Delta Asia’s policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of your personal information and data (“Personal Data”) as set out in this Statement is in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”). All the terms used in this Section have the same meaning defined in the Ordinance and the Client Agreement.

When you apply and/or continue to subscribe for the Services, it may be necessary for you to provide Delta Asia with your Personal Data in connection with the opening or continuation of accounts and the establishment, subscription or continuation of Delta Asia service(s) and/or product(s) (the ” Services “) or compliance of any law or guidelines issued by regulatory or other authorities. If you fail to provide the Personal Data or the Personal Data is incomplete or incorrect, Delta Asia may not be able to provide or continue to provide the Services to you or comply with any law or guidelines issued by regulatory or other authorities.

1. Use of Personal Data

You agree that your Personal Data provided by you to Delta Asia may be used and retained by Delta Asia (whether before or after the termination of the Agreement) for the following purposes and for other purposes as shall be agreed between you and
Delta Asia or required by law from time to time:
(a) Processing of the application for the Services;
(b) Provision and daily operation of the Services;
(c) Conducting credit checks at the time of the Services subscription and upon periodic or special reviews;
(d) Analyzing, verifying and/or checking of your credit, payment and/or status in relation to the provision of the Services;
(e) Processing of any benefits arising out of or in connection with the Services;
(f) Processing of any payment instructions, direct debit facilities and/or credit facilities requested by you;
(g) Enabling the collection of amounts outstanding in your account(s) in relation to the Services;
(h) Marketing services, products and other subjects as described in Clause 3 of this Section;
(i) Assisting other institutions to conduct credit checks;
(j) Ensuring your ongoing credit worthiness;
(k) Improving, enhancing, designing or launching existing or new financial services or related products for your use;
(l) Determining the amount of indebtedness owed to or by you;
(m) Collection of amounts outstanding from you and those providing guarantee or security for your obligations;
(n) Enabling Delta Asia to meet the requirements to make disclosure under the requirements of any law or regulation
binding on Delta Asia;
(o) Facilitating us in complying with Delta Asia’ anti-money laundering obligations;
(p) Enabling Delta Asia to comply with any applicable code, guideline or industry practices and to discharge Delta Asia’ obligation to regulators or other authorities; and
(q) Purposes relating to any of the above.

2. Data Disclosure

Personal Data held by Delta Asia relating to you will be kept confidential but Delta Asia may disclose and transfer such Personal Data for the purposes mentioned in Clause 1 of this Section to the following parties (whether within or outside Hong Kong):
(a) any employee, agent, contractor or third party service provider who provides administrative, credit information, credit facility, debt collection, telecommunications, security support, computer, payment, trade execution, securities and/or contracts clearing or settlement or other services to Delta Asia in connection with the operation of its business;
(b) any other person under a duty of confidentiality to Delta Asia including any company within Delta Asia Group comprising Delta Asia Group Limited Company and its subsidiaries (“Delta Asia Group “) which has undertaken to keep such information confidential;
(c) any financial institution or dealer with which you has or proposes to have dealings;
(d) any credit reference agency and in the event of default, any debt collection agency;
(e) any of our actual or proposed assignees or transferees of our rights with respect to you;
(f) any person providing or proposing to provide guarantee or security for your obligations;
(g) any person, regulatory or authorities to whom Delta Asia is under an obligation to make disclosure under the requirements of any law binding on Delta Asia; and
(h) i) any member of Delta Asia Group;
ii) third party financial institution, securities, commodities and investment services providers;
iii) third party reward, loyalty, privileges or co-branding programme providers; and
iv) co-branding partners of Delta Asia (the names of such co-branding partners will be provided at the time of
making application for the relevant services and products, as the case may be).
Such Personal Data may be transferred to a place outside Hong Kong.

