1.1 This privacy statement is made on behalf of Capital Dynamics Asset Management (HK) Private Limited ("CDHK"). CDHK is committed to protecting your privacy and to comply with the Hong Kong Personal Data (Privacy) Ordinance (“PDPO”).
1.2 This privacy statement sets out the policy of CDHK for management of personal information. We are committed to ensure the privacy, confidentiality and security of your information. The information we hold is managed in an open and transparent manner with procedures implemented in compliance with the PDPO and any applicable code of conduct and guidelines, and to deal with any complaints relating to our compliance therewith.
2.1 The information we collect from you will depend on what services we provide. CDHK will also collect any personal information necessary for the purposes of complying with the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (“AMLO”). Information may include the following:
3.1 CDHK only collects personal information as may be required by laws, regulations and/or authorities or that is necessary to conduct CDHK’s business. Personal information may be collected directly from individuals or entity or through a third party engaged by CDHK, and only by lawful and fair means.
3.2 Information is generally sought through our account opening forms, in which the purpose is articulated. Accordingly, we will always ensure you are apprised of our purpose in collecting information, and your right to gain access to such information.
3.3 If you do not provide the information requested, we may be unable to provide you with our services.
3.4 We may also collect information about you from our Website but this information will only identify who you are if you provide us with your details (eg. if you e-mail your contact details to us). When you visit our Website our web server collects the following types of information for statistical purposes:
No attempt is made to identify individual users from this information.
4.1 A cookie is a small text file placed on your computer hard drive by a web page server. Cookies may be accessed later by our web server. Cookies store information about your use of our Website. Cookies also allow us to provide you with more personalised service when using our Website. If you set your browser to reject cookies you may not be able to make full use of this Website.
5.1 CDHK collects and holds personal information about an individual for the purpose of providing financial services. We collect this information with your consent as per our account opening form or other documentation, for the primary purpose disclosed to you at the time of collection.
5.2 In some cases CDHK will use or disclose personal information for secondary purposes (any purpose other than a primary purpose). Personal information obtained to provide financial services may be applied to secondary purposes if the secondary purpose is directly related to the primary purpose of collection and the person concerned would reasonably expect the personal information to be used or disclosed for such secondary purpose.
5.3 In some cases we may ask you to give prescribed consent to any collection, use or disclosure of your personal information for purposes not related to the original purpose or a purpose directly related to the original purpose. If so, you will be required to give your prescribed consent verbally or in writing and may be given in person, or in written form.
5.4 We may use your personal information (e.g. postal address, e-mail address, telephone numbers, facsimile number, date of birth, bank account details, details related to the provision of verification and identification documentation) to:
5.5 CDHK may disclose your personal information to:
5.6 If you provide us with your e-mail address, it will only be used for the purpose for which you provided it to us. It will not be added to a mailing list without your consent unless the mailing list is related to the purpose for which you provided your e-mail address to us.
5.7 We require any party that has access to personal information to conform to our privacy standards.
6.1 CDHK, with your consent, either verbally or written, will only use personal information obtained for the provision of financial services, for the secondary purpose of direct marketing.
6.2 You will continue to receive information in relation to certain changes to products / services or regulations from us, as provided by the law. We will not disclose your information to any outside parties for the purpose of allowing them to directly market to you unless we obtain a written consent from you to do so.
7.1 CDHK takes all reasonable steps to ensure the personal information held about individuals is accurate, up-to-date and complete. We encourage you to assist us by informing us immediately if any of your details need to be corrected or updated.
7.2 Where a person requests access to their personal information, our policy is, subject to certain conditions, to permit access, and we will seek to provide such information within a reasonable period of time, and in the manner so requested (where reasonable to do so).
7.3 CDHK will correct personal information where that information is found to be inaccurate, incomplete, out of date, irrelevant or misleading or an individual requests us to correct information held about them. We will not charge you a fee for your access request but may charge you the reasonable cost of processing your request. If you request us to similarly advise a relevant third party of such correction, we will facilitate that notification unless impracticable or unlawful for us to do so.
7.4 CDHK may not always under all circumstances be able to give you access to all the personal information we hold about you or we may also decline your correction request. In that case, we will provide you with a written explanation of the reasons for our refusal, together with details of our complaints process if you wish to challenge the decision. You may also request that we associate the personal information we hold with a statement regarding your view of its inaccuracy, where applicable.
8.1 We take reasonable steps and precautions to protect personal data against unauthorised or accidental access, processing, erasure, loss or use
8.2 If you use the Internet to communicate with us, you should be aware that there are inherent risks in transmitting information over the Internet. CDHK does not have control over information while in transit over the Internet and we cannot guarantee its security.
8.3 Where information is no longer required to be held or retained by CDHK for any purpose or legal obligation, we will take all reasonable steps to destroy or de-identify the information accordingly.
9.1 If you have a complaint relating to our compliance with privacy laws or our treatment of your personal information, please contact our Privacy Officer by phone on (852) 2153 1455, 9.00am-6.00pm, Monday to Friday (excluding public holidays); or by email to firstname.lastname@example.org or by mail to, the Privacy Officer, Capital Dynamics Asset Management (HK) Pte Ltd, Suite 701, 7th Floor, Chinachem Leighton Plaza,29 Leighton Road,Causeway Bay, Hong Kong.
9.2 We will revert and endeavour to answer your questions or resolve any issues, where applicable, to your satisfaction. If you are not satisfied with the outcome, please be informed that you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data Hong Kong via: -
Post / In Person
Address :12/F, Sunlight Tower, 248 Queen's Road East, Wanchai, Hong Kong
Opening Hours: Monday to Friday,8:45 a.m. to 12:45 p.m,1.50 p.m. to 5:40 p.m.
Fax: 2877 7026.
Website: www.pcpd.org.hk (for a copy of the complaint form)