Income Partners Asset Management (HK) Limited (“IPAM”) and its employees are committed to protecting your privacy and to safeguarding that information in accordance with applicable laws and regulations, including the European General Data Protection Regulation (EU 2016/679) and the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486, laws of Hong Kong SAR).
Our Data Collection Methods
We may collect personal data pursuant to know-your-client and/or anti-money laundering related requests, a website or client account, any legal agreements, checklists, forms (including subscription forms and Foreign Account Tax Compliance Act / the Common Reporting Standard forms), and in any other documentation provided by us or IPAM’s service providers (including administrators and custodians) and completed by our customers in connection with or ancillary to asset management, investment advisory, registration, tax reporting, licensing or other related matters or services.
In addition to the foregoing, we may also collect your personal data (such as understanding your investment objectives, risk tolerances, product preferences or any other personal data) through telephone conversations and electronic (including e-mail) communications.
We may outsource data collection to service providers, including any law or accounting firms, administrators and custodians.
Legal Basis and Purposes for Collecting Your Personal Data
The primary legal basis for collecting your personal data is to enable us to provide asset management and advisory services to our clients in compliance with applicable legal and regulatory requirements. This includes complying with relevant customer or vendor due diligence, know-your-client or any anti-money laundering requirements, as well as any tax, regulatory codes of conduct, guidance or circulars published by regulatory authority with oversight over our operations.
Your Consent to Collection, Processing, Storage and Transfer to Third Parties
By providing personal data in connection with the foregoing Data Collection Methods, you are providing us with express consent to collect, process, store and transfer your data in accordance with this policy. In addition, for certain personal data, in particular for Foreign Account Tax Compliance Act or Common Reporting Standard forms, any information (including personal data) you provide in those forms will be reported to relevant tax authorities in compliance with our tax reporting obligations. We are also required to report breaches of personal data to regulatory authorities. Sharing of your Personal Data to third parties will be limited and set out below.
Sharing of Personal Data to certain Third Parties Which May be Located Outside Your Country / Region
IPAM is committed to the protection and privacy of personal data. IPAM may transfer your personal data outside Hong Kong, United States or European Union to Hong Kong (IPAM) or to the location where our data processors / service providers collect and process your personal data, which is primarily in Hong Kong. IPAM will not share such information with any affiliated or non-affiliated third party except:-
• For the purposes of conducting customer or vendor due diligence, know-your-client or anti-money laundering checks;
• For the purposes of operating a customer relationship or risk management system with a third party vendor;
• When necessary to complete a transaction in a customer account, such as with the execution broker, trade counterparty, clearing firm or account custodians;
• When required to maintain or service a customer account, including sharing with a fund administrator or custodian;
• To resolve customer disputes or enquiries;
• With persons acting in a fiduciary or representative capacity on behalf of the customer;
• With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of IPAM;
• In connection with a proposed sale or merger of IPAM’s interests or business;
• To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
• To comply with country, federal, state or the laws, rules and other applicable legal requirements in any jurisdiction, or in connection with a regulatory request;
• In connection with a written agreement to provide services, including investment management or advisory services when the information is released for the dominant purpose of providing the products or services covered by the agreement; and/or
• In any circumstances with the customer’s instruction or consent, or ancillary to the above.
We aim to collect personal data to the extent reasonably necessary to fulfil the Legal Basis and Purposes set out above.
Your Personal Data Rights
Personal data we collect from you should be accurate and where necessary, kept up to date. We will take reasonable steps to ensure that inaccurate personal data are erased or rectified without delay. You have a right to request and/or correct your personal data by contacting Ms. Nicola Wong at +852 2169 2100 or at firstname.lastname@example.org.Under the GDPR and other applicable legislation, and subject to applicable exemptions and/or limitations, you may have the following rights:
• Right to access personal data;
• Right to data portability, that is to receive personal data back in a commonly used format (amongst other things), and to have those data transmitted to a third party data controller without hindrance;
• Right to object to the processing of your personal data, including a general right to object and a right to object for direct marketing purposes;
Safeguarding your Personal Data
We endeavour to safeguard and protect your personal data from unauthorized access. No IPAM employee who is not so authorized shall obtain or seek to obtain personal and financial customer information. No IPAM employee with authorization to access personal and financial customer information shall share that information in any manner without the specific consent of an IPAM principal. Failure by an IPAM employee to observe IPAM’s procedures regarding customer and consumer privacy will result in discipline and may lead to termination. Separately, we protect personal data.
Comments, Suggestions or Exercise of your Rights