Privacy Policy

Hong Kong Privacy Notice

This Privacy Notice is provided to you pursuant to the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “PDPO”) in connection with your dealings with, and provision of personal data or information to, AMINA (Hong Kong) Limited (“AMINA HK”) and/or its affiliates (collectively “AMINA”) from time to time. AMINA HK respects personal data privacy and is committed to complying with the requirements of the PDPO. In doing so, it strives to ensure compliance by its staff with the strictest standard of security and confidentiality.

Collection of Information

1. AMINA HK may collect personal data about you in connection with various matters such as account opening or continuation, provision of services to you or compliance with any laws, regulations and/or rules issued by regulatory or other authorities. AMINA HK may also receive personal data about you from third parties, such as your accountants, lawyers, financial consultants, and/or other service providers.

2. The broad categories of personal data that may be collected includes, but is not limited to, name and address, occupation, contact details, gender, date and country of birth, nationality, identity card, social security or national insurance numbers, country of tax residence, tax reference numbers or passport numbers, health information and details of financial status.

3. A failure to provide the requested personal data, or the provision of inaccurate or incomplete information may result in AMINA HK not being able to (a) process your request, application, submission, enquiry, complaint or matter (as the case may be); (b) comply with any laws, regulations and/or rules issued by regulatory or other authorities; and/or (c) provide you with the services or information requested.

4. Personal data may also be collected from you in the ordinary course of the continuation of your relationship with AMINA HK. For example, when you open an account, effect transactions, attend seminar/events, participate in online activities or generally communicate verbally or in writing with AMINA HK. Additional personal data may also be collected at AMINA’s website. When you visit AMINA’s website, a record of your visit is made as a “hit”, which may show your Internet Protocol (IP) address and the pages you have visited. Such information may be used for statistical purposes, and for the purposes of maintaining and improving the website. When you browse any website, you should be aware that cookies are used. Cookies are small pieces of software that are issued to your computer or device and that store and sometimes track information about your use of the site. The types of cookies used on AMINA’s website includes session cookies and persistent cookies. The purpose of using cookies is to help AMINA improve website performance and user’s experience. The cookies used in connection with AMINA’s website does not collect or store personally identifiable information. You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software. However, if you do so, you may not be able to utilise or activate certain functions available on the AMINA website.

Purpose and Use

5. The purposes for which personal data may be used will vary depending on the nature of your relationship with AMINA HK. AMINA HK intends to use your personal data (including any third party personal data provided by you) for any or all of the following purposes:

a) Onboarding

• to verify your identity and process your application in accordance with all applicable legal and regulatory compliance checks.

b) Relationship management

• to operate your account and provide the necessary services to you;
• to manage your relationship, including communicating with you on products and services offered by AMINA HK and its business partners; and
• to handle customer service-related queries and complaints and the general maintenance of your account.

c) Product implementation and execution

• to provide products and services to you and ensuring proper execution;
• to research, design and launch financial, investment services or related products for you;
• to provide financial planning and investment, wealth management and related services and products; and
• to take steps to improve products and services with the use of technology.

d) Marketing

• to engage in prospecting and business development;
• to evaluate whether and how AMINA HK may offer products, services and events – including those offered by AMINA HK and/ or its business partners;
• to contact you for direct marketing purposes about products and services that will be of interest to you, including those offered by AMINA HK and/or its business partners, subject to your right to object; and
• to analyse the results of any marketing activities to measure the effectiveness and relevance of the campaigns.

e) Compliance and risk management

• to meet on-going regulatory and compliance obligations including the recording and monitoring of communication;
• to apply a risk classification to ongoing business relationships;
• to make disclosures to tax authorities, financial service regulators and other regulatory, judicial and governmental bodies or in proceedings and/or investigations;
• to receive and handle complaints, requests or reports; and
• to reply to any actual or potential proceedings, requests or the inquiries of a public or judicial authority.

f) Other purposes

• to enable a transfer, merger or disposal to a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer, merger or disposal of part or all of AMINA HK’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
• to collect data to ensure the security of the office premises (e.g., maintaining office access logs and CCTV system images);
• to assess and review personnel records for recruitment and human resources management purposes; and
• any other purpose directly related to any of (a) – (f) above.

