Your privacy is important to us. This Data Protection Policy outlines how your personal data will be managed in accordance with the Personal Data (Privacy) Ordinance of Hong Kong (Cap. 486) (“PDPO”) the objective of which is to protect the privacy rights of a person in relation to personal data. Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we may collect, use and/or disclose your personal data.
You agree and consent to Aberdeen International Fund Managers Limited and affiliates (“Aberdeen”) as well as our authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your personal data in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our business purpose and/or any changes in legal or regulatory requirements.
For the avoidance of doubt, this Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions. This Data Protection Policy is prepared in both the English and Chinese languages and in the event of any inconsistency, the English version shall prevail. Aberdeen processes your personal data which you had previously provided through contact with Aberdeen. Aberdeen may also have obtained your personal information from third parties such as Aberdeen’s distributors when you submit an application for investment in Aberdeen’s product.
In this Data Protection Policy, the term “personal data” refers to any data or information which relates to you as a living person and from which your identity can be ascertained, in a form in which access to or processing is practicable.
Personal data that we collect from you includes but is not limited to:
- your name;
- e-mail address; and
- other information relating to you which you have provided to us in any forms you may have submitted to us, or in other forms of interaction with you.
If you fail to provide the requested personal data, we may be unable to provide you with market updates and news relating to financial markets and products as stated below in the purposes for the collection, use and disclosure.
Purposes for the collection, use and disclosure
Aberdeen collects, uses and/or discloses your personal data, including any additional personal data you may subsequently provide, for the following purposes:
- to contact you and to send to you market updates and news relating to financial markets and products;
- to respond to any enquiry from you;
- to form part of the records of the recipient as to the business carried out by it;
- communicating with you to inform you of changes and updates to our policies, terms and conditions and other administrative information;
- to observe any legal, government or regulatory requirements of Hong Kong or other relevant jurisdiction including any disclosure or notification requirements to which any recipient of the personal data is subject;
- other purposes, directly or indirectly relating to any of the above and Aberdeen’s activities. (Hereinafter collectively referred to as the “General Purposes”)
Subject to your consent (including an indication of no objection), Aberdeen may also use and/or disclose your personal data for the following purposes: (i) sending you marketing updates on products and services offered by Aberdeen; (ii) promoting and administering events, contests and competitions organised or sponsored by Aberdeen;(iii) developing marketing programmes for Aberdeen; and (iv) other purposes, directly or indirectly relating to any of the above (collectively referred to as the “Marketing Purposes”).
Disclosure of personal data
Your personal data may be disclosed to Aberdeen’s holding company, subsidiaries, related and/or associated company, affiliates, delegates, trustee(s), business partners, and/or service providers, or any third party and/or agents (including outsourcing agents and data processors), any and all governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, any court and/or officer of the court for any of the above General Purposes and Marketing Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above General Purposes and Marketing Purposes. Further, your personal data may be transferred to locations outside Hong Kong.
Access and correction of your personal data
You are responsible for ensuring that the information you provide is accurate, complete, and not misleading and that such information is kept up to date.
You may request access to and correction of your personal data by writing to the Personal Data Protection Officer, at Aberdeen’s office address 30th Floor, LHT Tower, 31 Queen’s Road Central, Hong Kong with any enquiries in respect of your personal data.
Aberdeen reserves its rights to refuse to comply with your request for access or correction to your personal data under PDPO and if Aberdeen refuses to comply with such request, you will be informed of such refusal and the reason for the same.
Withdrawal of consent
If you wish to withdraw your consent to any use or disclosure of your personal data for Marketing Purposes as set out in this Data Protection Policy, you may write to the Personal Data Protection Officer at Aberdeen’s office address 30th Floor, LHT Tower, 31 Queen’s Road Central, Hong Kong, or click the “Unsubscribe” button on the email sent by Aberdeen.