Privacy Policy

TOPPER DRAGON SECURITIES LIMITED (“the Company”)

CIRCULAR TO CLIENTS RELATING TO THE PERSONAL DATA (PRIVACY) ORDINANCE (“THE ORDINANCE”)

1. From time to time, it is necessary for clients to supply the Company with data in connection with the opening or continuation of accounts and the establishment or continuation of credit facilities or provision of securities trading, nominee and/or investment advisory services. At the same time, some of the data are collected pursuant to laws, regulations, rules or codes binding on the Company.

2. Failure to supply such data may result in the Company being unable to open or continue accounts or establish or continue credit facilities or providing securities trading, nominee and/or investment advisory services.

3. It is also the case that data may be collected from clients in the ordinary course of the continuation of the business relationship.

4. The purposes for which data relating to a client may be used are as follow：

(i) the daily operation of the services and credit facilities provided to clients;

(ii) conducting credit appraisals;

(iii) assisting other financial institutions to conduct credit appraisals;

(iv) ensuring ongoing credit worthiness of clients;

(v) designing financial or related products for clients’ use;

(vi) marking financial or related products (if applicable);

(vii) determining the amount of indebtedness owed to or by clients (if applicable) (viii)collection of amounts outstanding from clients and those providing security for clients’ obligations;

(ix) meeting the requirements to make disclosure under the requirements of any laws, regulations, rules or codes binding on the Company; and

(x) other purposes / ancillary or relating to the maintenance of the accounts.

5. Data held by the Company relating to a client will be kept confidential but the Company may provide such information to the following parties within or outside Hong Kong to the extent permitted by law:

(i) any agent, contractor third party service provider who provides administrative, telecommunications, computer, legal, accounting, payment, securities clearing or other services to the Company in connection with the operation of its business;

(ii) any other person under a duty of confidentiality to the Company including professionals and agents (including lawyers, accountants and debt collection agents) who have undertaken to keep such information confidential;

(iii) any financial institution with which the client has or proposes to have dealings;

(iv) any actual or proposed assignee of the Company or participant or sub-participate or transferee of the Company’s rights in respect of the client; and

(v) any other person when we are compelled to make disclosure under the requirements of any laws binding on the Company;

(vi) any person with the clients express or implied consent;

(vii) any person where our interests require disclosure; and

(viii) any person where the public interest requires disclosure.

6. The Company may match, compare, transfer or exchange any personal data collected by it with the data collected by government bodies, other regulatory authorities, corporations, organizations or individuals, in Hong Kong or overseas for the purpose of verifying those data.

7. Under and in accordance with the terms of the Ordinance any individual:

(i) has the right to check whether the Company holds data about him / her and the right of access to such data;

(ii) has the right to require the Company to correct any data relating to him/her which is inaccurate;

(iii) has the right to ascertain the Company’ policies and practices in relation to data and to be informed of the kind of personal data held by the Company.

8. In accordance with the terms of the Ordinance, the Company has the right to change a reasonable fee for the processing any data access request.

9. The person to whom requests for access to data or correction of data for information regarding policies and practices and kinds of data held are to be addressed as follows: Responsible Officer

Topper Dragon Securities Limited