Data Privacy Policy of Well Link International Securities Limited (“WLISL”)

Please read the following before you send WLISL any Personal Data.

From time to time, it is necessary for customers to supply WLISL with data in connection with the opening or continuation of accounts and the establishment or continuation of credit facilities or provision of financial and/or other services.

Failure to supply such data may result in WLISL being unable to open or continue accounts or establish or continue credit facilities or provide financial or other services.

Data maybe collected from customers in the ordinary course of the continuation of the business relationship between customers and WLISL.

Providing personal information to WLISL through electronic means (such as e-mail, Internet or voice recording system) cannot be guaranteed to be completely secure. WLISL will not be responsible for any damage suffered by users if they send any information to WLISL through electronic devices, or if WLISL sends any information through electronic devices at the request of the user. Customers should take heed of such weaknesses and communicate personal information through electronic devices with caution.

WLISL will not collect any personal information that identifies a visitor to this Website unless specified otherwise. Your visit to this Website will record only the Domain Name Server, part of your email address and of the pages visited. Such information will be used to prepare aggregate information about the number of visitors to the Website and general statistics on usage patterns of the Website.

The purposes for which data relating to customers may be used (whether within or outside Hong Kong) are as follows:

i. the daily operation of the services and credit facilities provided to customers;

ii. conducting credit checks;

iii. assisting other institutions to conduct credit checks;

iv. ensuring ongoing credit worthiness of customers;

v. designing financial services or related products for customers’ use;

vi. marketing financial services or related products;

vii. determining the amount of indebtedness owed to or by customers;

viii. meeting the requirements to make disclosure under the requirements of any legal and/or regulatory requirements or court orders binding on WLISL; and

ix. purposes relating to any of the above.

How Data are stored:

a. In accordance with provisions of the laws and regulations, WLISL shall store your personal information that we collect within the territory of the People's Republic of China (hereinafter referred to as“China”) and shall keep such information strictly confidential. Where the personal information of relevant users collected by us within the territory of China needs to be transmitted to any overseas agency in certain situations, WLISL shall execute it in accordance with the provisions of the laws, administrative regulations and supervision departments, and shall request such overseas agency to keep your personal information confidential, by signing agreements, on-site verification or other effective measures.

b.Generally, WLISL will retain your personal information for no longer than is necessary for the purposes stated in this Policy. However, in any of the following conditions, WLISL may change the storage time of your personal information for complying with legal requirements:

i. To abide by relevant provisions of applicable laws and regulations;

ii. To abide by the provisions of court decision, ruling or other legal procedures;

iii. To abide by requirements by relevant government agencies or organizations of legal authorization;

iv. Purposes reasonably necessary for fulfilling relevant service agreements or this Policy, protecting social and public interests, protecting personal and property safety or other legitimate interests of our customers, WLISL or WLISL’s affiliated companies, other users or WLISL’s employees.

Use of Data in Direct Marketing:

WLISL intends to use and/or transfer the Customer’s data to any related companies of WLISL for direct marketing and WLISL requires the consent (which includes an indication of no objection) of the Customer for that purpose. In this connection, please note that:

a. Your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by WLISL from time to time may be used by WLISL in direct marketing;

b. The following classes of services, products and subjects may be marketed:

i. securities, commodities, investment and related services and products;

ii. reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to in clause b(i) above; and

iii. donations and contributions for charitable and/or non-profit making purposes.

c. If a Customer does not wish WLISL to use and/or transfer the Customer’s data for use in direct marketing, the Customer may, without charge, exercise the right to opt-out. Data held by WLISL relating to a customer will be kept confidential but WLISL may provide such information to the following parties (whether within or outside Hong Kong):

i. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, financial, trade execution, cash, securities and/or contracts clearing or settlement or other services to WLISL in connection with the operation of its business;

ii. any other person under a duty of confidentiality to WLISL including a group companies of WLISL which has undertaken to keep such information confidential;

iii. any financial institution or dealer with which the customer has or proposes to have dealings;

iv. any credit reference agency and in the event of default, any debt collection agency;

v. any actual or proposed assignee of WLISL or participant or sub-participant or transferee of the rights of WLISL in respect of the customer; and

vi. any exchange, entity, agency, regulatory or government body in any jurisdiction if required by law or pursuant to any court orders, rules or regulations to which WLISL is subject. In such cases, WLISL is usually under a duty of secrecy and will not be able to notify a customer or seek his consent in relation to such release of information.

Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (Cap. 486) (the (“Ordinance”), an individual has the right to:

i. check whether WLISL holds data about him and the right of access to such data;

ii. require WLISL to correct any data relating to him which is inaccurate; and

iii. ascertain WLISL’s policies and practices in relation to data and to be informed of the kind of personal data held by WLISL.

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:

The Data Protection Officer

Well Link International Securities Limited.

Tel   : (852)-3150 7888

Fax  : (852) 3150 7668

Address: Unit 13-15, 11/F, China Merchants Tower, Shun Tak Centre, 168-200 Connaught Road Central, Hong Kong

In accordance with the terms of the Personal Data (Privacy) Ordinance, Cap.486 of the Laws of Hong Kong (“the Ordinance”), WLISL has the right to charge a reasonable fee for the processing of any data access request.

In addition to WLISL’s duty of confidentiality to customers, WLISL shall at all times observe the above privacy principles and the Ordinance of the Hong Kong SAR in collecting, maintaining and using the personal data of customers.

This Policy may be revised, amended or supplemented from time to time by WLISL.