Personal Information Collection Statement
This statement provides you with notice as to why your personal data is collected, how it is intended to be used, to whom your personal data may be provided to and how to access, review and amend your personal data.
1. Collection of Personal Data
For the purpose of complying with law, regulation and regulatory provision, or to provide you with various products and services, or in order to contact or communicate with you, and develop our relationship with you, we may receive and keep the personal information provided by yourself , or, according to law, regulation, regulatory provision, your authorization or consent to collect, enquire, and verify your personal information from/with members of the Noah Group or other third parties (including but not limited to credit reference agencies, information service providers, relevant authorities, employers, counterparties, contact persons and other entities/individuals).
The kinds of Data that may be collected includes, but is not limited to, your name, gender, address, occupation, contact details, date and place of birth, nationality, identity card or passport details, financial status, tax information, educational and marital status, employment information, biometric credential(s) (including without limitation fingerprint(s), facial map(s) or any other biometric data as approved by Noah HK from time to time), and technical information about your mobile device (including but not limited to Hardware device model, device identification code (such as IMEI / android ID), unique device identifier, and operation logs related to the Website service), operation system and application software, IP address or location, that is gathered periodically to facilitate the provision of software updates, product support, and other services (if any) related to, or in connection with, the website service.
2. Protection of Personal Data
Noah HK takes all reasonably practicable means to protect the Data, such as, by restricting the access of Data by authorized personnel only and incorporating security measures into equipment in which Data is held. Encryption technology is employed for sensitive data transmission. If Noah HK engages data processors to handle or process personal data on the Noah HK’s behalf (whether within or outside Hong Kong), Noah HK would adopt contractual or other means to prevent any unauthorised or accidental access, processing erasure, loss or use of the transferred data by the data processors.
The records of your Data will be stored in secured places with restricted access. The authorized personnel of Noah HK or its affiliates (who have been trained in personal data handling and protection) will only access and process the Data on a “need-to-know” basis.
3. Authorisation of Disclosure by Noah HK
You hereby authorise Noah HK to supply to its affiliates with all Data relating to you or your account （if any）with Noah HK. Failure to supply such Data may result in Noah HK being unable to provide services to you or unable to comply with any laws or regulations or guidelines and codes issued by regulatory or other authorities.
4. Use of Personal Data
1. Users of personal dataYou confirm for yourself that all personal data concerning you may be used by any of the following companies or persons: Noah HK and its affiliates, any director, officer or employee of Noah HK and its affiliates, only in the course of business; or any person (such as lawyers, advisers etc.) authorised by the forgoing, only in the course of business.
2. Purpose of use
Your Data may be used are as follows:
a) processing applications for account opening and/or other financial services and facilities;
b) daily operation of the account and/or other financial services and facilities provided to you and relating to any transactions you may undertake;
c) marketing services, products and other subjects (please see further details in paragraph 5 below);
d) complying with any law, regulation, guideline, court order or order of a regulatory body;
e) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within Noah Group and/or any other use of data and information in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
f) exchanging information with Noah HK and any financial institution and entities with whom the Noah HK provides affinity;
g) compiling statistical information and client profiles;
h) new or existing client verification procedures and ongoing account administration;
i) updating, comparing and/or verifying any and all of your Data that may be held by any member of Noah Group or agents of Noah Group; or
j) any other purposes relating to or in connection with the business or dealings of Noah HK and its affiliates and purposes relating thereto.
3. Provision of information to other users
Data held by Noah HK relating to you will be kept confidential but Noah HK may provide and disclose such information to the following parties (whether within or outside Hong Kong) for the purposes set out in paragraph 4.2 above:
a) any agent, contractor or third party service provider who provides administrative, telecommunications, electronic fund transfer service, computer, payment, debt collection or other services to Noah HK in connection with the operation of its business;
b) any branch, subsidiary, holding company, associated company or affiliate of Noah HK;
c) any other person under a duty of confidentiality to Noah HK including any member of Noah Group which has undertaken to keep such information confidential;
d) any person to whom Noah HK or any member of Noah Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to Noah HK or any member of Noah Group, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which Noah HK or any member of Noah Group is expected to comply, or any disclosure pursuant to any contractual or other commitment of Noah HK or any member of Noah Group with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside Hong Kong and may be existing currently and in the future;
e) third party financial institutions, insurers, credit card companies, securities and investment service providers;
f) third party reward, loyalty, co-branding and privileges programme providers;
g) co-branding partners of Noah HK and any member of Noah Group (as the case may be); or
h) external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, gift redemption centres, data processing companies and information technology companies) that Noah HK engages for the purposes set out in paragraph 4.2.
