Anson Bay Private Client Services Limited

Privacy Policy and Personal Information Collection Statement

Anson Bay Private Client Services Limited and/or their affiliates (referred to hereinafter as the “Company”, “Anson Bay”, “us”, “we”, “our”) recognize our responsibilities in relation to the collection, holding, processing, use and/or transfer of your personal data.

In compliance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “Ordinance”), this Privacy Policy, which includes our Personal Information Collection Statement, sets out the manner in which personal data may be collected, held, used, transferred and otherwise handled by the Company. It is issued to individuals who provide personal data to the Company.

This policy applies to any individual’s personal data which is in our process or under our control.

Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate.

1. What Personal Data we collect

Personal data is any information that relates to an identifiable individual and we may collect this information when you interact with our services:

1. Personal particulars (e.g. name, contact details, residential or correspondence address, gender, date of birth, nationality, country of residence, occupation, dependents, beneficiaries, etc);
2. Identification documents (e.g. identity card or passport details, national identification cards, etc);
3. Financial identifiers and other information (e.g. tax identification number, bank account statements, income, assets, liabilities, investment portfolio statements, existing insurance policies, bank account details or other payment details, etc);
4. Information about your physical and mental health (e.g. medical history, etc);
5. Details of interaction with us (e.g. images, biometrics, etc); and
6. Other information relevant to the services provided to you.

In order to establish, maintain and administer the relationship between you and Anson Bay, and to comply with applicable legal and regulatory requirements, you may be asked from time to time to provide personal data and supporting information.

Where requested information is not provided, Anson Bay may be unable to process an application, continue providing services, fulfil contractual obligations, or satisfy applicable legal, regulatory or compliance requirements.

2. How we collect your Personal Data

We will collect and store your personal data:

• directly when you provide such information to us (for example, when you send us enquiries or communications, face-to-face meeting, etc);
• during the course of your ongoing dealings with Anson Bay, including when you submit applications, make payments, conduct transactions, participate in seminars or events, access online platforms, or otherwise communicate with Anson Bay in person, by telephone, electronically or in writing;
• indirectly through your use of apps or social media platforms; or
• where you have provided it to us through any other means.

We may obtain lawfully collected personal or non-personal data about you from affiliated entities, business partners and other independent third parties’ sources.

3. How do we use your Personal Data

In order to provide you with our insurance brokerage services and other services set out in the “Purpose” below, we may collect personal data directly from you or from other third parties who have obtained your consent for the provision of your basic personal information to Anson Bay and have referred you to Anson Bay (e.g. your bank or your financial adviser).

The purposes for which personal data may be collected, used, processed, retained or disclosed will depend on the nature of the relationship between you and Anson Bay. Personal data is collected for the following Purposes:

1. to provide you with access to the content on the website, apps or social media platforms;
2. to assess and process applications for products or services, including identity verification and customer due diligence procedures;
3. to provide insurance brokerage services to you, including assessing and evaluating your needs on insurance, wealth management, estate planning, business planning or other financial matters;
4. to advise or act for you on matters relating to insurance, wealth management, estate planning, business or financial planning, or arranging insurance contracts on your behalf;
5. to provide, administer and maintain accounts, policies, products and services requested by you, and to carry out activities associated with the servicing, management and administration of products and services offered by Anson Bay;
6. to provide subsequent services to you, including but not limited to conducting face-to-face meetings or phone discussions for the purposes of reviewing and administering any products/services you have purchased; any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services you have purchased, including investigation of claims;
7. to communicate with you including to send you administrative and technical communications about any account you may have with us, to provide technical support or notify about future changes to this policy;
8. for advanced data analytics, data matching, internal business and administrative purposes;
9. to develop, review and enhance insurance, wealth management, financial planning and related products or services;
10. to monitor your use of portal and social media platforms and conduct analysis of the use of the portal to operate, evaluate and improve the portal and our services, understand your preferences and troubleshoot any problems;
11. to comply with applicable legal, regulatory, compliance, risk management, reporting and internal governance requirements in Hong Kong or elsewhere;
12. to assist in law enforcement purposes, investigations by police or other government or regulatory authorities and to meet requirements imposed by applicable laws and regulations or other obligations committed to government or regulatory authorities;
13. subject to your consent or indication of no objection where required by law, to conduct direct marketing as described in section (E) below;
14. other purposes in connection with the provision of our brokerage services as notified at the time of collection; and
15. other purposes ancillary, incidental or directly connected to any of the above.

4. Who do we share your Personal Data with

Personal data will be kept secured (including when in transit), confidential and subject to the provisions of any applicable law. Anson Bay will take reasonable steps to protect the confidentiality and security of personal data against unauthorized access, use, loss, disclosure, alteration or destruction.

