Privacy Notice

This Privacy Notice describes how you interact either directly or indirectly with Anchorpoint Financial Limited or any of its subsidiaries from time-to-time (“Anchorpoint”, “we”, “us” or “our”) in relation to Anchorpoint’s collection, usage, storage, sharing and protection your personal data (“Personal Data”).

You have the option of whether to provide us with your Personal Data. If you refuse to provide your Personal Data, we may not be able to provide you with services and/or perform any of the contractual obligations that we entered with you since your Personal Data may be needed for us to perform such obligations, including undertaking necessary KYC steps and/or to complying with certain legal requirements.

As we may make changes to this policy from time to time, such as to take into account changes to our standard practices and procedures or where necessary to comply with applicable law, it is important that you check from time to time for newer versions of this Privacy Notice. We will also inform you of any material changes.

In addition, it is important that the Personal Data we have from you is accurate and up to date. Let us know if your Personal Data changes. From time to time, we may also ask you to confirm whether there have been any changes, including as part of our ongoing KYC obligations.

1. The Personal Data We Collect

We collect and process some or all of the following Personal Data about you:

1.1 Your identity data, such as, your full name, user name, title, date of birth, gender, biometric information, national identity information, identity document type and number that we require to verify your identity and other business and operational functions; and

1.2 Your social identity data, such as, your group/company data, information on referrals related to you, behavioral data, risk assessment data, KYC & compliance assessment data.

2. Use of Your Personal Data

We may use your Personal Data for any of the following purposes:

2.1 considering and processing your application(s) (including assessing the merits and/or suitability of your application(s)) for Anchorpoint products and services;

2.2 provisioning, developing, improving and designing our products and services;

2.3 meeting our internal operational requirements (including credit and risk management, system or product development and planning, carrying out testing and analysis and insurance, audit and administrative purposes);

2.4 marketing services, products and other subjects;

2.5 responding to inquiries or managing complaints, including monitoring social media platforms to identify relevant conversations, sentiments, and complaints about Anchorpoint;

2.6 recording our communications including online messages, emails, and telephone calls for record-keeping and evidential purposes; and

2.7 meeting or complying with any obligations, requirements or arrangements for disclosing and using data that apply to us, including those that we or any such member is expected to comply with according to:

(A) any present or future law or regulation within or outside Hong Kong;
(B) any present or future guidelines or guidance 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;
(C) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers applicable to us by reason of its financial, commercial, business or other interests or activities in or related to the relevant jurisdiction (each an “Authority”); or
(D) any investigation, demand or request from an Authority.

3. How We Collect Your Personal Data

3.1 We will collect some of your Personal Data from you directly, such as, while visiting our website(s) applying for our Services, creating an account with us, using the Services, subscribing to our newsletters, through social media channels, entering competitions, promotions or filling out surveys provided by us, and providing feedback to us.

3.2 We may also collect your Personal Data about your equipment, browsing actions and patterns while you interact with us via our website(s) or app(s). We collect these Personal Data by using cookies, server logs and other similar technologies.

3.3 We also obtain Personal Data about you from third parties, such as, fraud and crime prevention agencies, customer referral, public blockchain, and information in the public domain.

3.4 In some cases we may be required by applicable laws or regulations to collect certain types of Personal Data about you.

3.5 We will generally collect the Personal Data by ourselves without the help of third parties. However, in some cases we may collect Personal Data from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us.

4. Direct Marketing

4.1 We may from time to time communicate to you with promotional and marketing materials and information based on the Personal Data that you provided to us. We may use your Personal Data in direct marketing, and we require your consent to indicate no objection for that purpose.

4.2 You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal Data for direct marketing purposes by following the opt-out instructions contained in the relevant communications.

4.3 We may provide your Personal Data to our affiliates, subsidiaries and service providers for use of marketing and we require your written consent to indicate no objection.

4.4 If you have any question or complaint related to our direct marketing, please contact us using the Contact details section of this Privacy Notice.