3. Use of Data as per Hong Kong Investor Identification Regime and Over-The-Counter Regime

You acknowledge and agree that we (Delta Asia Securities Limited), may collect, store, process, use, disclose and transfer personal data relating to you (including your CID and BCAN(s)) as required for us to provide services to you in relation to (i) securities listed or traded on the Stock Exchange of Hong Kong (SEHK) and (ii) an over-the-counter securities transaction for shares listed on the Stock Exchange of Hong Kong and also for complying with the rules and requirements of SEHK and the Securities and Futures Commission (SFC) in effect from time to time. Without limiting the foregoing, this includes –
(a) disclosing and transferring your personal data (including CID and BCAN(s)) to SEHK and/or the SFC in accordance with the rules and requirements of SEHK and the SFC in effect from time to time;
(b) allowing SEHK to: (i) collect, store, process and use your personal data (including CID and BCAN(s)) for market surveillance and monitoring purposes and enforcement of the Rules of the Exchange of SEHK; and (ii) disclose and transfer such information to the relevant regulators and law enforcement agencies in Hong Kong (including, but not limited to, the SFC) so as to facilitate the performance of their statutory functions with respect to the Hong Kong financial markets; and (iii) use such information for conducting analysis for the purposes of market oversight; and
(c) allowing the SFC to: (i) collect, store, process and use your personal data (including CID and BCAN(s)) for the performance of its statutory functions including monitoring, surveillance and enforcement functions with respect to the Hong Kong financial markets; and (ii) disclose and transfer such information to relevant regulators and law enforcement agencies in Hong Kong in accordance with applicable laws or regulatory requirements.
You also agree that despite any subsequent purported withdrawal of consent by you, your personal data may continue to be stored, processed, used, disclosed or transferred for the above purposes after such purported withdrawal of consent.

4. Use of Data in Direct Marketing

Delta Asia intends to use your Personal Data in direct marketing and Delta Asia requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
(a) your name, contact details, products and other services portfolio information, transaction pattern and behaviour, risk profile, financial background and demographic data held by Delta Asia from time to time may be used by Delta Asia in direct marketing;
(b) the following classes of services, products and subjects may be marketed;
i) financial, securities, commodities, investment and related services, products and facilities;
ii) reward, loyalty, privileges or any programme and related services, products and facilities; and
iii) services and products offered by Delta Asia’ co-branding partners (the names of such co-branding partners will be
provided at the time of making application for the relevant services, products and facilities, as the case may be);
(c) the above services, products and subjects may be provided or solicited by Delta Asia and/or;
i) any member of Delta Asia Group;
ii) third party financial institution, securities, commodities and investment services providers;
iii) third party reward, loyalty, privileges or co-branding programme providers; and
iv) co-branding partners of Delta Asia (the names of such co-branding partners will be provided at the time of
making application for the relevant services and products, as the case may be);
(d) in addition to marketing the above services, products and subject itself, Delta Asia also intends to provide data described in Clause 4 (a) of this Section to all or any of the persons described in Clause 4 (c) of this Section for use by them in marketing those services, products and subjects, and Delta Asia requires your written consent (which includes an indication of no objection) for that purpose.
If you do not wish Delta Asia to use or provide to other persons your Personal Data for use in direct marketing as described in Clause 3 of this Section, you may exercise your opt-out right by notifying Delta Asia in writing to our Data Protection Officer together with your name, address, contact information and account number(s) to the address provided in Clause 5 of this Section.

5. Access to and Correction of Personal Information

Under and in accordance with the Ordinance, you have the right to:
(a) Check whether Delta Asia hold any of your Personal Data;
(b) Access your Personal Data held by Delta Asia;
(c) Require Delta Asia to correct any Personal Data which is inaccurate;
(d) Ascertain our policies and practices (from time to time) in relation to Personal Data and the types of Personal
Data held by Delta Asia.
As provided in the Ordinance, Delta Asia have the right to charge a reasonable fee for the processing of any Personal Data access request. All requests for access to or correction of Personal Data or information regarding policies and practices and types of Personal Data held should be in writing and addressed to:

Data Protection Officer
Delta Asia Securities Limited
Delta Asia Financial Futures Limited
5th Floor, Luk Kwok Centre, 72 Gloucester Road, Wanchai, Hong Kong