Notice of Use, Collection and Disclosure of Personal Data (the “Notice”) for Annual Flagship Investors’ Forum 2020 (the “Event”)
1. Our Commitment
We, CLSA Limited (”CITIC CLSA”), believe in protecting your privacy. We ask that you read this Notice and the Personal Data Protection Laws Annex and Circular Relating to the Personal Data (Privacy) Ordinance of Hong Kong as set out on our website at https://www.clsa.com/terms-of-business/ (as amended and /or supplemented from time to time) (collectively, “Data Policies”) carefully as they contain 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, you may not be able to attend or participate in the Event.
By submission of the registration form for the Event, you are deemed to have confirmed that you have read and understood the Data Protection Policies and this Notice, and you are deemed to acknowledge and consent to us collecting, using or disclosing your personal data for the purpose listed hereof and to the provisions hereof.
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 provided by you in the registration form for the Event. 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 during the Event, including but not limited to any photographs, videos or other recordings of you.
3. Purpose for Collection and Use of Personal Data
Generally, personal data is collected and used by us or members of CSI Group for the following purposes:
- processing your applications for the Event;
- planning and organizing the Event, and any other related purposes;
- responding to your enquiries;
- providing services and products to you or your employer from time to time;
- managing the relationship between us and / or administration of your account or the account of your employer;
- conducting identity and/or credit checks;
- assisting other financial institutions to conduct credit checks and other members of the Group (as defined below);
- internal audit and planning;
- in connection with any system or facility for payment by electronic means or via other communication media in which CITIC CLSA participates;
- in connection with any verification or exchange of information;
- developing new services and/or products;
- providing you with marketing, advertising and promotional information, materials and/or documents relating to our products and/or services (please see Section 7 of this Notice on use and transfer of personal data for marketing purposes);
- 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;
- updating you on our products and services from time to time;
- processing any applications or requests for new services and / or products made by you;
- 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 you may from time to time agree.
“CSI Group” or “Group” means CITIC Securities International Company Limited and its subsidiaries and Affiliates. For this purpose, “Affiliate” means CITIC Securities Co., Limited and a person that is directly or indirectly controlled by CITIC Securities International Company Limited and/or is under common control with CITIC Securities International Company Limited.
4. Disclosure of Personal Data
We may disclose your personal data to other companies of the CSI Group, business partners, third party service providers (including those providing administrative, telecommunications, computer, financial intermediary, payment or securities clearing or other services to CITIC 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 CITIC CLSA or participant or sub-participant or transferee of CITIC 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, auditors and agents for the purposes stated above or auditing purpose or for any investigation, administrative or legal proceeding and to legal, regulatory, governmental, tax, law enforcement or other authorities (which may be located within or outside Hong Kong) or exchanges or as required by laws and regulations.
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
To the extent that we may need to transfer personal data outside of Hong Kong, whether to the parties set out in Section 4 or simply to data storage facilities, we shall do so in accordance with the Personal Data Privacy Ordinance (“PDPO”).
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 also use your name, email address, address or phone number to send you marketing, advertising and promotional materials about investment, credit and/or financial products and/or services of CITIC CLSA and/ or of any other companies belonging to the CSI Group. We may share your personal data with any other companies within the CSI Group or our business partners who provide the same products and services for direct marketing purposes. Your consent is required before we do so.
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.
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.
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 Data Policies
If we have any change on the Data Policies, we will post the changes on our website. Such changes to the Data Policies shall apply from the time that we post the same on our website. We will seek your fresh consent if we wish to use or disclose your personal data for new purposes.
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14. Governing Law
As we are a Hong Kong registered company, this Notice has been prepared solely in accordance with the requirements of the relevant laws of Hong Kong. We do not represent or warrant that this Notice complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Notice as such.
15. Contact Us
If you have any comments or questions about this Notice, please contact us in writing at the address below:
Data Protection Officer/Chief Operating Officer
18/F One Pacific Place
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.