PERSONAL INFORMATION COLLECTION STATEMENT

This Statement is provided to the Client as an individual client (including prospective clients (including demo trading platform users) and data subjects) of the Imperium International Securities Limited (the “Company”) in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”). Terms defined in this statement have the same meaning as in the Securities Trading Cash Client Agreement / Securities Trading Margin Client Agreement / Futures and Options Trading Client Agreement / Wealth Management Agreement.

1. Use of Personal Data

1.1 Users

All personal data concerning the Client (whether provided by the Client or any other person, and whether provided before or after the date the Client receives the Securities Trading Cash Client Agreement / Securities Trading Margin Client Agreement / Futures and Options Trading Client Agreement/ Wealth Management Agreement containing this information) held by the Company will be kept confidential but the Company may provide such information to the following parties for the purposes set out in paragraph 1.2 (each, a “User”):

1. Imperium International Securities Limited and any of its Associates and Affiliates (the “Group”); 
2. Any local or foreign governmental, regulatory or other bodies or institutions, whether as required by law or regulations applicable to any member of the Group; 
3. Any director, officer or employee or agent of the Group; 
4. Any local or foreign person (such as lawyers, advisers, nominee, accountants, property valuers, custodian, third party service providers, immigration consulting companies, education consulting companies, educational institutions and insurance companies etc.) authorized by the Company and/or the Group when carrying out the Client’s Instructions, daily operation and the business of the Company and/or the Group; 
5. Credit reference agencies and in the event of default, to debt collection agencies; 
6. Any actual or proposed assignee of any rights and obligations of the Group ; 
7. Third party financial institutions, insurers, credit card companies, securities and investment services providers; 
8. Third party reward, loyalty, co-branding and privileges programme providers; 
9. Co-branding partners of the Company and the Group (the names of such co-branding partners can be found in the application forms for the relevant services and products, as the case may be); 
10. Charitable or non-profit making organisations; and 
11. External service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that the Company engages for the purposes set out in paragraph1.2 (xiii). 

1.2 Purposes

All personal data concerning the Client may be used by any User for the following purposes:

1. Enabling the Company and/or the Group to provide daily operation of the services (including demo trading platform services), and/or credit facilities and facilitating the same relating to the Client, including providing assistance in handling or processing applications under immigrant investor programs (including handling matters relating to criminal records) and/or local or foreign study and/or providing insurance services and/or providing relevant consulting services; 
2. Enabling an actual or proposed assignee of the Company and /or the Group, or participant or sub-participant of the Company’s (and/or the Group’s) rights in respect of the data subjects (persons who provide data and include the Client) to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;
3. Creating and maintaining the Company’s and/or the Group’s scoring models;
4. Carrying out new or existing clients’ verification and conducting credit checks at the time of application for credit facilities and at the time of regular or special reviews which will normally take place one or more times each year; 
5. Assisting other financial institutions to conduct credit checks and collect debts; 
6. Ensuring ongoing credit worthiness of data subjects; 
7. Any person to whom the Company and/or the Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to the Company or any law binding on or applying to the Company and/or the Group, or any disclosure under and for the purposes of any guidelines, rules or similar directives 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 the Company and/or the Group are expected to comply, or any disclosure pursuant to any contractual or other commitment of the Company and/or the 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.
8. Ongoing account administration, including without limitation the collection of amounts outstanding from data subjects, enforcement of data subjects’ obligations in respect of security, charge or other rights and interests held by any member of the Group; 
9. Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the 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;
10. Any other purpose relating to the execution of the Client’s Instructions (including instructions given in the demo trading platform) or in connection with the business or dealings of the Group;
11. Comparison with the Client’s personal data (irrespective of the purposes and sources for which such data were collected, and whether collected by a User or any other person) for the purpose of:
    ( a） data verification;
    ( b） credit checking; and/or 
    ( c） otherwise producing 
    or verifying data which may be used for the purpose of taking such action that a User or any other person may consider appropriate (including action that may relate to the rights, obligations or interest of the Client or any other person);
12. Researching and designing further products, services and other subjects;
13. Marketing products, services and other subjects of the Company and the Group (please see paragraph 1.3 below) to the Client;
14. Maintaining credit history of the data subjects for present and future reference; and
15. Transfer of such data to any place within and outside Hong Kong for the above purposes and/or relating thereto.

