Cookies & Privacy Policy
Please carefully read this Policy which provides you with information regarding the personal data and cookies policy of SYCICAP Asset Management Limited Hong Kong (“Syncicap”) and its affiliates (together “Syncicap Group).
I. Personal Information Collection Statement
1. Reason for collection of personal data
The Syncicap Group’s principal business activities are financial services (“Services”), including without limitation asset management, investment advisory and distribution of investment or financial products. In the course of conducting its business, the Syncicap Group may from time to time collect and hold personal data (as defined in the Personal Data (Privacy) Ordinance (the “Ordinance”)) relating to you and, if applicable, the directors or responsible officers of your organisation (“Personal Data”).
Examples of Personal Data that may be collected include company name, last and first name, contact information such as telephone and mobile number, email address and postal address, social media identity. You must ensure the accuracy of the Personal Data provided.
Failure to supply the requested Personal Data may result in the Syncicap Group being unable to provide Services or other support to you in a timely manner.
2. Purposes for which Personal Data may be used
Personal Data may be used by the [Syncicap Group] for the following:
(i) daily operation of the Syncicap Group’s business, including the provision of Services to you relating to the investment or financial products and communicating with you;
(ii) maintenance and verification of particulars and data, including the investor registers, and related checks and ongoing administration including ascertaining whether you are a “professional investor” under the Securities and Futures Ordinance (as amended from time to time);
(iii) conducting product, service surveys and audit checks;
(iv) internal data processing, preparation of internal statistical reports, sales revenue reports and rebates/soft dollar arrangement analysis and any other reports;
(v) collection of fees and charges owed to the Syncicap Group (if applicable);
(vi) enabling any actual or potential assignee or participant or sub-participant of the rights of Syncicap to evaluate the transaction or intended transaction;
(vii) comparison with your Personal Data (irrespective of the purposes and sources for which such data were collected, and whether collected by a Specified Person (as defined in section 4 below) or any other person) for the purpose of: (i) data verification; and (ii) otherwise producing or verifying data which may be used for the purpose of taking such action that a Specified Person or any other person may consider appropriate (including action that may relate to the rights, obligations or interest of you or any other person);
(viii) researching, designing and launching financial and investment services or related products for clients;
(ix) conducting direct marketing activities as set out in section 3 below;
(x) meeting the requirements to make disclosures in accordance with the requirements of any applicable laws binding on or applicable to the Syncicap [Group], or as requested by any regulatory authority or an order of a court of any competent jurisdiction;
(xi) taking action to defend or protect the interests of the Syncicap [Group]; and
(xii) any other incidental and associated purposes relating to the above.
3. Use of Personal Data for Direct Marketing
We, [the] Syncicap [Group] intend to use Personal Data in direct marketing in the manner as described below and we require your consent (which includes an indication of no objection)* for that purpose.
The following Personal Data may be used for direct marketing:
(i) Company name, last and first name, contact information such as telephone and mobile number, email address and postal address, social media identity;
(ii) account information, portfolio information, transaction pattern and behaviour, financial background, occupation and demographic data.
Personal Data may be used for direct marketing of one or more of the following products or services offered or distributed by Syncicap: (i) financial and investment products or investment opportunities, (ii) distribution and nominee services, (iii) financial services, including without limitation, asset management and investment advisory services, and (iv) any other products or services directly related to the above.
If you do not wish us to use your Personal Data for use in direct marketing as described above, you may exercise your opt-out right.
Your Personal Data will not be disclosed and/or transferred by us to any third party outside of [the] Syncicap [Group]for direct marketing without your prior written consent.
If you do not wish us to use your Personal Data for direct marketing, please let us know by writing to our Data Protection Officer at the address sales@syncicap.com.*
* Please note that the requirement to obtain your consent and the right to make a request to cease the use of your Personal Data for direct marketing is not applicable to you if the direct marketing is addressed to you solely in your capacity as a representative of a company or business and is not sent to you in your individual or personal capacity.
