Privacy Policy and Personal Information Collection Statement
Last Update: 14 November, 2011
This Statement is, except where separate and distinctive statements are provided, applicable to the AMTD Asia Limited's group of companies and the AMTD Group Company Limited's group of companies (together hereinafter the "Group"), including but not limited to AMTD Financial Planning Limited, AMTD Direct Limited, AMTD Strategic Capital Limited, AMTD Risk Management Limited, AMTD Securities Limited, AMTD Asset Management Limited and AMTD China (Holdings) Limited. Accordingly, references to "we", "us", or "our company" shall mean, as the case may be, the relevant company within the Group. This Statement is applicable to all our websites, including but not limited to our websites at www.amtd.com.hk , www.amtdclub.com.hk , www.amtdbuylabuy.com , www.amtdchina.com.cn and www.amtdclub.com.cn .
Please note that this Statement may be amended from time to time without prior notice. You are advised to check it on a regular basis.
I. Privacy Policy Statement
Our pledge
We are committed to safeguarding the privacy of individuals with respect to your personal data. We will make sure that our policies and practices, and those adopted by our affiliated companies and agents in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486) ("Ordinance") under the laws of Hong Kong. The meaning of the term "personal data" adopted in this Statement is defined in the Ordinance.
Where our operations are subject to privacy legislation other than that of Hong Kong (such as due to our carrying out of operational functions outside of Hong Kong), this Statement shall apply so far as it is consistent with such local legislation.
At times, you may be required to give your personal data and/or survey data including, but not limited to, your name, gender, age, identity document number and/or its copy, telephone number, fax number, home address and/or its proof, email address, credit card information, bank account number. Whilst some of the above requested data are optional (and the furnishing of which are subject to your voluntary choice), the refusal to provide certain requested data may render us unable to handle any application or request you are making, or render any services and/or products to you, or may deny you of access to certain parts of our websites, or may otherwise defeat the objectives of your visit. If you are under the age of 18, consent from your parent or guardian is required before you give us any personal data and/or survey data.
When you provide us your personal data and/or survey data, they would be deemed to be correct, complete and not misleading. We shall not be liable for any losses or damages in relation to or arising from the incorrectness or incompleteness of the personal data and/or survey data produced by you to us from time to time.
Information relating to your use , purchase or order of our services and/or products, such as call/connection time, duration, origin and destination, may be automatically collected for our accurate reporting and administration of your accounts.
Some of our websites may disclose non-personally identifiable aggregate statistics relating to our visitors to advertisers. Some of our websites may collect aggregate information about our visitors, e.g. statistics on the number of visits. This type of data may include, but is not limited to, the browser type and version, operating system, IP address and/or domain name.
Cookies used (if any) in any part of our websites will not be deployed for collecting personal data. For your information, Cookies are small computer files that can be stored in web surfers' computers for the purposes of obtaining configuration information and analyzing web surfers' viewing habits. They can save you from registering again when re-visiting a website and are commonly used to track your preferences in relation to the subject matter of the website. You may refuse to accept Cookies by modifying the relevant Internet options or browsing preferences of your computer system, but to do so you may not be able to utilize or activate certain available functions in our websites. Our websites may bar users who do not accept Cookies.
Calls between you and our Customer Service may be recorded for, including but not limited to, regulatory compliance, audit compliance, training, quality control and contractual purposes.
Your application for the use, purchase or order of any of our services and/or products may be subject to, including but not limited to, credit assessments, verification of your personal details and etc.. If we regard these checks as unsatisfactory, we will not enter into any agreements, arrangements or engagements with you. In some instances, data provided by you will be validated by using generally accepted practice or against our pre-existing data, or we may require to see original documentation before the data may be used, such as personal identifiers and/or proof of address.
Specific purposes for which your personal data may be used are set out in our "Personal Information Collection Statement" set out in Part II below (particularly those contained in points (i) through to (viii) in the first paragraph of Part II below).
If you have once given us your personal data, you may receive from us, our affiliated companies, agents or business partners from time to time direct marketing telephone calls, emails, SMS, direct mailings or other means, the same of which contain promotional materials. If you do not want us to use your personal data for direct marketing purposes, please write to our Data Protection Officer (whose address is set out at the bottom of this page) or click here, download our "Marketing Message Opt-out Request Form", fill that in and send it to Data Protection Officer (whose address is set out at the bottom of this page).
If you want to access to and/or correct your personal data which you have given us via application form, Internet or other means, you may write to our Data Protection Officer (whose address is set out at the bottom of this page). We will comply with the request within 40 days after receiving the request. We may charge you a reasonable fee for each successful access. However, such fee will be waived if the access is necessary to make a genuine and reasonable correction.
We use various encryption techniques to transmit via the Internet your personal data, which can only be accessed by our authorised personnel. Given the nature of the Internet, we cannot guarantee that the transmission is 100% secure. Please, however, refer to our "Security Statement" in Part III below for details on the steps that we have taken to ensure that any personal data collected by us via our websites is safe and secure from third party's unauthorised interference.
Physical records containing personal data are securely stored in locked areas when not in use. Access to physical and/or computer data is strictly controlled and requires appropriate management authorisation. Authorisations are granted only on a "need to know" basis. Where we hold, use and/or transmit customers' personal data, we will put in place adequate measures to protect it from accidental and/or unauthorised disclosure, change and/or destruction.
If you are our customer, your personal data which you have given us via application form, Internet or other means, during the subscription period will be retained for a reasonable period after termination of your subscription. We will purge unnecessary personal data from our system in accordance with our internal procedures.
| Internal guidelines on access to personal data |
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All of our staff will adhere to our internal Guidelines on Access to Personal Data drawn up to restrict access to personal data to only the members of staff who have legitimate needs to have such access.
We may have on-line stores, service providers and/ or product providers hosted in our websites which are operated by third party service providers, product providers and/or merchants. Alternatively, through us, you may also be introduced to third party service providers, product providers and/or merchants whether or not you are on-line. If you want to use, purchase or order any services and/or products from any of them, please note that any information you provide, once transferred to the relevant third party service providers, product providers and/or merchant, is beyond our control and thus outside the scope of protection afforded by us.
| This Statement only addresses the use and disclosure of information we collect directly from you. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you to review such website's privacy policy. We are not responsible for the policies or practices of third parties. |
| II. Personal Information Collection Statement
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As a customer of our company, or a visitor or user of our websites, it may be necessary for you to provide us with your personal data when you apply to us and/or continue to subscribe with us for a service and/or product. If your personal data is incomplete or incorrect, we may not be able to provide or continue to provide the services and/or products to you. We shall keep your personal data confidential at all times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal data will be in accordance with the Ordinance and are as set out in this Statement. Your personal data provided by you to us may be used and retained by us for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time:
- processing of your application for the use, purchase or order of any services and/or products, and provisioning of the services and/or products;
- marketing of services and/or products by (a) the Group and/or the Cheung Kong (Holdings) Limited's group of companies and the Hutchison Whampoa Limited's group of companies (together hereinafter the “Cheung Kong Hutchison Group”); (b) affiliated companies, agents and business partners of the Group and the Cheung Kong Hutchison Group (such as other financial institutions, mortgage referral service providers, credit card companies, insurance and reinsurance companies, banks, property development service providers, property and hotel service providers, retailers, securities and investment service providers, telecommunications service providers, third party reward, loyalty and privileges program providers and co-branding partners); and (c) our affiliated vendors (ie. vendors which provide services and/or products jointly with us) and merchants who offer services and/or products through our websites (including, but not limited to, our amtdBuylaBuy website) in relation to provision of services and/or products and their related services and/or products, or in respect of the latest offer or promotion of their services and/or products;
- processing of any benefits which may arise to you out of or in connection with the services and/or products;
- analyzing, verifying and/or checking of your credit, payment and/or account status in relation to the provision of the services and/or products;
- processing of any payment instructions, direct debit facilities and/or credit facilities requested by you;
- enabling the daily operation of your account, provisioning of customer services and/or the collection of amounts outstanding in your account in relation to the services and/or products;
- enabling us to comply with any obligations to interconnect or other industry practices, or to comply with obligations to or requests from government agencies or regulatory authorities; and
- enabling us in prevention of crime.
