Pursuant to the Personal Data (Privacy) Ordinance (the “Ordinance”), the following information is provided to you in connection with your dealings with and provision of data or information to Triada Capital Limited or its holding company, subsidiaries and affiliates from time to time (“Triada”). Please be aware that this Personal Information Collection Statement (the “Statement”) replaces any notice or statement of similar nature that may have been provided to you previously. Triada is committed to maintaining your personal data in accordance with the requirements of the Ordinance and will take all reasonable steps to ensure that your personal data is kept secure against unauthorised access, loss, disclosure and destruction.
(a) From time to time, it is necessary for clients and various other individuals (“data subjects”) to supply Triada with data in connection with various matters, and it is generally not obligatory for a data subject to provide personal data to Triada.
(b) Although provision of personal data is not obligatory, failure to supply such data may result in Triada being unable to continue services to clients and various other individuals or comply with any laws or guidelines issued by regulatory or other authorities.
(c) Data relating to the data subjects are collected or received by Triada from time to time in the ordinary course of Triada’ relationship with them, for example, when data subjects attend seminar/events or generally communicate verbally or in writing by data subjects with Triada.
(d) The purposes for which data relating to a data subject may be used will vary depending on the nature of the data subject’s relationship with Triada. They may comprise any or all of the following purposes: (i) the processing of applications for an account with and/or other financial services provided by Triada; (ii) enabling Triada to ensure the daily operation of the services provided to the data subjects; (iii) researching, designing and launching financial, investment, securities services or related products for data subjects’ use; (iv) promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in paragraphs (e) & (k) below); (v) providing alerts, newsletter and investment education materials requested/signed up by the data subjects; (vi) meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to Triada or any of its affiliates in Hong Kong or elsewhere from time to time; (vii) complying with any law binding or applying to Triada within or outside of Hong Kong; (viii) any purpose related to the administration of the products offered by Triada or the data subject’s participation therein; and (ix) purposes directly related or incidental to the above, including seeking professional advices.
(e) Use of Data in Direct Marketing: Triada intends to use the data subject’s data in direct marketing and Triada requires the data subject’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that: (i) the name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of the data subject held by Triada from time to time may be used by Triada in direct marketing; (ii) the following classes of services, products and subjects may be marketed in direct marketing: (1) financial, investment, securities and related services and products; (2) reward, loyalty or privileges programmes, promotional offers and related services; and (3) invitations to financial and investment seminars/events/forums.
(f) Data collected may be maintained for such period as may be required under applicable laws or as otherwise needed to fulfil any of the purposes set out in paragraph (d) above.
(g) Data held by Triada relating to a data subject will be kept confidential but Triada may provide such information to the following parties whether inside or outside Hong Kong for the purposes set out in paragraph (d): (i) Triada’ group companies; (ii) the service providers of Triada including the registrar, transfer agent, the custodian, administrative service agent, distributors, securities and investment service providers and the auditor of each products offered by Triada; (iii) any agent, contractor or third party service provider who provides administrative, research, design, launch, telecommunications, printing, letter shopping, mailing, computer, payment, securities clearing and settlement or other services to Triada in connection with the operation of its business; (iv) the intermediaries of Triada including third party financial institutions (e.g. banks, independent financial advisors, insurers), third party product issuers, correspondent banks which may handle or process payment to/from data subjects; (v) the employees, officers, directors and agents of Triada; (vi) any other party (including but not limited to, any regulatory authorities, governmental authorities, tax, law enforcement authorities) entitled thereto by law or regulation.
(h) Under the Ordinance, any individual has the right: (i) to check whether Triada holds data about him or her, and of access to such data; (ii) to require Triada to correct any data relating to him or her which is inaccurate; (iii) to ascertain Triada’ policies and practices in relation to data and to be informed of the kind of personal data held by Triada; and (iv) to object to the use of his/her personal data for marketing purposes and Triada shall not use his/her personal data for marketing purposes after he/she communicates his/her objection to Triada.
(i) In accordance with the terms of the Ordinance, Triada has the right to charge a reasonable fee for the processing of any data access request.
(j) Nothing in this Statement shall limit the rights of the data subject under the Ordinance.
(k) You may exercise your opt-out right by notifying Triada if you wish to object to the use of your personal data for direct marketing purposes. The person to whom such objections, requests for access to data, correction of data or for information regarding policies and practices and kinds of data held are to be addressed as follows:
Data Protection Officer
Triada Capital Limited
Unit 29-30, 43/F, Champion Tower
3 Garden Road, Central, Hong Kong