5. Disclosure of Your Personal Data

The Personal Data we hold is kept confidential but we may provide, transfer or disclose such data or information to other parties (whether within or outside Hong Kong):

5.1 any organisation, agent, contractor or third party service provider who provides administrative, telecommunications, identity verification/know-your-customer, computer, payment/transaction, cloud storage or services, data analytics, cybersecurity or securities clearing, securities broking and custody, or other services to us in connection with the establishment, operation, maintenance or provision of any of our products or services to you; and

5.2 government authorities who ask us to disclose that information, or to other people as required by applicable laws or regulations. This may include Hong Kong regulators including the HKMA, SFC and Hong Kong Police Force (HKPF), as well as other regulator(s) in Hong Kong and overseas.

We may also collect, use, disclose or transfer your personal data to other organisations in accordance with your requests or instructions. In some cases, the people to whom we disclose or transfer your information may be located outside of Hong Kong. Whenever we transfer your Personal Data out of Hong Kong, we will ensure that appropriate contractual safeguards are in place pursuant to the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong).

6. Personal Data of Another Person

Where you have provided us with another person’s personal data, you should provide him/her with a copy of this Privacy Notice and inform them of how we may use his/her data.

7. Security of Your Personal Data

7.1 Once we receive your Personal Data, we’ll do our best to protect it because the security of your Personal Data is important to us. We have technical and organisational security measures in place to safeguard your Personal Data (including Personal Data in transit and storage). These security measures ensure that the confidentiality and integrity of your Personal Data is not compromised. Multiple layers of protection have been put in place to protect against leakage of Personal Data to external parties. When using external service providers, we require that they adhere to certain security standards mandated by us. We may do this through contractual provisions, including any such provisions approved by a privacy regulator, and oversight of the service provider. Regardless of where Personal Data is transferred, we take all steps reasonably necessary to ensure that Personal Data is kept securely.

7.2 You should also be aware that the internet (including applications which use the internet for data transfer) may not be a secure form of communication and sending us Personal Data over the internet may carry with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when the sender and recipient are located in the same country) via countries with weaker privacy and data protection laws.

8. Retention of Your Personal Data

We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other purpose (for example, where we are required to retain Personal Data for longer than the purpose for which we originally collected it in order to comply with certain legal or regulatory requirements). Our retention periods are based on our business needs and for the purpose of complying with specific legal and regulatory requirements and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.

9. Your Rights

You have a number of rights in relation to the personal data that we hold about you. These rights are subject to certain exemptions. To exercise these rights, please contact us using the Contact details section of this Privacy Notice.

9.1 Request access to your Personal Data

You have the right to access any of the Personal Data that we hold about you and you have the right to be informed about the processing of your Personal Data.

To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality.

9.2 Rectification of your Personal Data

If the Personal Data that we hold about you is inaccurate, you have the right to have that data rectified.

Even if you do not request access to and/or correct your Personal Data held by us, if we are satisfied that, having regard to the reasons for which we hold your Personal Data, that Personal Data is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.

9.3 Restriction of use of your Personal Data

You may also request that we restrict the processing of that Personal Data. However, we may not be able to provide you the Services and/or perform any of the contractual obligations that we entered with you due to this request.

9.4 Deletion of Your Personal Data

In the majority of cases, we will keep your Personal Data for seven (7) years from the end of your relationship with us. You can ask us to delete some or all of your data earlier than this but we can only do so if:

(A) we have no legal or regulatory obligation to retain it; or
(B) we don’t need it to provide a service that you would still like us to provide to you.

If we can’t delete your data promptly after you ask us, please be sure that we’ll let you know.

9.5 Complaints

If you are concerned about the way in which we are managing your Personal Data and think we may have breached any applicable laws or regulations, or any other relevant obligation, please contact us using the Contact details section of this Privacy Notice.

10. Contact

If you have any question or complaint related to this Privacy Notice or our privacy practices, or if you wish to exercise your rights granted to you under this Privacy Notice and/or applicable law, please contact our Data Protection Officer at dpo@anchorpoint.hk.