Your personal data may be provided, whether within or outside Hong Kong, to the following recipients for the Purposes listed above:

1. any of our holding company, subsidiaries, affiliates, associated companies and representative offices, and any person associated with the Company;
2. any insurer or reinsurance company, trustee, custodian, investment manager, administrator, registrar, transfer agent, auditor, claims investigation company, industry association or federation, financial institution or other professional service provider engaged in connection with the products or services provided, in Hong Kong or elsewhere, and in this regard, you consent to the transfer of your data outside of Hong Kong;
3. any agent, contractor, consultant or third-party service provider who provides administrative, technology, telecommunications, payment processing, settlement, data management, marketing, communication, storage, printing, mailing, customer relationship management or other business support services (including direct marketing services) to the Company and/or our affiliates or elsewhere and who has a duty of confidentiality to the same;
4. the directors, officers, employees and authorized representatives of Anson Bay;
5. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and
6. any government department, governmental body, regulatory authority, law enforcement agency, court, tribunal or any other person to whom disclosure is required or permitted under applicable laws, regulations or official requests, in Hong Kong or elsewhere.

For our policy on sharing of your personal data for marketing purposes, please see the section below “Use and Provision of Personal Data in Direct Marketing”.

Transfer of your personal data will only be made for one or more of the Purposes specified above.

The transfer mentioned above may involve the transfer of your personal data to jurisdictions outside Hong Kong for processing. Overseas jurisdiction may not have laws which require the same protection of personal data as Hong Kong or other relevant jurisdictions. We will ensure that any such transfer only take place under adequate safeguards, as required by the law, or otherwise in accordance with the law.

5. Use and Provision of Personal Data in Direct Marketing

The Company and/or its affiliates intends to:

1. use your name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data held by the Company from time to time for the purpose of providing products and services and additional insurance advisory activities;
2. provide your personal data to insurance companies and/or reinsurers for the purpose of obtaining life cover;
3. provide information regarding your insurance policy and/or application to a financial institution for the purpose of obtaining financing;
4. provide your personal data to insurance companies and/or reinsurers for the purpose of obtaining additional life cover as well as health, wellness, annuity and other insurance products;
5. provide information regarding your insurance policy to the policy’s owner which may be you or an affiliated entity as instructed by you;
6. use your data to provide “after-sales” services including face-to-face meetings and phone discussions for the purpose of advising, reviewing and administering your policy(ies); and
7. use your data to conduct marketing and promotional activities relating to (i) insurance, wealth management, investment, financial planning and related products and services; (ii) seminars, workshops, educational events and customer engagement programmes; and (iii) products and services offered by Anson Bay and its affiliated companies, in each case subject to your consent or indication of no objection where required by law.

You have the right to opt out of the use of your personal data for direct marketing purposes at any time, and may in the future withdraw your consent to the use and provision of your personal data for providing the insurance advisory activities. Upon receipt of your request, Anson Bay will cease using your personal data for direct marketing without charge and within a reasonable period. You may send your request to contactus@ansonbay.com

6. Access Rights to Personal Data

Subject to applicable laws and regulations, including the Ordinance and those of Hong Kong where relevant, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate, incomplete or out of date. You may also request the Company to inform you of its policies and practices in relation to personal data, the types of personal data held by it, and how such personal data has been used or disclosed within the last year. You also have the right to withdraw consent to, or object to, the use of your personal data for direct marketing purposes, following which Anson Bay will cease such use in accordance with applicable legal requirements.

Requests for access and correction, enquiries regarding the Company’s data privacy practices and the kinds of data held by the Company, or objections to the use of your personal data for direct marketing purposes should be addressed in writing to:

Data Protection Officer
Anson Bay Private Client Services Limited
Unit 1922, Level 19, China Building, 29 Queen’s Road Central, Central, Hong Kong
Email: contactus@ansonbay.com

A reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your data access requests. We may not be able to accede to a request if there are regulatory reasons for it.

7. Retention of Personal Data

Personal data collected by Anson Bay will be retained only for as long as necessary to fulfil the purposes for which it was collected, to meet operational requirements, or to satisfy applicable legal, regulatory, taxation, accounting or compliance obligations.

8. Using technology responsibly

Our approach to conduct applies to everything we do, and we continue to assess that approach considering changes in the environment in which we operate. Anson Bay continues to explore and invest in new technologies, which offer tremendous potential to improve the services we provide to customers, and to manage our business more effectively. Data technologies and artificial intelligence (AI) give us the ability to process and analyse a depth and breadth of data which was never previously possible. These new opportunities come with new responsibilities: we must ensure that data and AI are used ethically and are secured.

Nothing in this policy shall restrict or affect any rights available to you under the Ordinance.