PRIVACY POLICY STATEMENT

We respect your privacy and your rights and choices.  We are committed to protecting the confidentiality and security of your personal data by complying with the requirements of the Personal Data (Privacy) Ordinance.  We explain here what we will, and will not do, with your personal data.  Please read this together with our Personal Information Collection Statement (PICS) which can be found here.  If you are our client, please also read this Statement together with your engagement letter.

Why we collect personal data and how we use it

We collect, store, use and process your personal data so that we can provide services to you and to keep you informed of news and developments that may be of interest or relevance to you or your business, or for any other purpose that you have agreed.  This may include using your personal data, for example: (a) to on-board you or your company as a client; (b) to provide legal services; (c) to manage our business; (d) to prepare, review and make contracts, agreements, governmental filings and other documents; (e) to implement and manage projects and assignments instructed by you; and (f) to update you on news and developments that may be of interest or relevance to you or your business.  We are committed to using your personal data only for such purposes.

The personal data we collect and how we collect it

We collect and/or request personal data from you when you submit personal data to us in one of various ways and through our interactions with you.  The personal data we collect includes but is not limited to the following types of personal data:

• Personal details including name, titles, addresses, contact information, date of birth, gender, relationship status, nationality(ies) and permanent residence(s)
• Similar details of your spouse, partner, children and other dependants
• Details of your family relationships
• Information about your businesses, shareholdings, assets and beneficial interests
• Financial information
• Bank account details.

No direct marketing

Some of the information we require is mandatory otherwise we will not be able to provide our services. We will not provide your personal data to third parties for direct marketing or other unrelated purposes.

Minors

We will not collect personal data relating to minors without the prior consent of a person with parental responsibility.

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.  We may however be required to keep your personal data for a longer period for legal and compliance reasons.

Sharing your personal data

We would not ordinarily disclose or transfer personal data to a third party without your prior consent.  Spouses, children, relatives, private bankers, external asset managers, trustees and other service providers have no automatic right of access to your personal data.

There are occasions when we may disclose your personal data to external people or agencies, such as: (a) our affiliates engaged in providing similar services; and (b) our agents, vendors, contractors or third party service providers who help us to provide services to you.  We will take all practicable steps to ensure that these persons keep your personal data confidential.  We may also transfer or disclose your data to relevant government authorities (including tax and anti-money laundering enforcement authorities), courts and tribunals as necessary or desirable or to comply with law, regulation or codes of practice or to enforce our rights against you.  Where required, we will first obtain consent from you for such disclosure.

Security of personal data

We store personal data on our cloud-based database and we restrict access to those persons who “need to know” and who have been trained to handle personal data properly.  We have strict personal data security policies.

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 us at [email protected] or at our business address stated on this website with the subject heading “Data Access Request”.  We may charge you a small fee for complying with a data access request.  We may amend this Privacy Policy Statement at any time and from time to time in order to inform you of any changes to the way we collect, store, handle and process personal data.

Thank you.

PERSONAL INFORMATION COLLECTION STATEMENT

Why do you need to collect my personal data?

We need to collect your personal data for the purpose of providing our services to you and to keep you informed of news and developments that may be of interest or relevance to you or your business, or for any other purpose that you have agreed.  This may include using your personal data, for example: (a) to on-board you or your company as a client; (b) to provide legal services; (c) to manage our business; (d) to prepare, review and make contracts, agreements, governmental filings and other documents; (e) to implement and manage projects and assignments instructed by you; and (f) to update you on news and developments that may be of interest or relevance to you or your business.  We are committed to using your personal data only for such purposes.

Do I need to supply my data?

In order for us to provide services to you, you must provide to us your personal data which may include, for example, the following types of information.

• Personal details including name, titles, addresses, contact information, date of birth, gender, relationship status, nationality(ies) and permanent residence(s)
• Similar details of your spouse, partner, children and other dependants
• Details of your family relationships
• Information about your businesses, shareholdings, assets and beneficial interests
• Financial information
• Bank account details.

If you do not provide us with such personal data, we will be unable to provide you with our services.   If you do not provide us with your contact information, we will not be able to contact you to ask you for your comments or instructions.  In certain circumstances, we may need to contact you urgently regarding our services.  If you do not provide us with your contact information, we will be unable to contact you urgently.

Who else will receive my personal data?

In order to provide our services to you, we may transfer or disclose your data to the following classes of persons who may be in or outside of Hong Kong: (a) our affiliates engaged in providing similar services; and (b) our agents, vendors, contractors or third party service providers who help us to provide services to you.  We will take all practicable steps to ensure that these persons keep your personal data confidential.  We may also transfer or disclose your data to relevant government authorities (including tax and anti-money laundering enforcement authorities), courts and tribunals as necessary or desirable or to comply with law, regulation or codes of practice or to enforce our rights against you.  Where required, we will first obtain consent from you prior to such disclosure.

What happens if my personal data becomes inaccurate?

Based on what you provide to us, we will take all practicable steps to ensure that your personal data is accurate taking into account the purpose for which we will use your personal data.

Where we believe that your personal data is inaccurate, we will not use the data unless and until we believe that the data is no longer inaccurate e.g. by correcting or erasing the data.

If we find out that your personal data which we disclosed to a third party was materially inaccurate at the time of disclosure taking into account the purpose for which the data is to be used by that third party, we will inform the third party that the data is inaccurate.  Where we have the correct information, we will provide the third party with such particulars so it can correct the data.

How safe will my personal data be?

We take all practicable steps to ensure that your personal data is protected against unauthorized or accidental access, processing, erasure, loss or use.  We store personal data in a cloud-based database access to which is password protected.  We restrict access to those persons who “need to know” and who have been trained to handle personal data properly.  We have strict personal data security policies.

How long will you keep my personal data for?

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.  We may however be required to keep your personal data for a longer period for legal and compliance reasons.

What rights do I have?

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 us at [email protected] or at our business address stated on this website with the subject heading “Data Access Request”.

Please also read our Privacy Policy Statement that can be found here.

Thank you.