• From time to time, it may be necessary for clients to supply Anuenue Securities Limited and/or any subsidiary or affiliated company or member within the same group (collectively "ASL") with data in connection with the opening or continuation of accounts and the establishment or continuation of financing facilities or provision of stock broking, custodial and nominee services. At the same time, some of the data are collected pursuant to laws, regulations, rules or codes binding on ASL or any Group Party.  


• The provision of your personal data to us is voluntary. However if you do not provide us with the personal data it may result in ASL being unable to open or continue accounts or establish or continue financing facilities or provide stock broking, custodial or nominee services.


• It is also the case that data are collected from clients in the ordinary course of the continuation of the trading relationship, for example, when clients withdraw or deposit securities.  


• The purposes for which data relating to a client may be used are as follows:
  • the daily operation of the services and credit facilities provided to clients;
  • conducting or assisting other financial institutions to conduct credit checks;
  • ensuring ongoing credit worthiness of clients;
  • designing financial services or related products;
  • collection of amounts outstanding from clients;
  • meeting the requirements to make disclosure under the requirements of any laws, regulations, rules or codes binding on ASL or any Group Party;
  • the promotion of the business activities of ASL or any Group Party; and
  • purposes relating thereto.


• Data held by ASL relating to a client will be kept confidential but ASL may provide such information to the following parties within or outside Hong Kong to the extent permitted by law:
  • any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or securities clearing or other services to ASL in connection with the operation of its business;
  • any Group Party;
  • any other person under a duty of confidentiality to ASL including any Group Party which has undertaken to keep such information confidential;
  • any financial institution with which the client has or proposes to have dealings;
  • any actual or proposed assignee of all or part of the business of ASL or participant or sub-participant or transferee of ASL's rights in respect of the client, or in the case of merger, acquisition or other public offering, the actual or proposed purchaser or subscriber for shares of ASL;
  • any other person to whom we are compelled to make disclosure under the requirements of any laws binding on ASL or any Group Party;
  • any person with the client's express or implied consent;
  • any person in the event that ASL's interests require disclosure.
• Use of data in direct marketing: ASL also intends to use your data including your name and contact details for sending you promotional materials and conducting direct marketing activities in relation to ASL’s financial products/services where appropriate. ASL may not use your personal data for such purpose unless we have received your consent to the intended use of data. By providing your personal data to ASL, you do not object to the use of your personal data by ASL in direct marketing as described in this section. If you prefer that we do not use your data in direct marketing, please notify us in writing or, alternatively, if you agree to our intended use of your personal data in direct marketing and then later decide that you would like to withdraw your consent to such intended use, please notify us in writing at the mail address set out below.


• Provision of data for use in direct marketing: ASL intends to provide your data including your name and contact details to Group Parties for sending you promotional materials and conducting direct marketing activities in relation to the financial products/services offered by Group Parties. However, ASL may not provide your personal data unless we have received your written consent to the intended provision of data. By providing your personal information to us and signing the Securities Trading Agreement, you do not object to the provision of your personal data for direct marketing to Group Parties. If you prefer that we do not provide your data to Group Parties for use in direct marketing, please notify us in writing or, alternatively, if you agree to our intended provision of your personal data and then later decide that you would like to withdraw your consent to such intended provision, please notify us in writing at the mail address set out below.


• In the course of performing our duties, ASL may, as permitted by law, match, compare, transfer or exchange any personal data provided by the client, or hereafter obtained, for these or any other purposes by ASL, with data held by government bodies, other regulatory authorities, stock exchanges, corporations, organisations or individuals in Hong Kong or overseas for the purpose of verifying those data.


• Under and in accordance with the terms of the Ordinance any individual:
  • has the right to check whether ASL holds data about him and the right to access such data;
  • has the right to require ASL to correct any data relating to him which is inaccurate;
  • has the right to ascertain ASL’s policies and practices in relation to data and to be informed of the kind of personal data held by ASL.


• In accordance with the terms of the Ordinance, ASL has the right to charge for costs directly related to and necessary for the processing of any data access request.


• When you use ASL Platforms, ASL collects general information about your visits by means of "Cookies" files and similar methodology. You are not allowed to disable this function. The information is only used for analyzing your preference in relation to the services we provide and will not be provided to any third parties.


• Once ASL has obtained your personal data, they will be encrypted and maintained securely in our system. Only authorized staff of ASL, who have been properly trained, will be permitted to access to those personal data. ASL will also ensure compliance by our staff with the strictest standards of security and confidentiality. ASL uses digital certificates to implement SSL (Secure Sockets Layer) protection. SSL encrypts your transaction data and information so they are unreadable in transit over the internet to guard against eavesdropping and unauthorized access.


• 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:
  
  Anuenue Securities Limited
  28/F, 18 Pennington Street
  Causeway Bay
  Hong Kong


• This policy is subject to change from time to time and any change will be posted on our website at www.anuesec.com

August 2018