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Privacy Policy Statement

Bond Connect Company Limited (“BCCL” , “we”, “our” or “us”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. Personal data will be collected from time to time in accordance with this Privacy Policy Statement.

This Privacy Policy describes how BCCL collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Policy applies to all users to PMIP, ePrime system, E-filing system, CNYplus system, and its associated sites and microsites accessed through the systems. (collectively “the systems”)

We regularly review this Privacy Policy Statement and may from time to time, without limitation, revise its terms. In relation to personal data supplied to us through the BCCL’s website or otherwise, continued use by you of the BCCL’s website or your continued relationship with us, including where you act on behalf of an entity who is or is applying to become an eligible foreign investor of the Northbound Bond Connect Scheme (“Bond Connect”) or a participant of the Northbound Swap Connect Scheme (“Swap Connect”) (“Investor”), shall be deemed to be your acceptance of and consent to this Privacy Policy Statement, as amended from time to time.

If you have any questions about this Privacy Policy Statement or how we use your personal data, please contact us through our Personal Data Protection Officer (details in "Contact Us" module below) or one of the communication channels set out in the “Contact Us” section in BCCL’s website.

We will take all practicable steps to ensure the security of the personal data and to avoid unauthorised or accidental access, erasure or other use. This includes physical, technical, and procedural security methods, where appropriate, to ensure that the personal data may only be accessed by authorised personnel.

Please note that if you do not provide us with your personal data (or the relevant personal data of person(s) by whom you have appointed to act for you), we may not be able to provide the information, or services that you (or the Investor) have asked for or process your (or the Investor’s) requests, subscriptions, registrations, or applications to admit as an eligible foreign investor in Bond Connect or a participant of Swap Connect, and we may not be able to perform or discharge the Regulatory Functions (defined below).

What Personal Data do we collect and how do we collect it?

The Company will collect and store any information you enter the website, or the systems operated by the Company, including, but not limited to, your name, gender, date of birth, e-mail address, address, location, etc. The Company may also legally obtain personal or non-personal data of you from our affiliates. The Company may also collect some information about your computer or other devices used when you visit this website and the systems operated by the Company.

If you use any social media features or platforms, either through our website, or otherwise through a social media provider, the Company may review and collect information about you through relevant social media providers in accordance with their policies. When using social media features, the Company may review your social media profile or account selection to provide, including but not limited to your name, gender, birthday, email address, address, location etc. The access to this information by the Company may be limited or blocked based on your privacy settings with the relevant social media provider.

Identity Card Number

We may also collect your identity card number and process this as required under applicable law or regulation, as required by any regulator having authority over us and subject to the PDPO, for the purposes of identifying you where it is reasonable for your identity card number to be used for this purpose.

Sensitive Personal Data

Some Personal Data that we process is classified as “Sensitive Personal Data” under applicable data protection laws.  What is considered Sensitive Personal Data varies by jurisdiction. If we are required to process Sensitive Personal Data, we will only do so in accordance with applicable law, and with your consent to the extent required under applicable data protection laws.      

The purposes for which we use your personal data

From time to time, we may collect your personal data including but not limited to your name, mailing address, telephone number, email address, date of birth and login name for the following purposes:

  1. processing your applications or subscriptions for our services, or the Investor’s application to participate as an eligible foreign investor of Bond Connect or as a participant of Swap Connect;
  2. performing or discharging our functions as a person authorized to provide automated trading services under Part III of the Securities and Futures Ordinance ("Regulatory Functions");
  3. treating you as a contact person for the Investor, if applicable;
  4. providing you (or the Investor) with our services, including operating and developing the Bond Connect, Swap Connect or other applicable services and providing services relating to clearing settlement or hedging, and if applicable, administer your account(s) in relation to our services;
  5. researching and/or designing new services and/or revamping any of our existing services;
  6. conducting research, statistical analysis and internal study;
  7. processing your application for employment or engagement with BCCL to assess your suitability as a candidate for such position and to conduct reference checks with your previous employers; and
  8. other purposes directly relating to any of the above.
Direct marketing

Direct marketing is usually not applicable to the setting of Bond Connect, Swap Connect or other services we provide to institutional investors, including without limitation the Investor. Where applicable and where you have given your consent and have not subsequently opted out, we may also use your name, mailing address, telephone number and email address to send promotional materials to you (or the Investor) and conduct direct marketing activities in relation to BCCL’s services, and the products or services offered by any entity affiliated with BCCL.

If you do not wish to receive any promotional and direct marketing materials from us or do not wish to receive particular types of promotional and direct marketing materials or do not wish to receive such materials through any particular means of communication, you may withdraw your consent to the use and provision to a third party of your personal data for direct marketing purposes at any time, and thereafter the Company shall, without charge to you, cease to use such data for direct marketing purposes. If you wish to withdraw your consent, please contact the Company's Personal Data Protection Officer (details in "Contact Us" module below) or one of the communication channels set out in the "Contact Us" section of our website. To ensure that your request can be processed quickly please provide your full name, email address, log in name and details of the service you have subscribed.

Do we disclose Personal Data to third parties or transfer it to another jurisdiction?

Transfers of personal data for direct marketing purposes

Where you have given your consent, we may transfer your name, mailing address, telephone number and email address to any entity affiliated with BCCL for the purposes of enabling those affiliates to send promotional materials to you and conduct direct marketing activities in relation to their products or services.

