Data Privacy Policy of Wocom Holdings Limited, Wocom Securities Limited, Wocom Limited, Wocom Foreign Exchange Co. Limited, Wocom Financial Services Company Limited, Wocom Nominees Limited and Wocom Investment Management Limited (“Wocom Group”)

At Wocom Group, we want to provide the best service possible to our customers.

One way that we do this is by using customer information to provide our customers with convenient access to the right products and services. We also recognize that our customers have important expectations regarding the use of that information.

Safeguarding customer information is a matter that we take seriously. That is why we at Wocom Group have set forth the following principles to affirm our long-standing commitment to confidentiality:

(a) From time to time, it is necessary for customers who are individuals to supply Wocom Group with data which are personal data (“Data”) for the purposes of and therefore protected by the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong). The purposes for which Data (and other information) relating to customers may be used are as follows:

• the daily operation of the services and facilities provided to customers;
• conducting credit checks;
• assisting other institutions to conduct credit checks; ensuring customers’ ongoing credit worthiness;
• designing financial services or related products for customers’ use;
• marketing financial services or related products to customers;
• determining the amount of indebtedness owed to or by customers;
• meeting the requirements to make disclosure under the requirements of any law or regulations;
• and any purposes relating to any of the foregoing.

(b) Data (and other information) held by Wocom Group relating to customers will be kept confidential but Wocom Group may disclose, and it is a condition of Wocom Group providing services, products and information to customers that each customer consents to the disclosure of, all Data (and other information) to:

• any officer, employee, agent, contractor or third party who provides administrative, credit information, debt collection, telecommunications, computer, payment or other services to Wocom Group in connection with the operation of their business;
• any financial institution with which the customer has or proposes to have dealings;
• regulatory authorities and other relevant government bodies;
• any other person under a duty of confidentiality to Wocom Group including a company within Wocom Group which has undertaken to keep such information confidential.

We share information regarding customers among Wocom Group only in accordance with strict internal security standards and confidentiality policies and with applicable law.

We hold our employees fully accountable for adhering to those standards, policies and laws.

We do not share information about our customers with other companies except in order to conduct our business, comply with applicable law, protect against fraud or make available special offers of products and services that we feel may be of interest to our customers.

We may also provide information to regulatory authorities and law enforcement officials in accordance with applicable law.

We have established high standards for protecting information regarding our customers from unauthorized alteration or destruction.

 

Wocom Group may, in accordance with the Personal Data (Privacy) Ordinance and any other applicable law:

(a) match, compare or exchange any Data or other information provided by, or in respect of, a customer with Data (or other information) held by Wocom Group or any other person for the purpose of:

• credit checking;
• Data (and other information) verification;
• otherwise producing or verifying Data (and other information) which may be used for the purpose of taking adverse action against the customer or any other person at any time;

(b) transfer such Data (and other information) to any place outside Hong Kong (whether for the processing, holding or use of such Data (and other information) outside Hong Kong).

Under and in accordance with the terms of the Personal Data (Privacy) Ordinance each customer has a right to:

• check whether Wocom Group hold Data about the customer and the right of access to such Data;
• require Wocom Group to correct any Data relating to the customer which is inaccurate;
• and ascertain Wocom Group’s policies and practices in relation to Data and to be informed of the kind of personal data relating to the customer held by Wocom Group.

 

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:

Compliance Department

Wocom Holdings Limited

Room 1002, Wing On Centre, 111 Connaught Road Central, Hong Kong

In accordance with the terms of the Personal Data (Privacy) Ordinance, Wocom Group has the right to charge a reasonable fee for the processing of any Data access request.

At Wocom Group, information regarding our customers is used solely in the legitimate conduct of our business, to deliver superior service and to design products and special offers that demonstrate our understanding of our customers and their needs.

As we move forward in developing new products and services in an era of vast technological change, we will continue to maintain our dedication to assuring that customer information is properly used and appropriately safeguarded.