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Privacy Policy

Notice to Clients relating to the “Hong Kong” Personal Data (Privacy) Ordinance (the “Ordinance”)

Reasons for the collection of personal data

From time to time, it is necessary for clients to supply Funderstone Securities Holdings Limited or its subsidiary companies (“Funderstone Group”) with data in connection with the opening or continuation of accounts and the establishment or continuation of margin facilities or provision of stock broking services.

Failure to supply such data may result in Funderstone Group being unable to open or continue accounts or establish or continue margin facilities or provide stock broking services.

It is also the case that data are collected from clients in the ordinary course of the continuation of servicing the relationship, for example, when clients withdraw cheques or physical share certificate.


The purposes for which data relating to a client may be used are as follows:-

• the daily operation of the services and margin facilities provided to clients;

• conducting credit checks;

• assisting other financial institutions to conduct credit checks and collect debts;

• ensuring ongoing credit worthiness of clients;

• marketing financial services or related products; and

• meeting the requirements to make disclosure under the requirements of any law or regulation binding on Funderstone Group.

Transfer of personal data

Data held by Funderstone Group relating to a client will be kept confidential but Funderstone Group may provide such information to the following parties for the purposes set out in above paragraph:-

• any agent, or third party service provider who provides securities clearing or other services to Funderstone Group in connection with the operation of its business;

• any other person under a duty of confidentiality to Funderstone Group including a group company of Funderstone Group which has undertaken to keep such information confidential;

• credit reference agencies, and, in the event of default,to debt collection agencies; and

• any person to whom Funderstone Group is under an obligation to make disclosure under the requirements of any law or regulation binding on Funderstone Group.

Access and correction of personal data

Under and in accordance with the terms of the Ordinance any individual has the right:- –

• to check whether Funderstone Group holds data about him and of access to such data; –

• to require Funderstone Group to correct any data relating to him which is inaccurate; –

• to ascertain Funderstone Group’s policies and practices in relation to data and to be informed of the kind of personal data held by Funderstone Group; –

• in relation to client credit, to request to be informed which items of data are routinely disclosed to credit reference agencies or debt collection agencies, and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency.

In accordance with the terms of the Ordinance, Funderstone Group 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 Funderstone Securities Holdings Limited Room 1802, Capital Centre, No. 151 Gloucester Road, Wanchai, Hong Kong Fax: 2845-2119 Nothing in this Notice shall limit the rights of client under the Personal Data (Privacy) Ordinance.