4. To whom the Personal Data may be provided
For the purposes set out in section 2 above, [the] Syncicap [Group] may, in the course of conducting its business or to the extent necessary, provide Personal Data to the following parties, who may be based within or outside Hong Kong (collectively, “Specified Persons”):
(i) the holding companies of Syncicap, its subsidiaries, associated companies and affiliates;
(ii) directors, officers, employees, or any authorised persons of Syncicap and the entities set out in (i) above;
(iii) any agent, contractor or third party service provider who offers administrative, telecommunications, computer, payment or other services to Syncicap in connection with the operation of its business;
(iv) any other person provided that such person is under a duty of confidentiality to the Syncicap Group which has undertaken to keep such information confidential;
(v) any financial institution with which you have or propose to have dealings, provided that such financial institution is under a duty of confidentiality to Syncicap;
(vi) any legal or tax adviser, accountant, other financial or professional adviser to Syncicap;
(vii) any actual or proposed assignee of Syncicap’s business or transferee of Syncicap’s rights in respect of you; and
(viii) any government, regulatory body or other person to whom Personal Data is required to be disclosed in accordance with the requirements of any applicable laws binding on / applicable to the Syncicap Group, or an order of a court of any competent jurisdiction.
5. What rights do you have?
In accordance with the Ordinance you may:
(i) check whether [the] Syncicap [Group] holds Personal Data about you and gain access to such data;
(ii) require [the] Syncicap [Group] to correct any Personal Data relating to you which is inaccurate;
(iii) ascertain the Syncicap Group’s policies and practices in relation to Personal Data and be informed of the kind of Personal Data held by [the] Syncicap [Group]. In accordance with the Ordinance, [the] Syncicap [Group] has the right to charge a reasonable fee for the processing of any Personal Data access request. All requests for access to Personal Data or correction of Personal Data or for information regarding policies and practices and kinds of Personal Data held should be addressed as follows:
Data Protection Officer
To: Head of Sales
Address: 66/F, The Centre, 99 Queen’s Road Central, Hong Kong
Telephone: +852 38428200
E-mail: sales@syncicap.com
II. Cookies Policy
1. What is a “cookie”?
A cookie is a small computer file that is sent from a website to the computer or mobile phone (referred to here as a “device”) browser and stored in that device. Such website can send its own cookies to the browser but the browser only permits a website to access the stored cookies it has sent to the browser previously. Through cookies, the relevant website can recognise the device and customise the content or response to the browser. Cookies may persist or exist temporarily during a browsing session.
2. Use of cookies
When you browse the Syncicap Website, the Website may use a number of cookies files. We may use cookies for the purposes stated below. By accepting to enter this Website you agree to our Cookies Policy and that the Website may send cookies to your device in accordance with our Cookies Policy. In additional to our own cookies, we may also include third-party cookies to report usage statistics of our website and/or related services, and interact with third-party websites and/or platforms [as listed in the Third-Party Cookies List below].
3. Purpose of use of cookies
We may use cookies for the purposes of [improving your online experience and provide content that is relevant to you]. Syncicap might use cookies to remember your previously selected settings such as: [country, investor type and acceptance of our terms and conditions]. [Some cookies are essential to allow you to navigate the Website and the features available.]
Please note that no personal data is collected through cookies. The expiry dates for Syncicap cookies vary between one day and two years.
[The acceptance of use of cookies on the Website is automatic upon your entry to the Website. However, if you do not want Syncicap to place cookies on your device there are a number of options available to you. You can modify your own browser settings to either:
- reject all cookies
- only allow ‘trusted’ sites to write cookies or
- only accept cookies from www.syncicap.com
Should you delete your cookies history, this may affect your experience on our Website – the preferences selected on your previous visits to the site will not be remembered and you will have to reset these upon each visit to the site.]
4. Types of cookies
The only cookie is on the Disclaimer when entering the website and stored for 24 hours unless the browser is closed.
5. Third-Party Cookies List
- Google Analytics
