Wolver Hill Asset Management Asia Limited Personal Information Collection Statement Relating to the Hong Kong Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong).
Wolver Hill Asset Management Asia Limited (the “Company”) is committed to maintaining your personal data—that is, information relating to a living individual from whom it is practicable for the identity of the individual to be directly or indirectly ascertained- in accordance with the requirements of the Personal Data (Privacy) Ordinance and will take all reasonable steps to ensure that your personal data is kept secure against unauthorized access, loss, disclosure and destruction. Please be aware that this Statement replaces any notice or statement of similar nature issued by the Company previously, pursuant to the Personal Data (Privacy) Ordinance (the “Ordinance”).
Obligation to Disclose Personal Data
Unless otherwise stated, you must supply personal data requested by us in connection with the opening or continuation of accounts with us by you or by companies related to you, the provision of services or products by us, or the use of certain features of our website, such as the submission of applications for employment. Failure to supply such data may result in the Company being unable to open or maintain such account(s) or provide services or products to you or companies related to you or to process an employment application as we may not have sufficient information.
The purposes and retention of the information:
- From time to time, it is necessary for clients and various other individuals (“data subjects”) to supply the Company with data in connection with various matters such as account opening or continuations, or provision of services to clients and other individuals or compliance with any laws or guidelines issued by regulatory or other authorities.
- Such data may include, but not limited to, data collected from data subjects in the ordinary course of the continuation of the company’s relationship with them, for example, when clients open account, write cheques, transfer funds, effect transactions, attend seminar/events or generally communicate verbally or in writing with the Company.
- The purposes for which data relating to a data subject may be used will vary depending on the nature of data subject’s relationship with the Company. They may comprise any or all of the following purposes:
o The processing of application for an account with the Company;
o The daily operation of the services;
o Marketing financial services or related products
o Meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to the Company
o Evaluating the candidacy of applicants for employment, and, where an application is successful, all aspects of our human resources functions
- All personal data, whether provided by you or another person, and whether provided before or after the date you receive this statement, may be provided to, exchanged with or transferred to, in the following circumstances as we may consider necessary whether the recipients are inside of or external to Hong Kong.
o Third party disclosures may include sharing such information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to the Company.
o We may also disclose your personal information to fulfil your instruction or pursuant to your express consent.
o In the case of applicants for employment or current employees, we may provide applicants’ personal data to entities that provide services to us relating to human resources processes (which may include pre-employment or other background checking).
o Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations.
Use of Data in Direct Marketing:
- The Company intends to use the data subject’s data in direct marketing and the Company requires the data subject’s consent (which includes an indication of no objection) for that purpose. The specific requirement regarding data subject’s consent (which includes an indication of no objection) under Part VIA of the Personal Data (Privacy) Ordinance 2012 shall take effect from 1st April 2013.
- Pursuant to the Ordinance, direct marketing activities conducted by the Company may include but not limited to the following:
o offering, or advertising of the availability, of goods, facilities or services; or
o sending information or goods, addressed to specific persons by name, by mail, fax, electronic mail or other means of communication; or
o making telephone calls to specific person.
- In this connection, please note that: the name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of the data subject held by the Company from time to time may be used by the Company in direct marketing.
- In addition to marketing services, products the Company is allowed to provide, the Company also intends to provide the data collected from data subjects to third parties (as permitted by, or to comply with, applicable laws and regulations) for use by them in marketing those services, products and subjects, and the Company requires the data subject’s written consent (which includes an indication of no objection) for that purpose.
- If data subject does not wish the Company to use or provide to other persons his data for use in direct marketing as described above, the data subject may exercise his opt-out right by notifying the Company.
Under the Ordinance, any individual has the right:
- To check whether the Company holds data about him or her, and of access to such data;
- To require the Company to correct any data relating to him or her which is accurate
- To object to the use of his/her personal data for marketing purposes and the Company shall not use his/her personal data for marketing purposes after he/she communicates his/her objection to the Company.
The holder of the personal data may requests to access to data or correction data. Such a request to be addressed as follows:
The Compliance Officer
Wolver Hill Asset Management Asia Limited
15th Floor Onfem Tower
29 Wyndham St, Central, Hong Kong
Nothing in this statement shall limit the rights of any data subject under the Ordinance.