1.3 Use of Data in Direct Marketing
The Company intends to use the Client’s data in direct marketing and the Company requires the Client’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that: 

1. The name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of the Client held by the Company may be used from time to time by any member of the Group in direct marketing; 
2. The following classes of services, products and subjects may be marketed;
   （a） Financial, insurance, securities, fiduciary, investment services, immigrant investor programs, local or foreign study and related services and products;
   （b） Reward, loyalty or privileges programmes and related services and products;
   （c） Services and products offered by the Company and any member of the Group with the co-branding partners (the names of such co-branding partners can be found in the application forms for the relevant services and products, as the case may be); and 
   （d） Donations and contributions for charitable and/or non-profit making purposes; 
3. The above services, products and subjects may be provided or (in the case of donations and contributions) solicited by the Company and / or:
   （a） Any member of the Group;
   （b） Third party financial institutions, insurers, credit card companies, securities and investment services providers, third party local or foreign immigration consulting companies, education consulting companies, educational institutions and insurance companies;
   （c） Third party reward, loyalty, co-branding or privileges programme providers;
   （d） Co-branding partners of the Company and the Group (the names of such co-branding partners can be found in the application forms for the relevant services and products, as the case may be); and
   （e） Charitable or non-profit making organisations;  
4. In addition to marketing the above services, products and subjects itself, the Company also intends to provide the data described in paragraph 1.3(i) above and, when requesting the Client’s consent or no objection as described in paragraph 1.3(iii) above for use by them in marketing those services, products and subjects; and the Company requires the Client’s written consent (which includes an indication of no objection) for that purpose; 
5. The Company may receive money or other property in return for providing the data to the other persons in paragraph 1.3(iv) above and, when requesting the Client’s consent or no objection as described in paragraph 1.3(iv) above, the Company will inform the Client if it will receive any money or other property in return for providing the data to the other persons. 

If the Client does not wish the Company to use or provide to other persons his data for use in direct marketing as described above, the Client may exercise his opt-out right by notifying the Company. 

 2. Rights of Access and Correction

The Client has the right to have access to and correction of the Client’s personal data as set out in the Ordinance. In general, and subject to certain exemptions, the Client is entitled to:

1. Request access to the Client’s personal data within a reasonable time, at a fee which is not excessive, in a reasonable manner and in a form that is intelligible; 
2. Request the correction of the Client’s personal data; 
3. Enquire whether the Company holds personal data in relation to the Client and ascertain the Company’s policy and practices in relation to data; 
4. Be informed on request which items of data are routinely disclosed to credit reference agencies or debt collection agencies, and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency; 
5. In relation to an account data (including, for the avoidance of doubt, any account repayment data) which has been provided by the Company to a credit reference agency, to instruct the Company, upon termination of the account by full repayment, to make a request to the credit reference agency to delete such account data from the database, as long as the instruction is given within five years of termination and at no time was there any default of payment in relation to the account, lasting in excess of 60 days within five years immediately before account termination. Account repayment data include amount last due, amount of repayment made during the last reporting period (being a period not exceeding 31 days immediately preceding the last contribution of account data by the Company to a credit reference agency), remaining available credit or outstanding balance and default data (being amount past due and number of days past due, date of settlement of amount past due, and date of final settlement of amount in default lasting in excess of 60 days (if any));and 
6. Be given reasons if a request for access or correction is refused, and object to any such refusal. 

3. In the event of any default of payment relating to an account, unless the amount in default is fully repaid or written off (other than due to a bankruptcy order) before the expiry of 60 days from the date such default occurred, the account repayment data (as defined in paragraph 2(v) above) may be retained by the credit reference agency until the expiry of five years from the date of final settlement of the amount in default. 

4. In the event any amount in an account is written-off due to a bankruptcy order being made against the data subjects, the account repayment data (as defined in paragraph 2(v) above) may be retained by the credit reference agency data, regardless of whether the account repayment data reveal any default of payment lasting in excess of 60 days, until the expiry of five years from the date of final settlement of the amount in default or the expiry of five years from the date of discharge from a bankruptcy as notified by the data subjects with evidence to the credit reference agency, whichever is earlier. 

5. The Company may have obtained a credit report on the Client from a credit reference agency in considering any application for credit. In the event that the data subject wishes to access the credit report, the Company will advise the contact details of the relevant agency. 

6. Disclosure Obligation 
Unless otherwise stated the Client must supply the personal data requested on the enclosed Account Opening Form to the Company. If the Client does not supply this data, it will not be possible for the Client to open an Account with the Company as the Company will not have sufficient information to open and administer the Account. 

7. Contact Person 
If the Client wishes to request access to and/or correct personal data and/or opt out of receiving direct marketing material or his personal data being use in DIRECT MARKETING, the Client should contact the Data Protection Officer on (852) 3585 8977, email to PDPO@imperiumhk.com or write to: 

The Data Protection Officer 
Room 2603A, 26/F, One Harbour Square,  
181 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong