Privacy Policy

Notes on the Personal Data (Privacy) Ordinance (PDPO)

When providing services to its clients and other parties, Hamon Investment Group Pte Limited and its subsidiaries and/or affiliates (“Hamon”) 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 the Company. 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.

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.

In accordance with the provisions of the PDPO, Hamon has the right to charge a reasonable fee for processing any data access request. Requests may be made in writing to Hamon at: Hamon Investment Group 3510-3515 Jardine House 1 Connaught Place Central, Hong Kong