Privacy Policy and Data Protection Statement

Quam Asset Management Limited (QAM) is committed to maintaining your personal data-that is, information relating to a living individual from whom it is practicable for the identity of the individual to be directly or indirectly ascertained- in accordance with the requirements of the Personal Data (Privacy) Ordinance (“Ordinance”) and will take all reasonable steps to ensure that your personal data is kept secure against unauthorized access, loss, disclosure and destruction. Please be aware that this Statement replaces any notice or statement of similar nature issued by QAM previously, pursuant to the Ordinance.

By visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use this Website. Please review the Terms and Conditions to learn of other terms and conditions applicable to your use of this Website.

  1. Obligation to Disclose Personal Data

    Unless otherwise stated, you must supply personal data requested by us in connection with the opening or continuation of accounts with us by you or by companies related to you, the provision of services or products by us, or the use of certain features of the QAM website, such as the submission of applications for employment. Failure to supply such data may result in QAM being unable to open or maintain such account(s) or provide services or products to you or companies related to you or to process an employment application as we may not have sufficient information.

  2. The purposes and retention of the information:


    1. From time to time, it is necessary for clients and various other individuals (“data subjects”) to supply QAM with data in connection with various maters such as account opening or continuations, or provision of services to clients and other individuals or compliance with any laws or guidelines issued by regulatory or other authorities.
    2. Such data may include, but not limited to, data collected from data subjects in the ordinary course of the continuation of QAM's relationship with them, for example, when clients register for an information account, attend seminar/events or generally communicate verbally or in writing with QAM.
    3. The purposes for which data relating to a data subject may be used will vary depending on the nature of data subject's relationship with QAM. They may comprise any or all of the following purposes:

      • The processing of application for an account with QAM;
      • Marketing financial services or related products
      • Meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to QAM
    4. All personal data, whether provided by you or another person, and whether provided before or after the date you receive this statement, may be provided to, exchanged with or transferred to, in the following circumstances as we may consider necessary whether the recipients are inside of or external to Hong Kong.

      • Third party disclosures may include sharing such information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to QAM.
      • We may also disclose your personal information to fulfil your instruction or pursuant to your express consent.
      • Under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations.
  3. Use of Data in Direct Marketing:


    1. QAM intends to use the data subject's data in direct marketing and QAM requires the data subject's consent (which includes an indication of no objection) for that purpose. The specific requirement regarding data subject's consent (which includes an indication of no objection) under Part VIA of the Personal Data (Privacy) Ordinance 2012 shall take effect from 1st April 2013.
    2. Pursuant to the Ordinance, direct marketing activities conducted by QAM may include but not limited to the following:

      • offering, or advertising of the availability, of goods, facilities or services; or
      • sending information or goods, addressed to specific persons by name, by mail, fax, electronic mail or other means of communication; or
      • making telephone calls to specific person.
    3. In this connection, please note that: the name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data of the data subject held by QAM from time to time may be used by QAM in direct marketing.
    4. In addition to marketing services, products QAM is allowed to provide, QAM also intends to provide the data collected from data subjects to third parties (as permitted by, or to comply with, applicable laws and regulations) for use by them in marketing those services, products and subjects, and QAM requires the data subject's written consent (which includes an indication of no objection) for that purpose.
    5. If data subject does not wish QAM to use or provide to other persons his data for use in direct marketing as described above, the data subject may exercise his opt-out right by notifying QAM.
  4. Aggregate Information

  5. We generally record certain usage information, such as the number and frequency of visitors to our Website. This information may include the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your Internet Protocol (IP) address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

  6. Privacy Preferences:

  7. This Website may contain information, including P3P privacy policies ("Privacy Preference Information"), intended to work with your selected privacy preferences. While we have tried to make such Privacy Preference Information included within this Website conform to this full-text of this Privacy Policy, this Privacy Policy is the definitive statement of the privacy policies and practices for this Website.

  8. Service Providers:

  9. We may use internal or external service providers to operate our Website and employ other persons to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personally identifiable information you submit through the Website, but only for performing their duties. These personnel are not permitted to use your personally identifiable information for any other purpose.

  10. Third Party Websites

  11. QAM may establish links between this Website and one or more websites operated by third parties. QAM has no control over any such other websites, the contents therein or the products/services offered. Your access to and use of such linked websites is governed by the terms of use and privacy policies of those sites, and shall be at your own risk. QAM disclaims responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from our Website.

  12. Security

  13. No data transmission over the internet can be 100% secure, so QAM cannot ensure or warrant the security of any information you submit to us on this Website. However, QAM seeks to protect your personal information when you transact business on our Website by requiring the use of a browser software program that supports industry standard SSL encryption.

  14. Under the Ordinance, any individual has the right:


    1. To check whether QAM holds data about him or her, and of access to such data;
    2. To require QAM to correct any data relating to him or her which is accurate
    3. To object to the use of his/her personal data for marketing purposes and QAM shall not use his/her personal data for marketing purposes after he/she communicates his/her objection to QAM.

According to the Ordinance, the holder of the personal data may request for access to data or correction of data. Such a request should be addressed as follows:
The Compliance Officer
Quam Asset Management Limited
18/F, China Building,
29 Queen's Road Central, Hong Kong

In accordance with the Ordinance, QAM has the right to charge a reasonable fee for the processing of any data access request.

© Copyright 2017 Quam Asset Management Limited. All rights reserved.

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