Personal Information Collection Statement

This statement is provided to the Client as an individual account holder of the Company in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”). Terms defined in this statement have the same meaning as in the Client Agreement.

  1. Disclosure Obligation

Unless otherwise stated the Client must supply the personal data requested on the enclosed Client Information Statement to Sorrento Securities Ltd. If the Client does not supply this data, it will not be possible for the Client to open an Account with the Company as the Company will not have sufficient information to open and administer the Account.

  1. Use of Personal Data

2.1     Users

All personal data concerning the Client (whether provided by the Client or any other person, and whether provided before or after the date the Client receives the Client Agreement containing this information) may be used by any of the following companies or persons (each, a “User”):

(a)      Sorrento Securities Ltd and/or any of the holding companies/subsidiaries associated with Sorrento Securities Limited (“the Group”);

(b)      any director, officer or employee or the agent of the Group;

(c)      any person (such as lawyers, advisers, nominee, custodian etc.) authorized by the Group when carrying out the Client’s Instructions and/or the business of the Group;

(d)      any actual or proposed assignee of any rights and obligations of the Group in relation to the Client;

(e)      any governmental, regulatory or other bodies or institutions, whether as required by law or regulations applicable to any member of the Group; and

(f)       any banks, financial institutions or brokers and insurance agents who are business partners, associates or related parties of the Group for the provision of investment products or services.

2.2     Purposes

All personal data concerning the Client may be used by any User for the following purposes:

(a)      carrying out new or existing client verification and credit checking procedures and assisting other financial institutions to do so;

(b)      ongoing Account administration, including the collection of amounts due, enforcement of security, charge or other rights and interests;

(c)      designing or marketing further products and services to the Client, including but not limited to the products/services of the Group or products/services provided by a broker or issuer authorized by or related to the Group;

(d)      transfer of such data to any place outside of Hong Kong;

(e)      comparison with the Client’s personal data (irrespective of the purposes and sources for which such data were collected, and whether collected by a User or any other person) for the purpose of: (A) credit checking; (B) data verification; and/or (C) otherwise producing or verifying data which may be used for the purpose

of taking such action that a User or any other person may consider appropriate (including action that may relate to the rights, obligations or interest of the Client or any other person);

(f)       providing on the terms of any other agreements and services relating to the Client;

(g)      any purpose relating to or in connection with compliance with any law, regulation, court order or order of any regulatory body; and

(h)      any other purpose relating to the execution of the Client’s instructions or in connection with the business or dealings of the Company.

2.3     Use of Data in Direct Marketing

The Group intends to use and/or transfer the Client’s data to any related companies of the Group for direct marketing and the Group requires the consent (which includes an indication of no objection) of the Client for that purpose. In this connection, please note that:

(a)      your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by the Group from time to time may be used by the Group in direct marketing;

(b)      the following classes of services, products and subjects may be marketed:

  1. securities, commodities, investment, insurance and related services and products;
  2. reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to in clause 2.3(b)(i) above; and
  3. donations and contributions for charitable and/or non-profit making purposes.

(c)      If client does not wish SORRENTO to use his/her data for use in direct marketing, client may exercise his/her opt-out right by notifying SORRENTO at any time and without charge. (To opt-out, please send your request to our customer services with your account number, phone number or other contact information by email, fax (852) 3959-9819 or post to 11/F, The Wellington, 198 Wellington Street, Central, Hong Kong)

  1. Rights of Access and Correction

The Client has the right to have access to and correction of the Client’s personal data as set out in the Ordinance. In general, and subject to certain exemptions, the Client is entitled to:

(a)      enquire whether Sorrento Securities Ltd. holds personal data in relation to the Client;

(b)      request access to the Client’s personal data within reasonable time, at a fee which is not excessive, in a reasonable manner and in a form that is intelligible;

(c)      request the correction of the Client’s personal data; and

(d)      be given reasons if a request for access or correction is refused, and object to any such refusal.

  1. Contact Person

If the Client wishes to request access to and/or correction of personal data concerning the Client, the Client should address the Client’s request to the Data Protection Officer at the Company.