PRIVACY POLICY

202202 - V1.07

PRIVACY POLICY

This statement is provided to clients of Eddid Securities and Futures Limited ("ESFL") in accordance with the requirements of the Personal Data (Privacy) Ordinance ("Ordinance") in Hong Kong. The terms mentioned in this statement have the same meaning as those in the Client Agreement. When you browse the website of ESFL or its affiliates or to open an account, you authorize ESFL and its affiliates to continuously collect and use your personal data.

 DISCLOSURE OBLIGATION

Unless otherwise stated, the Customer must supply the personal data requested during the account opening processes. If the Customer does not supply this data, ESFL reserves the right to suspend and stop the opening and operation of all customers and management accounts that do not have sufficient information until the customer can provide such information.

 PURPOSES OF COLLECTION

We may use the information collected to verify your identity, open an account for you (including issuing you with an Account number and password), service your account including providing statements and trade confirmations, facilitate Account funding and withdrawals, including in connection with margin trading, conduct credit checks at account opening and regularly thereafter, collect outstanding amounts from you whether through the use of cheques or bank transfers, collect personal information from those who provide security or guarantee your performance in connection with your account, carry out statistical and other analysis, and for any other purposes directly related to any of the above purposes (“Business Purposes”). If you do not provide us with your personal information for these Business Purposes, we may not be able to open an account or to provide any services to you.

 PERSONAL INFORMATION TO BE COLLECTED

Most of the personal information we collect is provided directly by you, for example by you filling in an application form. This information includes, but is not limited to, personal details, such as your name, address, date of birth, telephone number and e-mail address, information required pursuant to regulatory requirements verifying your identity such as a passport or other government issued photo identification, financial information such as your Account trading details, annual income, net worth, risk capital financial information, bank account details and credit card information.

Other information, such as your IP address, web browser type, operating system and your internet service provider, will be provided by you indirectly in the ordinary course of our business relationship with you, for example through online tracking, as described in the section below entitled “Cookies”.

 “Cookies” 

We use cookies and other technologies (collectively, "cookies") on our website to store and track information about you and your actions for the purposes of providing us with data we can use to improve your experience and to know you better. Cookies are small text files sent from various web servers that may be stored on your computer. Cookies enable us to capture how you arrived at our website, how often you visit, when you return, which pages on our website you visit, and to recognize when you are logged on when we receive a request from your web browser. We may link the information we store in cookies in order to identify information you submit while on our website. Cookies are readable only by us and do not on a standalone basis contain any personal, financial or Account information. We cannot and will not gather information about other websites you have visited in the past.

We may share usage information about persons who visit our website with reputable advertising companies for the purpose of targeting our banner advertisements on the internet. The information collected by the advertising company through the use of these pixel tags does not identify you personally.

Additionally, we may use third party software to track and analyze usage and volume information including page requests, form requests and click paths. The third party may use cookies to track your web browsing behavior and may implement cookies on behalf of us. Your personal information will not be used by that third party or be further transferred by that third party to any other person.

All web browsers have settings that allow you to block cookies. By visiting our website with your web browser set to allow cookies, you consent to our use of cookies as described above. If you choose to block cookies you may use our services, however, some functions and features may be disabled or may not work as they were initially designed to.

 DISCLOSURE WITHIN EDDID GROUP AND TO NONAFFILIATED THIRD PARTIES FOR BUSINESS PURPOSES

We may share your personal, financial and Account information with our affiliates for any of the Business Purposes, as permitted by applicable law including to countries outside of Hong Kong where there may not be comparable data protection laws. Our affiliates are companies which are controlled or directly or indirectly owned by members of the EDDID Group; and include financial service companies, such as dealers and other brokerage firms.

To help us improve our services to you for the Business Purposes, we may engage another business to help us carry out certain internal functions, such as account or data processing, fulfillment, client service, client satisfaction surveys as well as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing, credit references, debt collection companies or to any other businesses directly relevant to the Business Purposes.

We may also transfer your personal information to Service Providers in connection with the Business Purposes.

We may disclose your personal information to non-affiliated entities, governments or regulatory authorities as permitted or required by applicable law including disclosing your personal information to regulatory bodies for anti- money laundering and counter-terrorist financing purposes. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.

 DIRECT MARKETING BY EDDID GROUP MEMBERS

We may also use your name, telephone number, home address and e-mail address (“Personal Data”) to notify you of any new and existing financial services related products, services and promotions that may be of interest to you (“Direct Marketing”).

We may also use online tracking information for Direct Marketing. We will not use any personal information collected via online tracking information for Direct Marketing.

Your provision of Personal Data for Direct Marketing is voluntary and so if you do not wish us to use your Personal Data for Direct Marketing purposes, you can opt out by contacting us through the contact information set out under the section entitled “Contact us” below.

Should you close your Account with us, we will retain your personal information, but we will only use it to comply with our regulatory requirements and will only keep such information for a period which is not longer than necessary and permitted by the relevant local laws. We will also periodically contact you to notify you of new products, services and promotions we may offer from time to time but you can opt out if you wish.

