The Personal Information Collection Statement ("PICS") is made in accordance with the guidelines issued
by the Office of the Privacy Commissioner for personal data. The Company, namely Blue Concept Asia
Limited (“BCA”), is committed to ensuring that your privacy is protected according to the
Personal Data (Privacy) Ordinance (“PDPO”) of Hong Kong.
The PICS sets out the
policies and practices of BCA– with effective dated from 1 January 2020 – with regard to
certain information by which you can be identified (“Personal Data”) and what you are
agreeing to with respect to BCA’s use of your personal data for the purposes identified below.
The Personal Data which BCA will collect from you may include:
• From the information you provide to BCA when you meet its representatives;
• From
information about you provided to BCA by your company or an intermediary;
• When you
communicate with BCA by telephone, fax, email, or other forms of electronic communication. In this
respect, BCA may monitor, record and store any such communication;
• When you complete (or BCA
completes on your behalf) client on-boarding or application or other forms;
• From other
companies and/or associates within BCA’s organization;
• From your agents, advisers,
intermediaries, and custodians of your assets;
• From publicly available sources or from third
parties, most commonly where BCA needs to conduct background checks about you.
The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with.
The Personal Data provided by you will be used by BCA for one or more of the following purposes:
• Your name and contact information such as your home or business address, email address and
telephone number;
• Biographical information which may confirm your identity including your
date of birth, tax identification number and your passport number or national identity card details,
country of domicile and/or your nationality;
• Information relating to your financial
situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank
account details;
• Information about your knowledge and experience in the investment
field;
• An understanding of your goals and objectives in procuring BCA’s
services;
• Information about your employment, education, family or personal circumstances,
and interests, where relevant; and
• Information to assess whether you may represent a
politically exposed person or money laundering risk.
The basis for processing your personal data
(other than with your consent), how BCA uses that personal data and whom BCA share it with.
BCA processes your personal data because it is necessary for the performance of a contract to which you
are a party or in order to take steps at your request prior to entering into a contract.
In this
respect, BCA will use your personal data for the following:
• To prepare a proposal for you regarding the services BCA offers;
• To provide you with
the services as set out in our Terms of Engagement with you or as otherwise agreed with you from time to
time;
• To deal with any complaints or feedback you may have;
• For any other
purpose for which you provide BCA with your personal data.
In this respect, BCA may share your
personal data with or transfer it to the following:
• Your agents, advisers, intermediaries,
and custodians of your assets who you tell BCA about;
• Third parties whom BCA engages to
assist in delivering the services to you, including other companies within BCA’s
organization;
• BCA’s professional advisers where it is necessary for BCA to obtain
their advice or assistance, including lawyers, accountants, IT or public relations advisers;
•
Other third parties such as intermediaries who BCA introduces to you. BCA will wherever possible tell
you who they are before introduced you;
• BCA’s data storage providers.
BCA also processes your personal data because it is necessary for its legitimate interests, or sometimes
where it is necessary for the legitimate interests of another person.
In this respect, BCA will
your personal data for the following:
• For marketing to you. In this respect, see the separate section on Marketing as outlined in the
Data Privacy Police (Sec. 4 – Marketing);
• Training its staff or monitoring their
performance;
• For the administration and management of its business, including recovering
money you owe to BCA, and archiving or statistical analysis;
• Seeking advice on its rights
and obligations, such as where BCA requires its own legal advice;
In this respect, BCA will share
your personal data with the following:
• Its advisers or agents where it is necessary for BCA
to obtain their advice or assistance;
• ith third parties and their advisers where those
third parties are acquiring, or considering acquiring, all or part of our business.
BCA will also process your personal data for its compliance with a legal obligation which BCA is
under.
In this respect, BCA will use your personal data for the following:
• To meet its compliance and regulatory obligations, such as compliance with anti-money laundering
and counter-terrorist financing laws;
• As required by tax authorities or any competent court
or legal authority.
In this respect, BCA will share your personal data with the
following:
• Its advisers where it is necessary for BCA to obtain their advice or
assistance;
• Its auditors where it is necessary as part of their auditing
functions;
• With third parties who assist BCA in conducting background checks;
•
With relevant regulators or law enforcement agencies where BCA is required to do so.
Any personal
data collected from you will only be used for the specific purposes mentioned at the time of collection.
Failure to provide the requested personal data may result in the BCA being unable to process your
application, admission, or other purposes.
BCA will not sell, distribute, release, or disclose your Personal Data to any third party unless BCA has
your permission or is required by law to do so. BCA may use your personal data to send you promotional
information about third parties which the BCA thinks you may find interesting, unless you tell us that
you do not wish this to happen.
When processing your personal data as set out in this Data Privacy
Policy, as we are located in Hong Kong, it will have been transferred outside the European Union.
However, if your personal data is originally collected from within the EU it will only be transferred on
one of the following bases:
• the country that we send the personal data to is approved by the European Commission as providing
an adequate level of protection for personal data;
• the transfer is to a recipient in the
United States of America who has registered under the
• EU/US Privacy Shield;
• the
recipient has entered into European Commission standard contractual clauses with us; or
• you
have explicitly consented to the same.
You may request details of Personal Data which we hold about you under the Personal Data (Privacy) Ordinance of Hong Kong. If you would like to get a copy of the Personal Data held about you, please write to Blue Concept Asia Limited, Unit B, 5/F, Winning Centre, 46-48 Wyndham Street, Central, Hong Kong. BCA has the right to charge a reasonable fee for processing any data access request.
If you believe that any information, we are holding about you is incorrect, incomplete, or outdated, please write to, or email, us as soon as possible at the above address. We shall update your Personal Data as soon as practicable.
BCA may change the PICS from time to time by updating this page. You should check this page as and when deemed necessary to keep abreast of the latest changes, if any.