Privacy Statement

Quam Funds (SPC) LIMITED ("QF") is fully committed to protecting the privacy interests of individuals who provide us with information about themselves and to complying with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the "Ordinance"). In doing so, we instruct our staff to comply with strict internal standards of security and confidentiality.

THE PERSONALLY IDENTIFIABLE INFORMATION ("PI Information") which we collect at the web site comprises any or all of the following:

  1. the IP address of the visitor's personal computer; the country from which the inquiry is made; the pages visited; the time at which a visit is made and the browser type;

  2. certain personal details of the visitor (these may for instance include his/her name; age; sex; profession); contact details; whether the visitor holds any funds offered or distributed by QF and wishes to receive information and if so, what kind of information. This PI information, when collected, is not electronically encrypted; and

  3. PI Information collected at the website may include identification details, an electronically encrypted security passcode for that client and information regarding holdings in funds offered or distributed by QF which the client wishes to switch or redeem.


    4. We may use software tools or 'cookies' to gather information about site visitors' browsing activities. Cookies are small files which are sent to visitors' browsers and stored on visitors' computer hard discs. Through the use of cookies we may obtain information as to the manner in which this site is used. The information collected may be used for statistical and evaluation purposes and may be processed by us, our agents or any other third party which provide services to QF.
PI INFORMATION RECEIVED BY QF MAY BE USED BY QF and/or any of QF's holding companies, subsidiaries or associated companies, within or outside Hong Kong, for direct marketing purposes and in this connection, QF may transfer or disclose that information to any of those other companies or any agents or third parties which may provide services to QF, within or outside Hong Kong. PI Information which may be collected over the website from an On-line dealing client may be used by QF and transferred or disclosed to any manager or trustee of any funds offered or distributed by QF in which you may invest; any of their or QF's holding companies, subsidiaries or associated companies, agents and any other third party which provides services to QF, within or outside Hong Kong, for the purposes of processing any request that On-line dealing client may make and providing financial services or any related services, including direct marketing (by means of mail drops or via the internet). QF will cease to use your PI Information for direct marketing purposes if you request us to do so.

QF'S POLICY IS GENERALLY TO RETAIN PI INFORMATION concerning its individual clients for a minimum period of seven years after a person ceases to be a client and to erase or destroy it after the expiration of that period. PI Information concerning an individual which is collected at a time when that individual is not a client is erased or destroyed when that PI Information is no longer required for the purpose, including any directly related purpose, for which that information was used.

QF'S POLICY IS TO RESTRICT ACCESS TO PI INFORMATION concerning individuals to employees and agents who have a need to use that information and who have been instructed to handle such information properly and observe confidentiality. Security Passcodes used by On-line dealing clients is electronically encrypted.

AN INDIVIDUAL OR ANOTHER PERSON PERMITTED UNDER THE ORDINANCE on his/her behalf has the right to be informed by QF whether it holds PI Information about that individual and to request access to and/or correction of any such PI Information. Any such request may be made to Quam Funds (SPC) Limited, Room 1008, 10/ F Man Yee Building, 68 Des Vouex Road Central, Hong Kong. In order to deal with any such request, we will require evidence from you that you are the individual in respect of whom the request is made or a person permitted under the Ordinance to make the request on that individual's behalf. We will deal with any such request as soon as possible but in any event within the 40 days maximum period set by the Ordinance.

  
*Please refer to the principal brochure of the respective portfolio funds for further details.
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