Other transfers of your personal data

For one or more of the purposes specified above, your personal data may be:

  1. transferred to our affiliates (including but not limited to CFETS) in Hong Kong or elsewhere and in this regard you consent to the transfer of your data outside of Hong Kong;
  2. transferred back to us in its original form or any other form upon processing from our affiliates (including but not limited to CFETS) in Hong Kong or elsewhere and in this regard you consent to the transfer of your data back to Hong Kong
  3. supplied to any agent, contractor or third party who provides administrative, telecommunications, computer, payment, debt collection, data processing or other services to the BCCL, whether in Hong Kong or elsewhere; and
  4. other parties as notified to you at the time of collection.
How long do we keep the Personal Data?

Personal Data is retained in accordance with our internal policies and applicable law.

Your Personal Data will be retained by us for as long as is necessary to fulfil the purposes required for the processing. We will also refer to the following factors when determining or confirming the appropriate retention period of Personal Data:

  • ž the original purpose of collection
  • ž the termination of any contract involving the Data Subject’s Personal Data
  • ž the limitation period as defined in the applicable law
  • ž the existence of any legal or regulatory investigations or legal proceedings
  • ž specific laws or regulations setting out BCCL’s functions, obligations, and responsibilities
  • ž retention period set out in non-statutory guidelines issued by our regulators or international bodies
  • ž the sensitivity of the Personal Data and the degree of risk from the associated processing activity
Further details of our Personal Data retention period may be obtained upon request to the address in the “Contact Us” section below.

Where  any Personal Data is no longer necessary for the purposes for which it is collected, we shall cease the processing of that Personal Data as soon as reasonably practicable (although copies may be retained as necessary for archival purposes, for use in any actual or potential dispute, or for compliance with applicable laws), and take reasonable measures to destroy the relevant Personal Data.

How we use cookies

If you access our information or services through the BCCL’s website, you should be aware that cookies are used. Cookies are data files stored on your browser. The BCCL’s website automatically installs and uses cookies on your browser when you access it. Two kinds of cookies are used on the BCCL’s website:

Session Cookies: temporary cookies that only remain in your browser until the time you leave the BCCL’s website, which are used to obtain and store configuration information and administer the BCCL’s website, including carrying information from one page to another as you browse the site so as to, for example, avoid you having to re-enter information on each page that you visit. Session cookies are also used to compile anonymous statistics about the use of the BCCL’s website.

Persistent Cookies: cookies that remain in your browser for a longer period of time for the purpose of compiling anonymous statistics about the use of the BCCL’s website or to track and record user preferences.

The cookies used in connection with the BCCL’s website do not contain personal data. You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software. However, if you do so you may not be able to utilise or activate certain functions available on the BCCL’s website.

Compliance with laws and regulations

The BCCL may be required to retain, process and/or disclose your personal data in order to comply with applicable laws and regulations or in order to comply with a court order, subpoena or other legal process (whether in Hong Kong or elsewhere), or to comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong or elsewhere) or to perform or discharge the Regulatory Functions. The BCCL may need to disclose your personal data in order to enforce any agreement with you, protect our rights, property or safety, or the rights, property or safety of our employees, or to perform or discharge the Regulatory Functions.

Corporate reorganization

As we continue to develop our business, we may reorganise our group structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate our business or a similar service under either this Privacy Policy Statement or a different privacy policy statement which will be notified to you. Such a third party may be located, and use of your personal data may be made, outside of Hong Kong in connection with such acquisition or reorganisation.

Access and correction of personal data

Under the PDPO, you have the right to ascertain whether we hold your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request us to inform you of the type of personal data held by us. All data access requests shall be made using the form prescribed by the Privacy Commissioner for Personal Data ("Privacy Commissioner") which may be found on the official website of the Office of the Privacy Commissioner or via this link: https://www.pcpd.org.hk/english/publications/files/Dforme.pdf

Requests for access and correction of personal data or for information regarding policies and practices and kinds of data held by us should be addressed in writing and sent by post to our Personal Data Protection Officer (details in "Contact Us" module below) or make a request through the the “Contact Us” section in our website.

A reasonable fee may be charged to offset our administrative and actual costs incurred in complying with your data access requests.

Termination or cancellation

Should your account or relationship with the BCCL and/or CFETS (whether you are acting on behalf of the Investor) be cancelled or terminated at any time, we shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that we may keep copies of your data as is reasonably required for archival purposes, for use in relation to any actual or potential dispute, for the purpose of compliance with applicable laws and regulations and for the purpose of enforcing any agreement we have with you, for protecting our rights, property or safety, or the rights, property or safety of our employees, and for performing or discharging any of our  functions, obligations and responsibilities.

Minors

As our website and the systems we operate are not aimed at children, we only knowingly process Personal Data of minors when they visit our premises. If we discover that processing has taken place in any other circumstances, then we shall ensure it has occurred with a Lawful Basis or otherwise cease the processing and make reasonable efforts to dispose of the Personal Data in accordance with our internal policies.

General

If there is any inconsistency or conflict between the English and Chinese version of this Privacy Policy Statement, the English version shall prevail.

Contact us

Bond Connect Company Limited: Personal Data Protection Officer
Address: 4701,47/F, Two Exchange Square, 8 Connaught Place, Central, Hong Kong
Tel: (852) 2327 0033
Fax: (852) 2327 0987
Email: Dataprivacy@chinabondconnect.com

Last updated on 7 May 2024