PRIVACY POLICY STATEMENT

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We are committed to safeguarding the privacy of individuals with respect to your personal data. We assure that our policies and practices, and those adopted by our affiliated companies and agents in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486) (the “Ordinance”) under the laws of Hong Kong, as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of the term “personal data” adopted in this Statement is defined in the Ordinance.

Where our operations are subject to privacy legislation other than that of Hong Kong (such as due to our carrying out of operational functions outside of Hong Kong), this Statement shall apply so far as it is consistent with such local legislation.

Collection of Personal Information
From time to time, it is necessary for you to supply Wintone Wealth Management Limited (“the Company”) with personal data in connection with the application for and provision of financial planning products/services, insurance and/or Mandatory Provident Fund (“MPF”) or Retirement Scheme and/or related financial products as well as the carrying out by the Company of other services relating to these products and services. Failure to supply such data may result in the Company being unable to process your insurance & MPF or Retirement Scheme applications or to provide or continue to provide the financial planning products/services, insurance and/or Mandatory Provident Fund (“MPF”) or Retirement Scheme and/or the related services to you.

Purpose of Collection
Personal data relating to you may be used for the following purposes:
1. processing your application for providing the financial planning products/services, insurance and/or MPF or Retirement Scheme and/or related financial products ;
2. handling of any checking procedure related to your application and related claims;
3. facilitating the daily operation of the services provided to you;
4. verifying your eligibility for financial planning products/service, insurance, MPF or Retirement Scheme and/or related financial products;
5. providing you with marketing materials relating to financial planning products/services, insurance, MPF or retirement scheme concerning the Company, its group companies and financial institutions or insurers (collectively referred as the “Related Partners”);
6. communication with customers and prospective customers of the Company or its group companies or Related Partners;
7. assessing insurance protection and financial need analysis, investment risk appetite and/or MPF suitability assessment;
8. performing financial planning services, after sales services and policy review;
9. promoting, improving and furthering the provision of services by the Company and its group companies;
10. meeting any disclosure requirements imposed by law regulatory guidelines or regulatory authorities on Company, its group companies or Related Partners;
11. as other purposes as notified to you at the time of collection;
12. in respect of Financial Planning Products/Services and/or MPF or Retirement Schemes, the personal data provided by participating Employers and/or Members and details of transactions or dealings by such Participating Employers and/or Members may be used for the administration, communication and/or in connection with contributions or accrued benefits or MPF account in respect of the Participating Employers and/or Members under the MPF scheme.

Transferee
Data held by the Company relating to you will be kept confidential but the Company may, for the purposes set out above, transfer your personal data to:
1. the Company’s group companies; our consultants and any other persons under a duty of confidentiality to the Company;
2. any association or professional bodies in respect of the type of business carried on by the Company;
3. any other person necessary to comply with applicable legal or regulatory requirements, or orders of competent authorities;
4. any intermediaries, agents, consultants, business partners, The Company’s appointed service providers including for the services of telecommunications, information technology, administration, data processing, payment processing, who rendering services to the Company in connection with the operation of the Company’s business;
5. any third party with which you have or propose to have dealings;
6. any claim investigators; loss adjusters and other professional advisors;
7. any persons and corporate entities to whom the Company is obliged to disclose under the requirement of any law relating to the Company and its group companies or business partners;
8. any other parties as notified to you at the time of collection, in each case both within and outside of the Hong Kong Special Administrative Region.

Marketing and Promotion
Treating you as a valued customer, the Company and its group companies may use the personal data, including name and contact details collected from you for the purposes of direct marketing of the Company and its group companies’ financial planning products and/or services, insurance, MPF and/or retirement schemes or offers and for sending you the promotional materials or updates of such products, services or offers when they become available.

The Company may not use your personal data for direct marketing if you have indicated objection to such use. You may also, at any time, request the Company to cease the use of your personal data for direct marketing purposes, by informing the Company’s Compliance Officer at the contact set out below.

Access Requests and Corrections
You have the right to obtain access to and to request correction of any personal information concerning yourself held by the Company. Requests can be made to the Data Protection Officer of Wintone Wealth Management Limited, by mail to Suite 1201, 12/F, Chinachem Johnston Plaza, 176-186 Johnston Road, Wanchai, Hong Kong

According to the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
Nothing in this Statement shall limit the rights of the customers under the Ordinance.
The Company retains the right to change this Statement