1. Our Commitment
We, CLSA Limited (“CLSA”) (Hong Kong Company Registration No. 156668), believe in protecting your privacy. For the purposes of this Policy, “Affiliates” means any legal entity that, at any time, is directly or indirectly: (i) controlling CLSA; (ii) controlled by CLSA; (iii) under common control with CLSA; or (iv) controlled by CITIC Securities International Company Limited (“CSI”), including CSI itself. “CLSA Group” means CLSA together with all Affiliates of CLSA.
We ask that you read this Personal Data Policy Statement (“Policy”) carefully as it contains important information about what to expect when we collect personal data about you and how we will use your personal data. Your provision of personal data is voluntary. However, if you do not provide us with your personal data, we may not be able to provide you with the services and products requested.
2. Types of Personal Data
Generally, we may collect personal data that is linked to an individual. For example, an individual’s name, address, phone number and email address. This is not an exhaustive list and we may collect other types of personal data from you.
Apart from personal data, we may collect other types of information which is not linked to an individual and which is anonymous. For example, the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our customer services.
3. Purpose for Collection and Use of Personal Data
a. account opening, account maintenance and operations relating to your account including closing your account;
b. providing services and products to you from time to time;
c. administration and/or managing the relationship between us and / or your account;
d. conducting identity and/or credit checks;
e. assisting other financial institutions to conduct credit checks and other members of the CLSA Group;
f. internal audit and planning;
g. determining the amount of indebtedness owned to or by customers;
h. collection of amounts outstanding from customers and those providing security for customers’ obligations
i. in connection with any system or facility for payment by electronic means or via other communication media in which CLSA participates;
j. in connection with any verification or exchange of information;
k. developing new services and/or products;
l. providing you with marketing, advertising and promotional information, materials and/or documents relating to our products and/or services (please see Section 7 for our policy on use and transfer of personal data for marketing purposes);
m. complying with any present or future requirements or commitment (whether statutory, contractual or otherwise) of any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside Hong Kong;
n. updating you on our products and services from time to time;
o. processing any applications or requests for new services and / or products made by you;
q. enforcing our legal and/or contractual rights against you; and
all other incidental and associated purposes relating to the above and any other purpose which a customer may from time to time agree.
4. Disclosure of Personal Data
We may disclose your personal data to other companies of the CLSA Group, business partners, third party service providers (including those providing administrative, telecommunications, computer, financial intermediary, payment or securities clearing or other services to CLSA in connection with the operation of its business), financial institutions with which you have or propose to have dealings, any actual or proposed assignee of CLSA or participant or sub-participant or transferee of CLSA’s rights in respect of the customer, any potential investor in or purchaser of any interest in any Group company or in its business in connection with any potential reorganisation, merger or disposal, credit reference agencies, debt collection agencies, charity or charitable organisation, our professional advisers and agents and legal, regulatory, governmental, tax, law enforcement or other authorities (which may be located within or outside Hong Kong) for the purposes stated above.
In addition, there are certain circumstances under applicable laws where we are permitted to collect, use and disclose your personal data without your consent. You may obtain more information by contacting us (see Section 15).
We will not sell, rent or otherwise disclose your personal data to any third party not referred to above without your consent except in the following circumstances:
- we may share non-personal, non-individual information in aggregate form with third parties for business purposes, for example, we may tell our business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.
- as permitted under the laws of Hong Kong.
5. Transfer Of Personal Data Overseas
As a global financial institution, our services are supported by certain entities within the CLSA Group. These entities process your data as necessary to operate effectively, efficiently, and securely in facilitating transactions and providing products and services to our clients. To the extent that we may need to transfer personal data outside of Hong Kong, whether to the parties set out in this Policy or simply to data storage facilities, we shall do so in accordance with the Personal Data Privacy Ordinance (“PDPO”).
From time to time, we may also send your personal data overseas whenever it is necessary for the performance of, but not limited to, providing products and services to you, fulfilling the client agreement, complying with legal requirements, or conducting direct marketing activities. Such transfers may involve sharing your data with CLSA Group and third-party subcontractors, agents, or service providers working for us that operate or store data outside your local jurisdiction. Where your information is sent overseas, it is likely to be in the following jurisdictions: China, Singapore, Thailand, Philippines, Indonesia, Malaysia, Japan, Korea, India, Australia, the Netherlands, the United Kingdom, and the United States.
The personal data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by individuals operating outside your local jurisdiction who work for CLSA Group or for our suppliers. This includes jurisdiction that may not have the same level of protection for personal data. At CLSA, we are committed to protecting your personal data and your privacy. Where your personal data is sent outside your local jurisdiction, we ensure that appropriate data handling, security measures, and legal safeguards are in place. We employ a range of measures to keep your information safe and secure, which may include encryption and other security measures. Our employees and any third parties who carry out work for us must comply with appropriate compliance standards, including the responsibility to protect any information and implement appropriate measures for its use and transfer.
6. Consent
In some circumstances and as required by applicable laws, we will seek your express consent when collecting your personal data. For example, we will seek your consent where there are new purposes for the use of your personal data or where we use and transfer your personal data for direct marketing purposes (see Section 7).
In addition, you are able to withdraw your consent at any time by contacting us (see Section 15).
7. Use and Transfer of Personal Data in Direct Marketing
We may, from time to time, and with your consent as required by applicable law, use the personal data provided by you for direct marketing purposes. In this regard, please note that:
- Your personal data, including your name, contact details (such as email addresses and phone numbers), product and service preferences, transaction history, financial background, and demographic data, may be used by CLSA and shared with its Affiliates, or with third-party subcontractors, agents, or service providers who work for us, whether located locally or overseas, for the purposes of direct marketing.
- The types of services, products, and subjects that may be marketed to you, whether currently available or developed in the future by CLSA or its Affiliates, include:
- • News, updates, offers, and promotional information;
- • Investment, financial, insurance products or services;
- • Reward, loyalty, or privilege programs, along with related offerings; and
- • Products and services provided by our co-branding partners.
- The above services, products, and offers may be communicated or solicited through the following channels:
- • Email, telephone, mobile application, SMS and other electronic means
- • Either directly to you or through your representatives/contact persons, if you are a corporate entity.
8. Access And Correction
You are entitled to certain access and correction rights to your personal data under the PDPO. We may charge a reasonable administrative fee for this service. In exceptional circumstances, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.
9. Retention
Personal data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to conclude that the purpose for which that personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for legal or business purposes.
10. Accuracy
In order to ensure that your personal data is current, complete and accurate, please update us by contacting us (see Section 15).
11. Security Safeguards
We have put in place adequate security procedures and technical and organisational measures to safeguard your personal data. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.
12. Updates To The Privacy Policy
We keep our Policy under regular review. If we change our Policy, we will post the changes on our website. Such changes to our Policy shall apply from the time that we post the same on this website. We will seek your fresh consent if we wish to use or disclose your personal data for new purposes.
13. Cookies
A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier. If you wish to reject our cookie, you can configure your browser to do so. However, in a few cases some of our website features may not function if you remove cookies from your browser.
14. Governing Law
As we are a Hong Kong registered company, this Policy has been prepared solely in accordance with the requirements of the relevant laws of Hong Kong. We do not represent or warrant that this Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Policy as such.
15. Contact Us
If you wish to withdraw your consent for us to use your personal data for direct marketing or any of purposes outlined above at any time in the future, you must notify us formally of your decision to withdraw. Please note that in certain circumstances, withdrawal may prevent us from providing certain products or services to you. Your withdrawal will not retrospectively affect the lawfulness of our prior collection, use, or disclosure of your data based on your consent prior to withdrawal.
If you any have comments or questions about this Policy, please contact us in writing at the address below referencing ‘Personal Data Policy Statement:
Data Protection Officer/Chief Operating Officer
CLSA Limited
18/F One Pacific Place
88 Queensway
Hong Kong
Tel: 26008888
16. Disclaimer
Our website may contain links to other websites. Please note that we are not responsible for the privacy practices of such other websites and you are advised to read the privacy statement of each website you visit which may collect your personal data.