Privacy policy statement

The purpose of our Privacy Policy Statement (PPS) is to enable you: (a) to ascertain our policies and practices in relation to personal data; (b) to inform you of the kind of personal data held by us; and (c) to inform you the main purposes for which personal data held by us is or is to be used. This PPS should be read in conjunction with our client engagement letter, which contains a Personal Information Collection Statement (PICS).

Our policy

We are committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements of the Hong Kong Personal Data (Privacy) Ordinance, or any analogous statutory legislation. We are committed to ensuring that our employees, agents, contractors and providers uphold these obligations. We are also committed to collecting, storing and processing personal data only for the purposes and in the manner that we have informed you or, as appropriate, you have agreed.

Our collection of personal data

We will collect, store, use and process your personal data only for the purposes of providing professional services, and for any other purpose ancillary to the above or that you have agreed to or have been notified of.

The personal data we collect

The information we collect is determined by our operational needs and includes but is not limited to: name; address, contact information; nationality; gender; date of birth, directorships and other offices held.

How we use personal data

We use your personal data for us to run our business and that of our affiliated companies and businesses. We may also disclose your personal data in order to comply with law, regulation or a court or tribunal.

Retention of personal data

We will take all practicable steps to ensure that we do not keep your personal data for longer than is necessary for the purpose that we collected it. If we engage a data processor to process personal data, we will take means to prevent any personal data transferred to the data processor from being kept longer than is necessary for processing of the data. We may however be required to keep your personal data for a longer period for legal and compliance reasons.

Unless you have consented expressly for data to be retained for a longer period or there is a subsisting reason that obliges us to retain the data for a longer period, our retention policy is to keep data no longer than seven years.

Disclosure of personal data

We would not ordinarily disclose or transfer personal data to a third party without your prior consent. However, we may transfer or disclose your data to the following classes of persons who may be in or outside of Hong Kong:

Unless you have consented expressly for data to be retained for a longer period or there is a subsisting reason that obliges us to retain the data for a longer period, our retention policy is to keep data no longer than seven years.

  1. any of our affiliated companies and businesses;
  2. our associated partnership firms (any person referred to in (a) or (b) being an Acclime Company);
  3. the agents, vendors, contractors or third party service providers who assist or collaborate with Acclime to carry on business or to conduct internal operations and/or to provide Services (including but not limited to banking or other institutions, accountants, auditors, legal and other advisers);
  4. data processors;
  5. any person to whom we are required by applicable law or regulation to disclose such data;
  6. as is required for the proper provision of our services;
  7. as is required for the proper trusteeship or protectorship of a trust or foundation;
  8. as is required in order to provide relevant parties with information so as to enable them to carry out due diligence, KYC, AML and other verification procedures.

Security of personal data

We adopt strict personal data security policies. We store personal data in secure facilities and access is restricted to those persons who “need to know” and who have been trained to handle personal data properly.

Access to and correction of personal data

You have the right to ascertain what personal data of yours that we hold, to request access to your personal data (via the prescribed data access request form) and to request the correction of your personal data held by us. If you have any such request, please contact your relationship manager.

© Acclime 2019 | Privacy policy