Personal Information Collection Statement

The following Personal Data Privacy Statement is provided pursuant to the Personal Data (Privacy) Ordinance of Hong Kong (“Ordinance”) in connection with the provision of personal data or information (“Data”), to Fullgoal Asset Management (HK) Limited (“Fullgoal Asset Management”)  or its holding company and affiliates (together “Fullgoal Group”) from time to time. Fullgoal Asset Management is fully committed to protecting the privacy interests of individuals who provide us with information about themselves and to comply with the requirements of the Ordinance.

A. Collection:

1. From time to time, it is necessary for you to supply Fullgoal Group with Data in connection with various matters such as account opening or continuations, provision of services to you or compliance with any laws or guidelines issued by regulatory or other authorities.

2. The kinds of Data that may be collected includes, but is not limited to, name and address, occupation, contact details, date and country of birth, nationality, identity card, social security or national insurance numbers, country of tax residence, tax reference numbers or passport numbers, and details of financial status.

3. Failure to supply such Data may result in Fullgoal Group being unable to open an account or continue to provide services to you or unable to comply with any laws or regulations or guidelines and codes issued by regulatory or other authorities.

4. It is also the case that Data is collected from you in the ordinary course of the continuation of your relationship with Fullgoal Group, for example, when you open an account, write cheques, transfer funds, effect transactions, attend seminar/events, participate in online activities or generally communicate verbally or in writing with Fullgoal Group.

5. Additional Data may also be collected at Fullgoal Group’s websites which include, but is not limited to, the IP address of the visitor’s personal computer; the country from which the inquiry is made, certain personal or contact details of the visitor and client identification details..

B. Purpose and use:

1. The purposes for which Data may be used will vary depending on the nature of your relationship with Fullgoal Group. Fullgoal Group intends to use your Data (including any third party Data provided by you) for any or all of the following purposes:
   a) the processing of an application for an account with including confirming and verifying your identity;
   b) the daily operation of your account and the services to be provided to you; 
   c) any purpose related to the administration of the products and services offered by Fullgoal Group;
   d) researching, designing and launching financial, investment services or related products for clients;
   e) meeting the disclosure, reporting and compliance requirements (including but not limited to tax reporting) under any laws or regulations, codes, guidelines or internal Fullgoal Group compliance policies applicable to Fullgoal Group in Hong Kong or elsewhere;
   f) promoting and direct marketing of the services and products subject to your right to object to such use.

2. You have the right to object to the use of your Data for direct marketing purposes as set out in paragraph 1(f) above. Fullgoal Group will cease to use your Data for direct marketing purposes without charge if you so request.

C. Retention and Access:

1. The Data collected may be maintained for such period of time required under applicable law and as otherwise needed to fulfill the purposes set out above.

2. Data held by Fullgoal Group relating to you will be kept confidential and Fullgoal Group will take all reasonable measures to ensure that Data is kept secure against unauthorized access, loss, disclosure and destruction.  Fullgoal Group may provide such information to the following parties, whether inside or outside of Hong Kong, for the purposes set out in the “Purposes and use” section above:
   a) the ultimate holding company of Fullgoal Asset Management, its subsidiaries, representative offices, associated companies and/or affiliates as applicable;
   b) the service providers of Fullgoal Group including the trustee, investment manager, registrar, transfer agent, the custodian, administrative service agent, and the auditor of each product offered by Fullgoal Group; 
   c) any agent, contractor or third party service provider who provides administrative, research, design, launch, digital or telecommunication, clearing and settlement or other services to Fullgoal Group in connection with the operation of its business;
   d) the employees, officers, directors of Fullgoal Group;
   e) any party (including but not limited to, any local or foreign governmental, tax or regulatory authority or court of competent jurisdiction) entitled thereto by law or regulation or in response to a regulatory request; and
   f) external service providers of Fullgoal Group (including but not limited to printing houses, mailing houses, digital or telecommunication companies, data processing companies, storage companies, and information technology companies) that Fullgoal Group engages for the purposes set out in paragraph 1(f) in the “Purpose and Use” section above.

   Under the Ordinance, you have the right to:
   a) check whether Fullgoal Group holds Data about you, and access to such Data; 
   b) require Fullgoal Group to correct any Data relating to you which is inaccurate; 
   c) ascertain Fullgoal Group’s policies and practices in relation to data and to be informed of the kinds of Data held by Fullgoal Group; and 
   d) object to the use of your Data for direct marketing purposes and Fullgoal Group shall not use your Data for direct marketing purposes after you communicate your objection to Fullgoal Group. 

   In accordance with the terms of the Ordinance, Fullgoal Asset Management has the right to charge a reasonable fee for the process of any data request.

For access to your Data held by Fullgoal Group, correction of such Data, objection to use of your Data for direct marketing purposes or for information regarding policies and practices and kinds of Data held, please contact:

Head of Legal and Compliance
Fullgoal Asset Management (HK) Limited

Room 2404-5, Man Yee Building
68 Des Voeux Road Central, Hong Kong

Telephone: (852) 3713 3000

Fax: (852) 3713 3013

In order to deal with any such request, Fullgoal Asset Management may require evidence from you that you are the individual in respect of whom the request is made or a person permitted under the Ordinance to make the request on that individual’s behalf.

Nothing in this statement shall limit your rights under the Ordinance.