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1.1       Wintone Securities Limited (“Wintone”) is committed to protect the personal data which the Client provides in accordance with the Personal Data (Privacy) Ordinance (“Ordinance”).


1.2       Unless otherwise stated, the Client must provide the personal data requested during the account opening process.  If the Client does not provide such data, it will not be possible for the Client to open an account with Wintone as Wintone will not have sufficient information to open and administer the Account.


2.        COLLECTION


From time to time, it is necessary for clients to provide Wintone with data (including “personal data” as defined in the Ordinance as amended from time to time) in connection with the establishment or continuation of business relationship, or provision of products or services by Wintone.  This may include but will not be limited to information obtained in relation to Client’s identity (name, date of birth, passport/identity card number, taxpayer identification number, address(es), marital status, education level and employment as well as information collected for the purposes of ascertaining Client’s financial profile, risk appetite, income (including sources of income) and net worth.  Failure to supply, or to allow Wintone to use or disclose such data may result in Wintone being unable to establish or continue the business relationship, or provide products or services.


3.        PURPOSES


The purposes for which personal data of a client may be collected, used and/or disclosed by Wintone (whether before or after the termination of Client’s relationship with Wintone) are set out as follows:


3.1            processing of applications for, administering, maintaining, managing and operating services and/or products provided to the Client or to other persons for whom Client acts as guarantor or for whom Client provides third-party security;

3.2            customer relationship management (including but not limited to loyalty programs or privileges and rewards schemes);

3.3            conducting, seeking or obtaining credit checks, matching procedures, data verification, due diligence and risk management;

3.4            assisting other financial institutions to conduct credit checks and collect debts;

3.5            ensuring Client’s or any surety’ ongoing creditworthiness;

3.6            maintaining Client’s or any surety’s credit history for present and future reference;

3.7            determining the amount of indebtedness owed to or by Client or any surety;

3.8            collecting of amounts outstanding form Client or any surety;

3.9            improving, enhancing, designing or launching existing or new financial services or related products for Client’s use (including, where appropriate, providing Client with financial advice);

3.10         any purpose relating to or in connection with compliance with any law, regulation, court order or order of any regulatory body;

3.11         seeking or obtaining administrative, telecommunications, computer, payment, debt collection or securities clearing, custodian, audit, banking, financing, insurance, business consulting, outsourcing, or other services to Wintone Group in connection with the operation of its business; and

3.12         any other lawful purposes directly or indirectly relating or incidental to any of the above.




Personal data of Client held by Wintone will be kept confidential but Wintone may, at its sole discretion, provide such data to the following persons and/or entities (whether within or outside Hong Kong) for any of the purposes set out in clause 3 above:


4.1            Wintone and/or any of its affiliates or subsidiaries or any member of the Wintone (“Wintone Group”), whether in Hong Kong or elsewhere;

4.2            Any director, officer or employee or agent of Wintone;

4.3            Any nominee or custodian in whose name securities or other property may be registered;

4.4            any agent, contractor or third party service provider (whether in Hong Kong or elsewhere) who provides administrative, telecommunications, computer, information technology, payment, debt collection or securities clearing, custodian, audit, banking, financing, insurance, risk management, business consulting, outsourcing, customer relationship management, marketing or other services to Wintone in connection with the operation of its business;

4.5            any credit reference agencies or, in the event of default, any debt collection agencies;

4.6            any person which has undertaken to Wintone to keep such data confidential;

4.7            any person acting or proposing to act as surety;

4.8            any financial institution with which the Client has or proposes to have dealings;

4.9            the drawee bank providing a copy of a paid cheque (which may contain information about the payee) to the drawer;

4.10         any actual or proposed assignee or transferee of Wintone;

4.11         any person or entity who has established or proposes to establish any business relationship with Wintone or the recipient of the data; and

4.12         any person in accordance with the Laws or Regulatory Rules including through or pursuant to any rules, judgment, decision or ruling of the courts, arbitral tribunals, financial Dispute Resolution Centre Limited, governmental, Inland Revenue Department of HKSAR and/or tax authorities of another countries, regulatory or other bodies or institutions, whether as required by the Laws and Regulatory Rules that are applicable to any member of the Wintone, or otherwise, or any company issuing a notice under section 329 of the Securities and Futures Ordinance.





Wintone intends to use your personal data in direct marketing and Wintone requires the Client’s consent (which includes an indication of no objection) for that purpose.  In this connection, please note that:


5.1       The name, age group, contact details (including phone number, residential/mailing address and email address), products and services portfolio information, transaction pattern and behavior, financial background and demographic data of a Client held by Wintone from time to time may be used by Wintone in direct marketing;

5.2       The following classes of services, products and subjects may be marketed:

(a)      financial, insurance, securities, investment related services and products as well as any associated promotional offers;

(b)     reward, loyalty or privileges programmes and related services and products;

(c)      services and products offered by Wintone’s co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be); and

(d)     donations and contributions for charitable and/or non-profit making purposes;

5.3       The above services, products and subjects may be provided or (in the case of donation and contributions) solicited by Wintone and/or:

(a)        Wintone and/or Wintone Group;

(b)       third party financial institution, securities and investment services providers;

(c)        third party reward, loyalty, co-branding or privileges programme providers;

(d)       co-branding partners services and products, as the case may be); and

(e)        charitable or non-profit making organizations;

5.4       in addition to the marketing the above services, products and subjects itself, Wintone also intends to provide the data described in clause 5.1 above to all or any of the persons described in paragraph 5.3 above for use by them in marketing those services, products and subjects and Wintone requires the Client’s written consent (which includes an indication of no objection) for that purpose;

5.5       If a Client does not wish Wintone to use or provide to other persons his/her data for use in direct marketing as described above, the Client may exercise his/her opt-out right by notifying the Data Protection Officer of Wintone in writing to the address provided below.




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


6.1       request access to his or her personal data;

6.2       request correction of any of his or her personal data which is inaccurate;

6.3       ascertain a data user’s policies and practices in relation to personal data;

6.4       be informed of the kind of personal data held by the data user;

6.5       be informed of the main purposes for which personal data held by the data user are or are to be used;

6.6       make data access request and data correction request through the channel set out below.


In accordance with the provisions of the Ordinance, Wintone has the right to charge a reasonable fee for processing any data access request.  Requests may be made in writing to the Privacy Officer at:


Wintone Securities Limited

             Unit 03, 9/F, Yue Xiu Building 160-174 Lockhart Road, Wan Chai, Hong Kong




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