Our Privacy Principles

Sunfund Securities Limited, its subsidiaries and associates (collectively, hereinafter referred to as “Sunfund Group”, "we", "us" or "our") builds its business on trust between our customers and ourselves. To preserve the confidentiality of all personal data you provide to us, we maintain the following privacy principles:

• We only collect personal data that we believe to be relevant and required to understand your financial needs and to conduct our business.
• We use your personal data to provide you with better customer services and products.
• We may pass your personal data to other members of Sunfund Group or our respective agents, as permitted by law.
• We will not disclose your personal data to any external organisation unless we (i) have your consent or (ii) are required by law or (iii) have previously informed you.
• We may be required from time to time to disclose your personal data to governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority.
• We aim to keep your personal data on our records accurate and up-to-date.
• We maintain strict security systems designed to prevent unauthorised access to your personal data by anyone, including our staff.
• All members of Sunfund Group, all our staff and all third parties with permitted access to your personal data are specifically required to observe our confidentiality obligations.

By maintaining our commitment to these principles, we at Sunfund Group will ensure that we respect the inherent trust that you place in us.

Your Privacy Matters to Us

This section provides specific details of how we treat any personal data you provide us when you visit this website ("Site").

Data Security

• Security is our top priority. We will strive at all times to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
• Our web servers are protected behind "firewalls" and our systems are monitored to prevent any unauthorised access.
• We will not send personal data to you by ordinary email. As the security of ordinary email cannot be guaranteed, you should only send email to us using the secure email facility on this Site.

We will take all practical steps to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in the Hong Kong Special Administrative Region concerning the retention of personal data.

Security Assurance

• Both you and us play an important role in safeguarding against online fraud.
• We endeavour to put in place high standards of security to protect your interests.
• You should be careful that your account details (including your username and password) are not compromised. You should ensure that you do not knowingly or accidentally share, provide or facilitate unauthorised use of such details. Do not share your username or password or allow access or use of your username or password by others.
• You should safeguard your username and password and keep them secret and confidential. Never write them down. We will never ask you for your password given that you should be the only person who knows it.
• When choosing your username and password, do not use easily identifiable information such as your birthday, telephone number or a recognisable part of your name.
• If you think your username or password has been disclosed to another person, is lost or stolen or an unauthorised transaction has been conducted, you are responsible for informing us immediately.

Marketing Promotions

• Occasionally we may collect personal data from you when you visit this Site or when you participate in a contest or promotion (whether online, over the telephone or at one of our branches). We only collect personal data from you if you voluntarily provide it to us. We may use your personal data to inform you of products, services and other marketing materials which we think may be of interest to you. We may also invite you to participate in market research and surveys and other similar activities.
• You can choose to receive marketing and other promotional materials by email and you may opt out from receiving these materials at any time.
• If at any time you would like to stop receiving direct mailings from us, you should address your request to the Data Protection Officer at Sunfund Group. We will then, at no cost to you, act on your request within 30 days and ensure not to include you in future direct marketing promotions.
• If we do ask you to provide your personal data, we will always specify the purposes for which such personal data is collected and ensure that it is only used for the purposes specified at the time of collection.

*Notice Relating to the Personal Data (Privacy) Ordinance (the 'Ordinance')

This Statement is made by Sunfund Securities Limited (the “Company”) in accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region ('the Ordinance'). The Statement is intended to notify you why personal data is collected, how it will be used and to whom data access requests are to be addressed.