We may disclose and transfer (whether in Hong Kong or abroad) your personal data to the following parties to use, disclose, hold, process or retain such personal data for the purposes mentioned above:
- our affiliated companies and affiliated companies of the Cheung Kong Hutchison Group;
- agents and contractors (such as IT, network, customer service, sales agents, mailing houses, telecommunication service providers, telemarketing and direct sales agents, call centers, data processing service providers, third party reward, loyalty and privileges program providers, co-branding partners and contractors), telecommunications operators, and service providers in provisioning our services and/or products;
- banks, financial institutions and credit providers;
- debt collection agencies, credit reference agencies and security agencies;
- regulatory bodies, law enforcement agencies and courts;
- our professional advisers, and any other persons under a duty of confidentiality to us; and
- any of our actual or proposed assignees or transferees of our rights with respect to you.
In addition, we may disclose and transfer your personal data (whether in Hong Kong or abroad) to any company within the Group and the Cheung Kong Hutchison Group, and in this context, including any of their subsidiaries and any company in which the same has a direct or indirect interest or with which it is in joint venture or co-operation or their respective successors and assigns for the purposes of carrying out of market research, credit assessments, marketing of services and/or products by us and/or the Cheung Kong Hutchison Group and for the performance of procedures for comparing personal data with other information supplied by you to us and/or the Cheung Kong Hutchison Group for such purposes and for other purposes as shall be agreed between you and us or required by law from time to time.
If you do not wish to receive marketing or promotional information from the Group and/or the Cheung Kong Hutchison Group with respect to services and/or products not related to or in connection with the services and/or products which you have used, purchased, and/or ordered from us, or for us to disclose, transfer or use your personal data for direct marketing purposes as set out in the above paragraph, please write to our Data Protection Officer (whose address is set out at the bottom of this page) or click here, download our "Marketing Message Opt-out Request Form", fill that in and send it to Data Protection Officer (whose address is set out at the bottom of this page).
Under and in accordance with the Ordinance, you have the right to:
- check whether we hold any of your personal data;
- access your personal data held by us;
- require us to correct any personal data which is inaccurate; and
- ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.
In accordance with the Ordinance, we have the right to charge a reasonable fee for the processing of any personal data access request. All requests for access to or correction of personal data or information regarding policies and practices and types of personal data held should be in writing and addressed to our Data Protection Officer (whose address is set out at the bottom of this page).
While the Internet is not an inherently secure environment for communications, Internet communications can be made safer by the application of appropriate technology as we have done (please see below). Internet security, however, is not solely a "technology" issue. Common sense and normal practice in safeguarding personal and transaction data are of equal importance. "Hackers" need a "door" to get into the system. Often, access through this "door" is provided to "hackers" due to simple carelessness in the physical distribution of sensitive documents and the handling of sensitive data, such as passwords or personal identification numbers. You must, therefore, handle such sensitive documents and data with extreme care.
We take security matters very seriously and treat all personal data obtained from users of our websites confidential. In addition to the firewalls and other sophisticated equipment implemented, we also provide and maintain necessary measures to protect our system, information and data contained in them from accidental or malicious disruption or destruction.
We will adhere to stringent security measures to ensure transaction integrity and protect confidential information. Such measures relate to, for instance:
- business and information privacy practices;
- transaction integrity; and
- information protection.
Should you have any enquiries concerning this Statement, please feel free to contact our Data Protection Officer. The contact details are as follows:
Data Protection Officer
AMTD Customers Service Department,
6/F, Hamption Loft, Hampton Place, 11 Hoi Fan Road, Tai Kok Tsui, Kowloon,
Hong Kong
Tel: (852) 3161 3688
E-mail :enquiry@amtd.com.hk
Note: In case of discrepancies between English and Chinese versions (where applicable), the English version shall apply and prevail.
Important : By accessing this website and any of its pages, you are agreeing to the terms set out above.
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