Keeping Your Information Secure
PERSONAL INFORMATION COLLECTION STATEMENT
Pursuant to the Personal Data (Privacy) Ordinance (the “Ordinance”), the following information is provided to you in connection with your dealings with and provision of data or information to Matthews International Capital Management, LLC, Matthews Global Investors (Hong Kong) Limited, Matthews Global Investors (Singapore) Pte. Ltd. Matthews Global Investors (UK) Ltd., [and/or their respective affiliated companies] (collectively referred to herein as the "Matthews Group"). Please be aware that this Statement replaces any notice or statement of similar nature that may have been provided to you previously. The Matthews Group is committed to maintaining your personal data in accordance with the requirements of the Ordinance and will take all reasonable steps to ensure that your personal data is kept secure against unauthorised access, loss, disclosure and destruction.
(a) From time to time, it is necessary for clients and various other individuals (“data subjects”) to supply the Matthews Group with data in connection with various matters such as account opening or continuations, or provision of services to clients and other individuals.
(b) Although it is not generally obligatory for a data subject to provide personal data, failure to supply such data may result in the Matthews Group being unable to accept and/or process an application for our products or services or continue services to clients and various other individuals or comply with any laws or guidelines issued by regulatory or other authorities.
(c) Data relating to the data subjects are collected or received by the Matthews Group from time to time in the ordinary course of the continuation of the Matthews Group's relationship with them, for example, when data subjects open account, write cheques, transfers funds, effect transactions, attend seminar/events or generally communicate verbally or in writing by data subjects with the Matthews Group.
(d) The purposes for which data relating to a data subject may be used will vary depending on the nature of the data subject's relationship with the Matthews Group. They may comprise any or all of the following purposes:
i. the processing of applications for an account with and/or other financial services provided by the Matthews Group;
ii. enabling the Matthews Group to ensure the daily operation of the services provided to the data subjects;
iii. promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in paragraph (e) below;
iv. providing alerts, newsletter and investment education materials requested/signed up by the data subjects;
v. designing and organising financial, investment seminars/events/forums;
vi. designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision of services by the Matthews Group;
vii. meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to the Matthews Group or any of its affiliates in Hong Kong or elsewhere from time to time;
viii. complying with any law binding or applying to the Matthews Group within or outside of Hong Kong existing currently and in the future, as well as any present or future contractual or other obligations or requirements with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities that is assumed by or imposed on the Matthews Group by reason of its financial, commercial or business activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities;
ix. any purpose related to the administration of the products offered by the Matthews Group or the data subject's participation therein; and
x. purposes directly related or incidental to the above, including seeking professional advices.
(e) USE OF DATA IN DIRECT MARKETING
The Matthews Group intends to use the data subject's data e.g. name, contact details - included in direct marketing only with respect to Matthews Group products or services it offers. The Matthews Group requires the data subject's consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
i. the name, contact details, web activity on the Matthews Asia website, transaction pattern and behaviour, financial background and demographic data of the data subject held or acquired by the Matthews Group from time to time may be used by the Matthews Group in direct marketing; and
ii. the following classes of services, products and subjects may be used in direct marketing as described above: (1) financial, investment, securities, and other related services and products that the Matthews Group offers; and (2) invitations to financial and investment seminars/events/forums.
(f) Data collected may be maintained for such period as may be required under applicable laws or as otherwise needed to fulfill any of the purposes set out in paragraph (d) above.
(g) Data held by the Matthews Group relating to a data subject will be kept confidential but the Matthews Group may provide such information to the following parties whether inside or outside Hong Kong for the purposes set out in paragraph (d):
i. Matthews Group, its subsidiaries, representative offices and/or affiliates of the Matthews Group;
ii. the service providers of the Matthews Group including the registrar, transfer agent, the custodian, administrative service agent, share distributors, securities and investment service providers and the auditor of each products offered by the Matthews Group;
iii. any agent, contractor or third party service provider who provides administrative, research, design, launch, telecommunications, printing, mailing, computer, payment, securities clearing and settlement or other services to the Matthews Group in connection with the operation of its business;
iv. the intermediaries of the Matthews Group including third party financial institutions (e.g. banks, Independent Financial Advisors, insurers), third party product issuers, correspondent banks which may handle or process payment to/from data subjects;
v. the employees, officers, directors and agents of the Matthews Group;
any party (including but not limited to, any regulatory authorities, governmental authorities, tax, law enforcement authorities) entitled thereto by law or regulation (whether statutory or not);
vii. (1) the Matthews Group; and (2) external service providers (including but not limited to public relation companies, data processing companies, market research firms, and information technology companies), that the Matthews Group engages for the purposes set out in paragraph (e).
(h) Under the Ordinance, any individual has the right:
i. to check whether the Matthews Group holds data about him or her, and of access to such data;
ii. to require the Matthews Group to correct any data relating to him or her which is inaccurate;
iii. to ascertain the Matthews Group's policies and practices in relation to data and to be informed of the kind of personal data held by the Matthews Group;
iv. to object to the use of his/her personal data for direct marketing purposes and the Matthews Group shall not use his/her personal data for marketing purposes after he/she communicates his/her objection to the Matthews Group.
(i) In accordance with the terms of the Ordinance, The Matthews Group has the right to charge a reasonable fee for the processing of any data access request.
(j) You may exercise your opt-out right of ongoing communications by checking the opt-out box on the Matthews Group website, or by notifying the Matthews Group if you wish to object to the use of your personal data for direct marketing purposes. The person to whom such objections, requests for access to data, correction of data or for information regarding policies and practices and kinds of data held are to be addressed as follows:
The Data Privacy Officer
Matthews Global Investors (Hong Kong) Limited
Suite 3602 Two Pacific Place
88 Queensway Admiralty, Hong Kong
(k) Nothing in this Statement shall limit the rights of the data subject under the Personal Data (Privacy) Ordinance.
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