 DISCLOSURE TO NON-AFFILIATED THIRD PARTIES FOR DIRECT MARKETING

We will not sell, license, lease or otherwise disclose your personal information to any third party for any reasons, except as described below.

We may provide a non-affiliated third party with your Personal Data, to help us analyze and identify client needs, notify clients of product and service offerings or conduct general marketing and market research for us in connection with our financial services products and services only. In order to promote the products and services we provide to you, we may also share your personal and account information with third-party service providers and joint marketers not affiliated with us [for gain], namely financial service institutions with whom we have joint marketing agreements, such as agreements to market financial services or products that we jointly offer, endorse or sponsor; and companies under contract to perform services for us or on our behalf, including direct marketing services.

We generally require that all non-affiliated third parties to which we provide your nonpublic information agree to keep your information confidential and use such information solely for the limited purpose for which we have engaged them, or as otherwise required by law. We also seek to ensure that these non-affiliated third parties maintain appropriate data security procedures to guard against unauthorized use of, or access to, your information.

We may also transfer online tracking information for Direct Marketing to the above described third parties for gain.

We will not transfer any online tracking information for Direct Marketing to any third parties other than the above described.

We will not however transfer any of your Personal Data to any of the above described third parties for Direct Marketing purposes without your prior written consent. Your provision of your personal information for Direct Marketing is voluntary and you can opt out by contacting us through our contact details under the section entitled “Contact us”.

 SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION

We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the local applicable legal requirements including the Personal Data (Privacy) Ordinance in Hong Kong with respect to managing your personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations.

We employ physical, electronic, and procedural safeguards in order to protect your personal, financial and Account information and to offer you a safe and secure trading environment. When you open an Account with us, you are issued a unique Account number and password.

Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so.

We limit access to your personal, financial and Account information to those employees and employees of our affiliates who need to know in order to conduct business, including servicing your Account. These employees will have access to your Account number and user id. Although certain employees have the ability to reset your Account password and Secure Access Website password for you, they will not have access to your password, as they are not saved in our systems.

We have employed adequate security measures based on recognized international standards, to safeguard your personal information and protect from it from being disclosed, compromised or leaked.

Your personal, financial, and Account information, including your credit card details (where applicable), will be disposed of or purged from our records based on our data retention policy seven years after the Account has been closed, which is compliance with recognized international standards.

You are ultimately and solely responsible for maintaining the secrecy of your Account number and password and the Secure Access Website user id and password. In order to better safeguard this information, we highly recommend you the following precautions:

· Do not disclose your Account number and password, or Secure Access Website user id and password to anyone;

· Do not save your Account number and password, or Secure Access Website user id and password on any shared, public or private computer, tablet, mobile phone, or any other device;

· Avoid using public computers at internet cafes and similar places whenever possible;

· Immediately change your Account password and Secure Access Website password after your first log-in;

· Change your Account password and Secure Access Website password regularly and whenever you believe there may have been a breach or when you believe a breach may occur in the future;

· Choose strong passwords that are not easily breakable, include capitalized letters, numerical values and symbols and differ from other passwords you are using for other accounts;

· Do not configure the save password option on the web browser you are using;

· The computer, tablet, mobile phone, or other device you are using has security controls, such as, antivirus software;

· Ensure that the Website you are accessing is legitimate ESFL Website;

· Make sure that the Website is changed to “https” prior to entering any information, such as, personal information, logins, passwords and credit card information to ensure information is encrypted during transmission;

· Do not continue the transmission, if the SSL Certificate of the Website you are accessing does not belong to ESFL and immediately notify ESFL;

· Validate all calls, emails or other communications from ESFL are genuine prior to disclosing any personal, financial or Account information; and

· Notify ESFL immediately if you believe your Account or Secure Access Website access has been compromised.

 OPT-OUT

If you do not agree to allow us to use or transfer your personal information for Direct Marketing purposes, you can opt out by contacting us using the contact details below the section entitled “Contact us”.

 CONTACT US

In connection with your access rights or Direct Marketing opt-out rights as well as any queries about our privacy policy and procedures, you may notify us at cshk@eddidsec.com (HK Client) / cs@eddidsec.com (non-HK Client) or at 21/F, Citic Tower, 1 Tim Mei Avenue, Central, Hong Kong. For joint accounts, an-opt out election made by one account owner will be applicable to all owners on the Account. Please allow approximately 30 days from our receipt of your request for your instructions to become effective.

 CHANGES TO THIS PRIVACY STATEMENT

In the event any material changes are made to this statement, the revised statement will be posted on our website as soon as reasonably practical. By your continued use of the website and/or by opening an Account with us, you hereby agree to accept this as notice provided to you.

Any dispute over this statement is subject to the terms of this statement and our Terms. If you have any questions that this statement does not address, please contact our Data Protection Officer or a support representative.