraudulent activity within the group and to monitor and/or enforce the Company’s compliance with any regulatory rules and codes. We may also share your information with regulatory bodies in the United Kingdom or, if applicable, overseas, as well as with other companies (directly or via shared databases) to prevent and detect fraud.
In order to prevent and detect fraud we may at any time:
● share information about you with other organisations and public bodies including the police;
● undertake additional fraud searches; or
● check and/or file your details with fraud prevention agencies and databases, and if you give us false or inaccurate information and we suspect fraud, we will record this to prevent fraud and money laundering.
We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details write to us at the correspondence address below or by sending us an email to [email protected] We and other organisations may also search these agencies and databases to:
● help make decisions about the provision and administration of investment services;
● trace debtors or beneficiaries, recover debt, prevent fraud and to manage your investment;
● check your identity to prevent money laundering, unless you furnish us with other satisfactory proof of identity; or
● check details of job applicants and employees.
We only share this information with the Company´s officers, employees, and third-party contractors. When we use or share information from or with third-parties, we will respect any permissions that you have set about how you would like your information to be used. Most internet browsers allow you to stop receiving cookies via options/settings. You may enable these options/settings. However, this will mean that our system may not recognise your computer when you log in and so you may not be able to use or access certain parts of the Website. For information about cookies generally, please visit www.allaboutcookies.org.
Links to Other Websites
We recommend that you check the policy of each website that you visit and contact the owner or operator of that website if you have any concerns.
Updates to your Personal Information
Please let us know if there are any changes to your personal information as it is important that the information that we hold about you is accurate and up to date. You can ask us to update or correct your personal information by writing to us at the correspondence address below or by sending us an email to [email protected]
How Long we Store Information About you
We will keep your personal information for as long as it is considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your relationship with us has ended.
How to Find out What Information we Hold About you
You have the right to request a copy of the personal information we hold about you free of charge in a ‘Subject Access Request.’ To do this, you may write to us at the correspondence address below or by sending us an email to [email protected] Before providing any personal information to you that we hold about you we will take all reasonable steps to confirm your identity. We do this to protect your personal information and to ensure that it is only sent to the person to whom the information relates.
Managing your Preferences
160 Gloucester Road, Overseas Trust Bank Building, 6/F, Room A13, Wanchai, Hong Kong
Disclaimer Date: March, 21 2020