Such information and Data may be transferred to a place outside Hong Kong.
5. Direct Marketing Consents
Noah HK intends to use your Data in direct marketing and Noah HK 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 services portfolio information, transaction pattern and behaviour, financial background and demographic data held by Noah HK from time to time may be used by Noah HK or any member of Noah Group in direct marketing.
b) the following classes of services, products and subjects may be marketed:
(i)financial, insurance, credit and related services and products;
(ii)reward, loyalty, co-branding or privileges programmes and related services and products; or
(iii)services and products offered by Noah HK’s co-branding partners (as the case may be).
c) the above services, products and subjects may be provided or (in the case of donations and contributions) solicited by Noah HK and/or:
(i)third party financial institutions, insurers, securities and investment service providers;
(ii)third party reward, loyalty, co-branding or privileges programme providers; or
(iii)co-branding partners of Noah HK and/or any member of Noah Group (as the case may be).
d) In addition to marketing the above services, products and subjects itself, Noah HK also intends to provide the Data described in paragraph 5b) above to all or any of the persons described in paragraph 5c) above for use by them in marketing those services, products and subjects, and Noah HK requires your written consent (which includes an indication of no objection) for that purpose.
e) Noah HK may receive money or other property in return for providing the Data to the other persons in paragraph 5d) above and, when requesting your consent or no objection as described in paragraph 5d) above, Noah HK will inform you if it will receive any money or other property in return for providing the Data to the other persons.
If you do not wish Noah HK, to use or provide to other persons your Data for use in direct marketing as described above, you may exercise your opt-out right by notifying Noah HK.
6. Rights of Access and Correction
The Data collected may be maintained for such period of time required under applicable laws and as otherwise needed to fulfil the purposes set out in paragraph 4 above. Data held by Noah HK relating to you will be kept confidential and Noah HK will take all reasonable measures to ensure that Data is kept secured against unauthorized access, loss, disclosure and destruction. Noah HK may provide the Data to the following persons, whether inside or outside of Hong Kong, for the purposes set out in paragraph 4 above and you consent to any such use or transfer:
a) the ultimate holding company of Noah HK, its subsidiaries, representative offices, associated companies and affiliates;
b) the service providers and agents of Noah HK;
c) any agent, contractor or third party service provider who provides administrative, research, design, launch, digital or telecommunications, clearing and settlement or other services to Noah HK in connection with its business;
d) the employees, officers and directors of each of Noah HK and all the persons set out in a) above;
e) any relevant Issuer, its delegate or holding company;
f) any person (including, but not limited to, any governmental or regulatory authority or court of competent jurisdiction) entitled thereto by applicable laws or in response to a regulatory request;
g) any person to whom the business of Noah HK may be sold; or
h) external service providers of Noah HK (including, but not limited to, printing houses, mailing houses, digital or telecommunication companies, data processing companies, storage companies, and information technology companies) that Noah HK engages for the purposes of direct marketing.
Under the PDPO, you have the right to:
a) check whether Noah HK holds Data about you and access such Data;
b) require Noah HK to correct any Data relating to you which is inaccurate; and
c) ascertain Noah HK’s policies and practices in relation to Data and to be informed of the kinds of Data held by Noah HK; and
d) object to the use of your Data for direct marketing purposes. Following the receipt of such objection, Noah HK shall not use your Data for direct marketing purposes. In accordance with the PDPO, Noah HK has the right to charge a reasonable fee for the processing of any data access request.
7. Contact Person
The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:-
Noah Holdings (Hong Kong) Limited
34/F, Tower Two, Times Square, 1 Matheson Street, Causeway Bay, Hong Kong
This statement applies to all transactions entered into by you with or through Noah HK, whether before or after the date of this statement.