Privacy

Purpose of this privacy notice

This privacy notice provides information on how Hargreaves Asia collects and processes your personal data through your use of this website, including any data you may provide through this website, for example, if you request information through the website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

We may collect and process personal information about you including:

1. information provided by filling in forms on our website, posting material, requesting further services or reporting a problem with our website;
2. information provided as part of a job application or submitting your CV
3. identity data including first name, last name, status and title;
4. financial data including bank account, payment card details and information in relation to credit risk assessments; and
5. technical data concerning your visits to our website including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose (Aggregated Data). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Any personal information submitted as part of an application for a job with Hargreaves Asia will only be used in connection with such application. You must ensure that all information provided is accurate, complete and up-to-date.  Personal data provided which is inaccurate or incomplete may influence the process and outcome of the recruitment. It is voluntary for you to provide the personal data requested by us. However, failure to receive the personal data from you may result in being unable to process your application and consequently, may result in your application being rejected.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise.
2. Third parties or publicly available sources. We may receive personal data about you indirectly through one of our people, a client or a third party.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Keeping a record of the services you have subscribed to and delivering services you have requested.
3. Communicating with you by telephone or email.
4. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
5. Where we need to comply with a legal or regulatory obligation.
6. Administering our website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details below.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We will only disclose your personal data to another person or organisation where:

1. We need to share the information to provide a product or service you have requested.
2. We need to carry out a credit check in relation to a product or service you have requested. In order to process your application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.
3. We need to send the information to persons or organisations that work on our behalf to provide a product or service you have requested. Where such a person or organisation does work on our behalf, we will ensure that they are contractually required to take appropriate technical and organisational measures to protect your personal information against unauthorised or unlawful processing and against accidental loss or destruction of, or damage to, personal information and only use the information in order to provide a product or service on our behalf.
4. We are required to disclose the information in order to comply with the law or regulatory requirements.

We will also share personal information with other entities the Hargreaves Services plc group of companies as part of monitoring and providing information in relation to the use of our website, for systems maintenance support and hosting of data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The personal information that we collect from you may be transferred outside of Hong Kong. Whenever we transfer your personal data out of Hong Kong, we will take all steps reasonably necessary to ensure that any such transfer is made securely and there is adequate protection in place in order to protect your personal data.

Please contact us if you require further information on the specific mechanism used by us when transferring your personal data out of the Hong Kong.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We have installed CCTV systems in some of our premises for the purposes of public and staff safety and crime prevention and detection.

Images captured by CCTV cameras will be kept for no longer than is necessary.

We will only disclose images and audio to other bodies who intend to use it for the purposes stated above. Images and audio will not be released to the media for entertainment purposes or placed on the internet for public viewing.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You are entitled, in accordance with the Personal Data (Privacy) Ordinance (https://www.elegislation.gov.hk/hk/cap486), to access and correct your personal data and to withdraw your consent to direct marketing. Such requests to access to or correct personal data or to withdraw consent to direct marketing should sent using the contact information in section 12 below.

Depending on your location, you may also have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

What are Cookies?

Cookies are small data files stored on your computer when you visit certain websites. A cookie itself does not contain or collect personally identifiable information. On this website, Hargreaves Services plc makes use of cookies to personalise your experience and help us identify and resolve errors. Cookies set across Hargreaves Services Plc sites, set by the company or its third party partners, can be in the form of session or persistent cookies and may use different technologies, such as JavaScript or Flash.

How to manage cookies

If you would like to “opt out” of the cookies set by this website, this can be accomplished on a cookie-by-cookie basis subject to browser settings. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences. Please note, you may limit site operation or functions if you limit the cookies. For more information about cookies, visit: www.allaboutcookies.org or www.aboutcookies.org.

Our use of cookies

To make full use of our website, enjoy the personalised features and ensure the website works to its full potential; your computer, tablet or mobile phone will need to accept cookies.

We use cookies to:

1. remember you when you visit this website to keep track of your browsing patterns and to build up a profile of how you and other users use the website;
2. make our website operate as efficiently as possible; and
3. administer services and/or information to you.

The main cookies we use include those detailed below:

1. We may use both “session” cookies and “persistent” cookies on the website.
2. We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/policies/privacy/.

Third Party Cookies

Our website may contain links to other websites. Some of these third parties generate their own cookies. We do not control these third-party websites and are not responsible for their privacy statements.

We may change this notice at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we have made, as they are binding on you. If we make substantial changes in the way we use your personal information, we will notify you by posting a prominent notice on our website.

If you would like to exercise any of your rights detailed in section 9 above or if you have any questions about how we treat your personal data and protect your privacy, please contact our Compliance Manager: