Privacy Statement
VCOMPLY GLOBAL Consulting Limited
The purpose of this Privacy Statement is to establish the policies and practices of VCOMPLY GLOBAL Consulting Limited, its associated companies and/or its subsidiaries (“we”, “us”, “our”; collectively, the “Company”) towards our commitment in complying with the Personal Data (Privacy) Ordinance (the “Ordinance”) and in protecting the privacy, confidentiality and security of all personal data which we may collect or being held so as to maintain the trust and confidence between you and us.
Collection of Data
We may collect the data of customers and other individuals in connection with the purposes set out in this Privacy Statement.
If the data requested by us is not provided, services or products may not be able to be provided (or continue to be provided) to those customers and other individuals, applicants or persons linked to you.
Use of Data
Personal data relating to a data subject may be used for the following purpose(s) (which may vary depending on the nature of your relationship with the Company) :
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the processing of applications for an account with the Company
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the daily operation of services and/or products
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the marketing of services and/or products
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meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to the Company
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exercising our rights under the contract(s) with you, including collecting any amount due and/or payable to us
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meeting our obligations, requirements or arrangements or those of any member of the Company, whether compulsory or voluntary, to comply with or in connection with any rules, regulations and/or laws applicable to us within or outside jurisdiction of the Hong Kong Special Administrative Region (“Hong Kong”) currently and in future
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third party disclosures may include sharing such information with non-affiliated companies which perform supporting services on our behalf including those that provide professional, legal or accounting advice to the Company
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any other purposes relating to the purposes listed above.
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Disclosure of Data
Data held by us will be kept confidential, but we or a member of the Company may transfer or disclose such data to the following parties (whether within or outside Hong Kong) for the purposes set out in this Privacy Statement below :
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any agents, contractors, subcontractors and/or associates of the Company (including their employees, officers, agents, contractors, service providers and professional advisors)
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any third party service providers which provide services to us or any member of the Company in connection with the operation or maintenance of our business (including their employees and officers)
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any authorities, any law enforcement agencies or regulatory bodies for complying with the applicable laws, rules, regulations, codes and guidelines or any person or entity to whom we or any member of the Company are under the obligation to satisfy a legally enforceable demand for disclosure under the requirements of any laws, rules, regulations, codes and guidelines
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any person under a duty of confidentiality to us or any member of the Company which has undertaken to keep such information confidential
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any person receiving payment from you, the banker of such person and any intermediaries which may handle or process such payment
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credit reference agencies, and, in the event of default, to debt collection agencies
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any persons to whom we or any member of the Company are under the obligation or required or expected to make disclosure for the purposes set out in this Privacy Statement
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any party enters into or proposes to enter into the transaction for and on your behalf
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for marketing services and/or products
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any member of the Company; and
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external service providers that we or any member of the Company engage(s) for the purposes set out in this Privacy Statement
Use of Data in Direct Marketing
The Company intends to use your data in direct marketing, and we require your consent (which includes an indication of no objection) for that purpose. Pursuant to the Ordinance, direct marketing activities conducted by the Company may include but not limited to the following :
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offering, or advertising of the availability, of goods, facilities or services and/or products
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sending information or goods, addressed to specific persons by name, by mail, fax, electronic mail or other means of communication; and/or
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making telephone calls to specific person(s)
In this connection, please note that:
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the names, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of the data subject held by us from time to time may be used by us in direct marketing;
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in addition to marketing services and/or products which the Company is allowed to provide, the Company also intends to provide the data collected from data subjects to third parties (as permitted by, or to comply with, applicable laws and regulations) for use by them in marketing those services, products and subjects, and the Company requires the data subject’s written consent (which includes an indication of no objection) for that purpose.
If you do not wish us to use or provide to other persons his data for use in direct marketing as described above, you may exercise your opt-out right by notifying us in writing to our Data Protection Officer.
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Access and Correction of Data
Under the Ordinance, you have the right :
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to ascertain whether we hold data about you, and to have access to such data
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to request the Company to correct your personal data which is inaccurate
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to object to the use of your personal data for marketing purposes and the Company shall not use your personal data for marketing purposes after you communicate your objection to the Company.
We may impose reasonable fees for the data access request in accordance with the Ordinance.
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Details
Please address your request(s) for data access or correction by writing to our Data Protection Officer at:
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VCOMPLY GLOBAL CONSULTING LIMITED
Unit 2406, 24/F., Strand 50 (formerly known as Bonham Trade Centre)
50 Bonham Strand
Sheung Wan
Hong Kong
Email : compliance@vcomplyglobal.com
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Amendments to this Privacy Statement
The contents of this Privacy Statement may be amended from time to time. Please contact us or visit our website for the latest Privacy Statement.
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In the event of any discrepancy between the Chinese and the English versions, the latter shall prevail.
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(updated version in October 2022)