6. You have the right to object to the use of your personal data for direct marketing purposes as set out above. AMINA HK will cease to use your personal data for direct marketing purposes without charge if you so request.
Direct Marketing

7. AMINA HK intends to use the personal data collected for direct marketing but may not use the personal data unless your consent (which includes an indication of no objection to the intended use) has been received.

8. AMINA HK also intends to provide the personal data collected to all or any of the transferees of a whole or any substantial part of the business of any AMINA entity (the “Transferees”), service providers and related third parties (including consultants) (collectively, the “Parties”) for use by them in direct marketing. However, the personal data may not be so provided unless your consent (which includes an indication of no objection to the intended provision) has been received.

9. AMINA HK would like to use the personal data collected, including but not limited to your name and contact details (such as telephone number, email address and/or correspondence address), or provide the same to all or any of the Parties for the Parties’ use, for the following direct marketing purposes through various communication means such as direct-mail, email, telephone, SMS and brochures:

(a) financial planning and investment, wealth management and related services and products, financial, investment and
educational seminars and forums or other financial services and products; and

(b) new product and service launch and other promotional offers.

Retention and Access

10. Different retention periods apply to the various kinds of personal data collected and held by AMINA HK. We take all reasonably practicable steps to ensure that personal data will not be kept longer than is necessary for the fulfilment of the purposes (or any directly related purpose) for which the personal data is or is to be used, unless the retention is otherwise permitted or required by law.

11. Personal data held by AMINA relating to you will be kept confidential and AMINA will take all reasonable measures to ensure that personal data is kept secure against unauthorised access, loss, disclosure and destruction. AMINA HK may provide such information to the following parties, whether inside or outside of Hong Kong, for the purposes set out in the “Purpose and Use” and “Direct Marketing” sections above:

(a) the ultimate holding company of AMINA HK, its subsidiaries, associated companies and/or affiliates;

(b) the service providers of AMINA HK including investment managers, transfer/paying agents, custodians, banks, administrative service agents, auditors, lawyers and accountants etc;

(c) any agent, contractor, subcontractor, consultant, insurer, or third party service provider who provides administrative, research, design, launch, digital or telecommunication, clearing and settlement or other services to AMINA HK in connection with the operation of its business;

(d) the employees, officers, directors of AMINA HK;

(e) any party (including but not limited to, any local or foreign governmental, tax or regulatory authorities, or court of competent jurisdiction) entitled thereto by law or regulation, or in response to a regulatory request;

(f) affiliated or unaffiliated providers of outsourced or other services, and other external service providers of AMINA HK (including but not limited to printing houses, mailing houses, digital or telecommunication companies, information technology companies, data storage and infrastructure companies, cloud providers, data processing companies and storage companies) that AMINA HK engages for the purposes set out in the “Purpose and Use” section above; and

(g) any actual or proposed assignee(s) and/or transferee(s) of AMINA HK and/or its rights or obligations with respect to you.

12. AMINA HK’s policy is to restrict access to personal data concerning individuals to those persons who have a need to use that personal data and who have been instructed to handle such information properly and observe confidentiality.

13. Please note that the personal data transferred outside of Hong Kong may be subject a lower level of protection and/or cease to be protected by any relevant banking secrecy, client confidentiality or data protection laws of Hong Kong.

14. Under and in accordance with the terms of the PDPO, you have the right to:

(a) check whether AMINA HK holds personal data about you and to access such personal data;

(b) require AMINA HK to correct any data relating to you which is inaccurate;

(c) ascertain the AMINA HK’s policies and practices in relation to personal data and to be informed of the kinds of personal data held by AMINA HK; and

(d) object to the use of your personal data for direct marketing purposes and AMINA HK shall not use your personal data for direct marketing purposes after you communicate your objection to AMINA HK.

15. In accordance with the terms of the PDPO, AMINA HK has the right to charge a reasonable fee for the processing of any personal data access request.