Personal Information Collection Statement (PICS)
When providing services to its clients and other parties, The Hamon Investment Group Pte Limited and its subsidiaries and/or affiliates (“Hamon”) may act as a Data Controller, and may from time to time require you to supply your personal data for the purposes of opening or continuing portfolio accounts or in the establishment or continuation of investment management services by Hamon. Failure to supply such data may result in Hamon being unable to provide and/or continue to provide investment management services.The usage of the personal data may depend upon your position with Hamon, which is included but not limited to:
- The application procedures for the opening of a new account in Hamon and its affiliates;
- Providing investment management services, dealing and advisory services, custody services and other services under the terms and conditions of the accounts a customer holds with Hamon;
The daily operation of the services provided to you;
Marketing financial services or related products;
Complying the requirements to make disclosures under the requirements of any law, regulation, codes, guideline or any other rules which may be binding on or applicable to the Company or any of its subsidiaries or affiliates.
Data held by Hamon relating to you will be kept confidential but Hamon may from time to time provide such data to the following parties for the above reasons:
- any agent, contractor or third party service provider who provides administrative, telecommunications, computer, trade execution, payment or securities clearing or other services to Hamon in connection with the operation of its business;
any other person under a duty of confidentiality to Hamon including a related company of Hamon which has undertaken to keep such information confidential;
- any banking or financial institution with which you have or proposes to have dealings with;
- any group of companies of Hamon namely, any subsidiary or affiliate of Hamon or non-group related companies for marketing purposes;
- any actual or proposed assignee of Hamon or participant or sub-participant or transferee of Hamon’s rights in respect of the services that Hamon provides to you; and
- any person to whom Hamon is under an obligation to disclose under any law, rules, regulations, directions, guidelines applicable to Hamon or its business.
Hamon, as the Data Controller and its appointed Data Processors will retain your personal information for as long as required for us to perform the services. The length of the retention period will be determined by such considerations as legal or regulatory obligations that require the Manager or its Data Processors to retain your personal information, and applicable statutory limitation periods, whichever are longer.
Recipients of Data
Hamon may disclose your personal information as follows:
- to its service providers, including Data Processors, and their affiliates, and other third party service providers engaged by Hamon in order to process the data for the above mentioned purposes; and
- to competent authorities (including tax authorities), courts and regulatory bodies as required by the Hong Kong and/or EU law or requested or to affiliates for internal investigations and reporting.
International Transfer of Data
The disclosure of personal information to the Data Processors and third parties set out above may involve the transfer of data to jurisdictions outside the European Economic Area (EEA). Any such transfers are made in accordance with the requirements of Articles 44 to 49 of the GDPR. Where such transfers are made to countries that do not have an adequacy decision in place, appropriate safeguards such as European Commission approved standard contractual clauses will be put in place or your consent will be obtained prior to the transfer.
Data Subject Rights
Under and in accordance with the terms of the PDPO and codes and guidelines issued pursuant thereto, any individual may:
- check whether Hamon holds your personal data and request access to such data;
- request Hamon to correct any data relating to him/her/it which is inaccurate;
- request Hamon to cease using the said data for direct marketing purposes;
- ascertain Hamon’s policies and practices in relation to such data;
- be informed of the kind of such data held by Hamon;
- be informed of the main purposes for which personal data held by the data user are or are to be used; and
- make data access request and data correction request through the channel set out below.
You have the following rights, in certain circumstances, in relation to your personal information under the GDPR:
- Right to access your personal information;
- Right to rectify your personal information;
- Right to restrict the use of your personal information (in certain specific circumstances);
- Right to request that your personal information is erased (in certain specific circumstances);
- Right to object to processing of your personal information (in certain specific circumstances);
- Right to data portability (in certain specific circumstances); and
- Right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by the Manager or its Data Processors infringes the GDPR.