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Privacy Policy

FFC Financial Group Privacy Principles

Silver Fountain Trust HK Limited (“SFT”) as a member of the Fortune Financial Capital Financial Group ("FFC Financial Group" and “any "member of the FFC Financial Group" means Fortune Fountain Capital Limited and/or its affiliates, subsidiaries, associated entities and any of their branches and offices) adopts the FFC Financial Group Privacy Principles to build its business on trust between our customers and ourselves. To preserve the confidentiality of all personal data the Client provides to us, we adopt the FFC Financial Group Privacy Principles as follows:

1. We only collect personal data that we believe to be relevant and required to understand the financial needs of the Client and to conduct our business.

2. We will use Client’s personal data to provide the Client with better customer services and products.

3. We may pass Clients’ personal data to other members of the FFC Financial Group or our respective agents, as permitted by law.

4. We will not disclose our Clients’ personal data to any external organisation unless we (i) obtain the prior consent of the Client or (ii) are required by law or (iii) have previously informed the Client.

5. We may be required from time to time to disclose Clients’ personal data to governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority.

6. We aim to keep our Clients’ personal data on our records accurate and up-to-date.

7. We maintain strict security systems designed to prevent unauthorised access to our Clients’ personal data by anyone including our staff.

All members of the FFC Financial Group, all our staff and all third parties with permitted access to our Clients’ personal data are specifically required to observe our confidentiality obligations.
PERSONAL INFORMATION COLLECTION STATEMENT (the “Statement”)

Notice Relating to the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Privacy Ordinance”)

This Statement is made by SFT in accordance with the Privacy Ordinance and the FFC Financial Group Privacy Principles. The Statement is intended to notify you why personal data is collected, how it will be used and to whom data access requests are to be addressed.

1 As a Client of SFT, it is necessary from time to time for the Client or other individuals in connection with the purposes set out in this Data Privacy Policy to supply personal data of the Client (“Personal Data”), within the meaning ascribed in the Privacy Ordinance, to SFT or affiliates when opening or administering accounts, or in the establishment, continuation or provision of investment, dealing or related services.
2 Failure to supply Personal Data may result in SFT being unable to open or administer accounts or establish, continue or provide investment, dealing or related services.
3 Personal Data may also be (i) collected in the ordinary course of continuation of the business relationship with SFT and/or Affiliates; (ii) collected from you directly, from someone acting on your behalf or from another source; and (iii) combined with other data available to members of the FFC Financial Group.

4 Subject to the provisions of the Privacy Ordinance, you hereby consent to any Personal Data being used for any of the following purposes:

(a) considering and processing applications for products and services and the daily operation of the products and services provided to the Client;

(b) conducting credit checks;

(c) assisting other institutions to conduct credit checks and collect debts;

(d) maintain credit history of the Client for present and future reference;

(e) ensuring ongoing credit worthiness and good standing of the Client;

(f) designing investment, dealing, financial products and services (including insurance, securities, commodities, investment, tax consultants and related services or products) for the Client’s use;

(g) marketing investment, dealing or related services or products and other subjects as described in Clause (10) below to Client (please see further details in Clause (10) below);

(h) supporting any statements made in any documents in connection with the services of SFT;

(i) determining the amount of indebtedness owed to or by the Client;

(j) collecting of amount outstanding from Client and those providing security for Client’s obligations;

(k) assisting other relevant parties, professionals, institutions or relevant regulatory authorities to verify certain facts in connection with the services of SFT;

(l) meeting our obligations, requirements or arrangements or those of any member of the FFC Financial Group, whether compulsory or voluntary, to comply with or in connection with:

(1) any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside the Hong Kong Special Administrative Region ("Hong Kong") existing currently and in the future ("Laws") (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);

(2) any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future (e.g. guidelines, guidance or requests given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information) and any international guidance, internal policies or procedures;

(3) any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents with jurisdiction over all or any part of the FFC Financial Group (together the "Authorities" and each an "Authority") that is assumed by, imposed on or applicable to us or any member of the FFC Financial Group; or

(4) any agreement or treaty between Authorities;

(m) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the FFC Financial Group and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;

(n) conducting any action to meet our obligations or those of any member of the FFC Financial Group to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters; /p>

(o) meeting requirements to make disclosures under the requirements of any laws and/or regulations binding on SFT;

(p) meeting our obligations or those of any member of the FFC Financial Group to comply with any demand or request from the Authorities;

(q) enabling actual or proposed assignee(s) of all or any part of our business and/or assets, or participant(s) or sub-participant(s) of our rights in respect of you to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation and enabling the actual assignee(s) to use your data in the operation of the business or rights assigned; and

(r) any other purposes relating to or incidental to any of the above.

5 SFT shall keep Personal Data confidential but SFT may be required to provide Personal Data to the following persons in furtherance of the purposes set out in Clause (4) above, to which you hereby consent:

(a) any agents, contractors, sub-contractors or associates of the FFC Financial Group (including their employees, officers, agents, contractors, service providers and professional advisers);

(b) any officer, employee, agent or third party service provider who provides services to SFT or any member of the FFC Financial Group in connection with the operation or maintenance of our business (including their employees and officers);

(c) any authorities;

(d) an appropriate person under a duty of confidentiality to SFT or any member of the FFC Financial Group including any Affiliate which has undertaken to keep such information confidential;

(e) any person or institution with which the Client has or proposes to have dealings;

(f) credit reference agencies and debt collection agencies (in the event of default payment);

(f) credit reference agencies and debt collection agencies (in the event of default payment);

(g) any persons to whom we are or any member of the FFC Financial Group is under an obligation or required or expected to make disclosure for the purposes set out in, or in connection with, Clause (4)(l), (4)(m) or (4)(n) above;

(h) any actual or proposed assignee, transferee, delegate, successor or person to whom our right in respect of you and the authorized person of the Client;

(i) any of SFT’s actual or proposed assignees, participants, sub-participants or transferees; and

(j) any persons giving or proposing to give a guarantee or security to guarantee or secure your obligations to us; and

(k) (1) any member of the FFC Financial Group;

(2) third party financial institutions, insurers, tax consultants, legal advisors, securities and investment services providers;

(3) third party reward, loyalty, co-branding and privileges programme providers;

(4) co-branding partners of ours or any member of the FFC Financial Group (the names of such co-branding partners will be provided during the application process for the relevant products and services, as the case may be);

(5) charitable or non-profit making organisations; and

(6) external service providers that we or any member of the FFC Financial Group engage(s) for the purposes set out in Clause (4)(g) above.

6 Personal Data may be transferred to any place outside of Hong Kong, whether for the processing, holding or use of such data outside Hong Kong, and also to service providers which offer services to any Affiliate in connection with the operation of its business.

7 To the extent permitted by law, Personal Data collected by SFT from time to time may be used and disclosed in accordance with this Data Privacy Policy.

8 In accordance with the terms of the Privacy Ordinance, any individual has the right to:

(a) check whether SFT holds data about him/her and access to such data;

(b) require SFT to correct any data relating to him/her which is inaccurate;

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

(d) in relation to customer credit, request to be informed which items of Personal 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.

9 In accordance with the Privacy Ordinance, SFT reserves the right to charge a reasonable fee for the processing of any data access request. All requests for access to data or correction of data (when the Client considers that his/her Personal Data, supplied by SFT following a data access request, is inaccurate) or for information regarding policies and practices and kinds of data held should be addressed as follows:

Data Protection Officer

Silver Fountain Trust HK Limited

Suites 1005-1008, 10th Floor,

One Exchange Square, 8 Connaught Place,

Central, Hong Kong

10 USE OF PERSONAL DATA IN DIRECT MARKETING

We intend to use your Personal Data in direct marketing and we require your consent (which includes an indication of no objection) before we can use your Personal Data for this purpose. Your provision for this purpose is voluntary. The specific requirement regarding your consent (which includes an indication of no objection) is introduced in Part VIA of the Personal Data (Privacy) Amendment Ordinance 2012. In this connection, please note that:

(a) your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by SFT from time to time (“Marketing Personal Data”) may be used by SFT in direct marketing.

(b) the following classes of services, products and subjects may be marketed:

(i) financial, insurance, securities, commodities, investment and related services and products and facilities;

(ii) reward, loyalty, co-branding or privileges programmes in relation to the class of marketing subjects as referred to in Clause (10)(b)(i) above;

(iii) services and products offered by SFT’s co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be) in relation to the class of marketing subjects as referred to in Clause (10)(b)(i) above; and

(iv) donations and contributions for charitable and/or non-profit making purposes;

(c) the above services, products and subjects may be provided to or (in the case of donations and contributions) solicited by SFT and/or:

(i) any member of the FFC Financial Group;

(ii) any Affiliate of SFT;

(iii) third party financial institutions, insurers, securities, commodities and investment services providers;

(iv) third party reward, loyalty, co-branding or privileges programme providers;

(v) co-branding partners of SFT (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be); and

(vi) charitable or non-profit making organization;

(d) In addition to marketing the above services, products and subjects itself, SFT also intends to provide the Personal Data described in Clause (10)(a) above, whether such provision is for gain or not, to all or any of the persons described in Clause (10)(c) above for use by them in marketing those services, products and subjects described in Clause (10)(b) above (in respect of which SFT may or may not be remunerated), and SFT requires your written consent (which includes an indication of no objection) for those purposes;

We may not use your Marketing Personal Data for direct marketing without your consent. Please indicate your consent when signing relevant customer documents.
If you give your consent but subsequently change your mind and no longer wish SFT to use or provide to other persons your Marketing Personal Data for use in direct marketing as described above, you may exercise your opt-out right by notifying SFT in writing addressed to the Data Protection Officer in Clause (9) of this policy.
Please note however that the right to make such a request is not applicable to you if the direct marketing is addressed to you in your capacity as a representative of a company or business and is not sent to you in your individual or personal capacity.

11 Provision of Another Person’s Data

(a) Where you provide data about another person to us, you should give a copy of this Notice to that person and, in particular, tell them how we may use their data.