• From time to time, it is necessary for individuals to supply the Company with data in connection with the opening or continuation of accounts and the establishment or continuation of facilities or provision of in relation to securities trading or compliance with any laws, guidelines or requests issued by regulatory or other authorities.
• Failure to supply such data may result in the Company being unable to open or continue accounts or establish or continue margin facilities or provide services in relation securities trading.
• It is also the case that data are collected from (i) customers in the ordinary course of the continuation of the clients relationship, (ii) a person acting on behalf of the individual whose data are provided, and (iii) other sources (for example, information obtained from credit reference agencies). Data may also be generated or combined with other information available to the Company or any member of Sunfund Group ("Sunfund Group" means Sunfund (Hong Kong) Company Limited, its affiliates, subsidiaries, associated entities and any of their branches and offices (together or individually) and "member of Sunfund Group" has the same meaning).
• The purposes for which data may be used are as follows:
  • considering applications for products and services and the daily operation of products, services and margin facilities provided to customers;
  • conducting credit checks (including without limitation upon an application for margin facilities and upon periodic or special reviews of the credit which normally will take place one or more times each year);
  • creating and maintaining The Company's credit and risk related models;
  • assisting other financial institutions to conduct credit checks and collect debts;
  • ensuring ongoing credit worthiness of customers;
  • designing financial services or related products for customers' use;
  • marketing services, products and other subjects as described in (f) below;
  • determining the amount of indebtedness owed by customers;
  • collecting of amounts outstanding from customers and those providing security for customers' obligations;
  • meeting obligations, requirements or arrangements, whether compulsory or voluntary, of the Company or any of its branches or any member of Sunfund Group to comply with, or in connection with:
    • any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside the Hong Kong Special Administrative Region ("Hong Kong") existing currently and in the future ("Laws") (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
    • any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future (e.g. guidelines, guidance or requests given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information) and any international guidance, internal policies or procedures;
    • any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents with jurisdiction over all or any part of Sunfund Group (together the "Authorities" and each an "Authority") that is assumed by, imposed on or applicable to the Company or any of its branches or any member of Sunfund Group; or
    • any agreement or treaty between Authorities;
  • complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within Sunfund Group and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
  • conducting any action to meet obligations of the Company or any member of Sunfund Group to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;
  • meeting any obligations of the Company or any member of Sunfund Group to comply with any demand or request from the Authorities;
  • enabling an actual or proposed assignee of the Company, or participant or sub-participant of the Company 's rights in respect of the customer to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation; and
  • purposes relating thereto.
• Data held by the Company or a member of Sunfund Group relating to an individual will be kept confidential but the Company or a member of Sunfund Group may provide such information to the following parties (whether within or outside Hong Kong) for the purposes set out in paragraph (d):
  • any agents, contractors, sub-contractors, service providers or associates of Sunfund Group (including their employees, directors, officers, agents, contractors, service providers, and professional advisers);
  • any third party service provider who provides administrative, telecommunications, computer, payment or securities clearing or other services to the Company in connection with the operation of its business (including their employees, directors and officers);
  • any Authorities;
  • any person under a duty of confidentiality to the Company including a member of Sunfund Group which has undertaken to keep such information confidential;
  • any persons acting on behalf of an individual whose data are provided, payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, swap or trade repositories, stock exchanges, companies in which the customer has an interest in securities (where such securities are held by the Company or any member of Sunfund Group) or a person making any payment into the customer's account;
  • credit reference agencies, and, in the event of default, to debt collection agencies;
  • any person to whom the Company or any of its branches or any member of Sunfund Group is under an obligation or required or expected to make disclosure for the purposes set out in, or in connection with, paragraph (d)(x), (d)(xi) or (d)(xii);
  • any actual or proposed assignee of the Company or participant or sub-participant or transferee of the Company's rights in respect of the customer; and
  • • any member of Sunfund Group;
    • third party financial institutions, insurers, securities and investment services providers;
    • third party reward, loyalty, co-branding and privileges programme providers;
    • charitable or non-profit making organisations; and
    • external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that the Company engages for the purposes set out in paragraph (d)(vii).

    Such information may be transferred to a place outside Hong Kong.

    Use of Data in Direct Marketing

    The Company intends to use a customer's data in direct marketing and the Company requires the customer's consent (which includes an indication of no objection) for that purpose. In this connection, please note that the name, contact details, products and other service portfolio information, transaction pattern and behavior, financial background and demographic data of a customer held by the Company from time to time may be used by the Company in direct marketing;

    If a customer does not wish the Company to use or provide to other persons his data for use in direct marketing as described above, the customer may exercise his opt-out right by notifying the Company.
• In accordance with the terms of the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
• The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed as follows:

  
  The Data Protection Officer
  Sunfund Securities Limited
  18th Floor, Hip Shing Hong Centre,
  No. 55 Des Voeux Road Central, Central, Hong Kong
  E-mail: info@sunfund.com.hk

• The Company may have obtained a credit report on the customer from a credit reference agency in considering any application for margin facility. In the event the customer wishes to access the credit report, the Company will advise the contact details of the relevant credit reference agency.
• Nothing in this Notice shall limit the rights of customers under the Ordinance.

Note: In case of discrepancies between the English and Chinese versions, the English version shall apply and prevail.
IMPORTANT: By accessing this web site and any of its pages you are agreeing to the terms set out above.
* You may be subject to an earlier version of this Notice (known as Notice to Customers relating to the Personal Data (Privacy) Ordinance) if you have not consented to subsequent changes to the earlier notice.