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FFC Financial Group Privacy Policy

Fortune Fountain Capital Financial Group ("FFC Financial Group" and any "member of the FFC Financial Group" means Fortune Fountain Capital Financial Group 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 clients (the “Clients”) and ourselves. To preserve the confidentiality of all personal data clients 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 Clients’ personal data to provide the Clients 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 FFC Financial Group 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 FFC Financial Group, 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 FFC Financial Group or its 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 FFC Financial Group 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 FFC Financial Group and/or its 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 FFC Financial Group;

(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 FFC Financial Group;

(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;

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

(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       FFC Financial Group shall keep Personal Data confidential but FFC Financial Group 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 FFC Financial Group 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 FFC Financial Group 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);

(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 FFC Financial Group’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 FFC Financial Group 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 FFC Financial Group holds data about him/her and access to such data;

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

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

FFC Financial Group

Room 1005-1008, 10/F , 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 FFC Financial Group from time to time (Marketing Personal Data) may be used by FFC Financial Group 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 FFC Financial Group’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 FFC Financial Group and/or:

(i)      any member of the FFC Financial Group;

(ii)     any Affiliate of FFC Financial Group;

(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 FFC Financial Group (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, FFC Financial Group 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 FFC Financial Group may or may not be remunerated), and FFC Financial Group 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 FFC Financial Group 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 FFC Financial Group 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.



PRIVACY STATEMENT FOR BROWSING FORTUNE FOUNTAIN CAPITAL GROUP WEBSITE

Use of Cookies on FFC Financial Group websites

FFC Financial Group may record your visit to this website for analysis on the number of visitors to the website and general usage patterns. A part of the abovementioned information together with your personalised settings information may be collected via the use of "Cookies".


Cookies are small bits of information that are automatically stored on a person's web browser in his/her computer that can be retrieved by this site. Cookies can make the site more useful by storing information about your preferences on particular webpages and about your personalised settings, thus enabling website owners to provide more useful features for their users. During your visit to this website, our network servers may also record and verify your domain name and IP address and track the pages you visit. This information does not identify you as an individual.


The information collected by Cookies is anonymous visitor’s personalised settings information such as language preference and aggregated research data including number of the visitors, behavior and usage patterns. Most browsers are initially set to accept cookies. If you would prefer, you can change the setting on your browser itself by setting your browser to disable cookies or inform you when they are set. However, by disabling them, you may not be able to take full advantage of our website.


IP Address

Your IP address is identified and logged automatically in our server log files whenever you visit our website, along with the page(s) and the time of visited. IP address is a number that is assigned automatically by your internet service provider to your computer or other electronic device. It is a standard practice to collect IP address on the internet. We may use the IP address for the purposes such as to calculate site usage levels, to help diagnose server problems, to personalize your experience while engaging with us online and offline, to administer the website and/or for compliance and security purposes.


Information collected through your browser or device

Certain information may be collected through your browsers or your device, such as browser and device type and version, screen resolution, operation system version and/or your Media Assess Control address. This information is used to ensure websites function properly, for fraud detection and prevention, and for other security purposes.


Internet Communication Privacy

The Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. It is your responsibility to maintain the secrecy of any Login ID and password you hold.


Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same jurisdiction) via countries with weaker privacy and data protection laws than in your jurisdiction.  As a result, FFC Financial Group does not take any responsibility or liability for the confidentiality, security or integrity of data of information in connection with its transmission over the Internet.


In order to maintain the security of our system, protect our staff, record transactions, and in certain circumstances, to prevent and detect crime or unauthorized activities, we reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.


FFC Financial Group may update, amend or revise the Privacy Policy on this website from time to time. You should regularly check this page for the latest version.


If there is any discrepancy between the English and Chinese versions, the English version shall prevail.