Privacy Ordinance

1. From time to time, it may be necessary for you to supply GPSL and/or any member of GPSL with data in connection with the opening or continuation of Accounts and the establishment or continuation of credit facilities or provision of the relevant trading, nominee and/or investment advisory services. The data is collected pursuant to applicable laws, regulations, rules or codes binding on GPSL and/or any member of GPSL.
2. Failure to supply such data may result in GPSL and/or any member of GPSL being unable to open or continue accounts or establish or continue credit facilities or provide securities trading nominee and/or investment advisory services to you.
3. It is also the case that data may be collected from you in the ordinary course of the continuation of the business relationship.

1. the daily operation of the related services and credit facilities provided to you;
2. conducting credit checks;
3. assisting other financial institution to conduct credit checks;
4. ensuring on-going credit worthiness of you;
5. designing financial services or related products for your use;
6. marketing financial services, relating products and other subjects (please see further details in paragraph 7 below);
7. collection of amounts outstanding from you and amounts as security for your obligations;
8. Meeting the requirements to make disclosure under the requirements of any law,
9. purposes ancillary or relating to any of the above.
10. Data held by GPSL and/or any member of GPSL relating to you will be kept confidential but GPSL and/or any member of GPSL may provide such information to the following parties for the purposes set out in paragraph 4:-
11. 1 any member of GPSL, including the holding companies of Grand Partner Limited.
12. 2 any agent, contractor or third party service provider who provides administrative, telecommunications, computer, legal, accounting, payment or securities clearing or other services to GPSL and/or any member of GPSL in connection with the operation of its business;
13. 5.3 any other person under a duty of confidentiality to GPSL and/or any member of GPSL;
14. 5.4 any financial institution with which you have or propose to have dealings;
15. 5.5 any actual or proposed assignee of GPSL and/or any member of GPSL or participant or sub-participant or transferee of GPSL’s rights in respect of you;
16. 5.6 any person to whom GPSL and/or any member of GPSL is compelled by law or by relevant regulatory authorities to make disclosure;
17. 5.7 any person with your express or implied consent;
18. 5.8 any person where GPSL’s and/or any member of GPSL’s interests require disclosure;
19. 5.9 any person where the public interest requires disclosure.
20. 6. In the course of performing GPSL’s and/or any member of GPSL’s duties, GPSL and/or any member of GPSL may as permitted by law, match, compare transfer or exchange any
21. personal data provided by you with data held, or hereafter obtained, for these or any other purposes by GPSL and/or any member of GPSL, government bodies, other regulatory authorities, corporations, organizations or individuals in Hong Kong or overseas for the purpose of verifying those data
22. 7. Use of Data in Direct Marketing
23. GPSL (the “Company”)intends to use the subject's data in direct marketing and the Company requires the data subject's consent (which includes an indication of no objection) for that purpose. The specific requirement regarding data subject's consent (which includes an indication of no objection). In this connection, please note that:
24. 7.1 the name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data of the data subject held by the Company from time to time may be used by the Company in direct marketing;
25. 7.2 the following classes of services, products and subjects may be marketed:
26. 7.2.1 financial, securities, commodities, investment and related services and products and facilities;
27. 7.2.2 reward, loyalty or privileges programs and related services and products;
28. 7.2.3 services and products offered by the Company's co-branding partners; and
29. 7.2.4 donations and contributions for charitable and/or non-profit making purposes;

• 8. Under and in accordance with the terms of the PDPO any individual:-
• 8.1 has the right to check whether GPSL and/or any member of GPSL holds data about him/her and the right of access to such data;
• 8.2 has the right to require GPSL and/or any member of GPSL to correct any data relating to him/her which is inaccurate; and
• 8.3 has the right to ascertain GPSL’s and/or any member of GPSL’s policies and practices in relation to data and to be informed of the kind of personal data held by GPSL and/or any member of GPSL.
• 9. In accordance with the terms of the PDPO, GPSL and/or any member of GPSL has the right to charge a reasonable fee for the processing of any data access request.
• 10. The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:-