This privacy policy sets out how the Company, namely Blue Concept Asia Limited (“BCA”), uses and protects any information that you give BCA when you use this website – with effective date from 1 January 2020. BCA is committed to ensuring that your privacy is protected according to the Personal Data (Privacy) Ordinance (“PDPO”) of Hong Kong.
Should we ask you to provide certain information by which you can be identified when using this website (“Personal Data”), then you can be assured that it will only be used in accordance with this privacy statement. BCA may change this policy from time to time by updating this page. You should check this page as and when deemed necessary to keep abreast of the latest changes, if any.
The contact details for BCA’s Privacy and Data Compliance Officer are:
• By post:
Attention to the Data Protection Officer, Blue Concept Asia Limited, Unit B, 5/F, Winning Centre, 46-48 Wyndham Street, Central, Hong Kong.
• By email: info@blueconceptasia.com
• By telephone: +852 3705 8371
• By Fax: +852 3705 8374
This Privacy Policy supersedes any previous policies or equivalent which you may have been provided with or seen prior to the Effective Date stated above.
BCA may collect your personal data in several ways, for example:
• From the information you provide to BCA when you meet its representatives;
• From information about you provided to BCA by your company or an intermediary;
• When you communicate with BCA by telephone, fax, email, or other forms of electronic communication. In this respect, BCA may monitor, record and store any such communication;
• When you complete (or BCA completes on your behalf) client on-boarding or application or other forms;
• From other companies and/or associates within BCA’s organization;
• From your agents, advisers, intermediaries, and custodians of your assets;
• From publicly available sources or from third parties, most commonly where BCA needs to conduct background checks about you.
These Personal Data will help the BCA understand your needs and provide you with a better service, and BCA collects the following categories of personal data about you:
• Your name and contact information such as your home or business address, email address and telephone number;
• Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality;
• Information relating to your financial situation such as income, expenditure, assetsand liabilities, sources of wealth, as well as your bank account details;
• Information about your knowledge and experience in the investment field;
• An understanding of your goals and objectives in procuring BCA’s services;
• Information about your employment, education, family or personal circumstances,and interests, where relevant; and
• Information to assess whether you may represent a politically exposed person ormoney laundering risk.
The basis for processing your personal data (other than with your consent), how BCA uses that personal data and whom BCA share it with.
BCA processes your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
In this respect, BCA will use your personal data for the following:
• To prepare a proposal for you regarding the services BCA offers;
• To provide you with the services as set out in our Terms of Engagement with you or as otherwise agreed with you from time to time;
• To deal with any complaints or feedback you may have;
• For any other purpose for which you provide BCA with your personal data.
In this respect, BCA may share your personal data with or transfer it to the following:
• Your agents, advisers, intermediaries, and custodians of your assets who you tell BCA about;
• Third parties whom BCA engages to assist in delivering the services to you, including other companies within BCA’s organization;
• BCA’s professional advisers where it is necessary for BCA to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
• Other third parties such as intermediaries who BCA introduces to you. BCA will wherever possible tell you who they are before introduced you;
• BCA’s data storage providers.
BCA also processes your personal data because it is necessary for its legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.
In this respect, BCA will your personal data for the following:
• For marketing to you. In this respect, see the separate section on Marketing below;
• Training its staff or monitoring their performance;
• For the administration and management of its business, including recovering money you owe to BCA, and archiving or statistical analysis;
• Seeking advice on its rights and obligations, such as where BCA requires its own legal advice;
In this respect, BCA will share your personal data with the following:
• Its advisers or agents where it is necessary for BCA to obtain their advice or assistance;
• With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
BCA will also process your personal data for its compliance with a legal obligation which BCA is under.
In this respect, BCA will use your personal data for the following:
• To meet its compliance and regulatory obligations, such as compliance with anti money laundering and counter-terrorist financing laws;
• As required by tax authorities or any competent court or legal authority.
In this respect, BCA will share your personal data with the following:
• Its advisers where it is necessary for BCA to obtain their advice or assistance;
• Its auditors where it is necessary as part of their auditing functions;
• With third parties who assist BCA in conducting background checks;
• With relevant regulators or law enforcement agencies where BCA is required to do so.
BCA will send you marketing about similar services BCA provides, as well as other information in the form of alerts, newsletters and invitations to events or functions which BCA believes might be of interest to you.
BCA will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.
If you object to receiving marketing from us at any time, please contact us:
• By post: Attention to the Data Protection Officer, Blue Concept Asia Limited, Unit B, 5/F, Winning Centre, 46-48 Wyndham Street, Central, Hong Kong.
• By email: info@blueconceptasia.com
• By telephone: +852 3705 8371
• By Fax: +852 3705 8374
BCA is committed to ensuring that your Personal Data is secure. In order to prevent unauthorized access or disclosure, BCA has put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Data BCA collects online.
BCA will retain your Personal Data only for so long as it is necessary for fulfilling the purposes for which they are collected. After that time, unless BCA is under any legal or regulatory obligation to keep your Personal Data, your Personal data will be erased.
In particular:
• where BCA has collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, BCA will retain that personal data for five years after the termination of the relationship, unless BCA is required to retain this information by another law or for the purposes of court proceedings; or
• otherwise, BCA will in most cases retain your personal data for a period of seven years after the termination of the contractual or other relationship with you in case any claims arise out of the provision of its services to you.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie will help web traffic or let you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
BCA uses traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
If you have previously agreed to us using your Personal Data for direct marketing purposes, you may change your mind at any time and restrict the use of your Personal Data by writing to, or emailing, us at info@blueconceptasia.com.
We will not sell, distribute, release, or disclose your Personal Data to third parties unless we have your permission or are required by law to do so. We may use your Personal Data to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of Personal Data which we hold about you under the Personal Data (Privacy) Ordinance of Hong Kong. A small fee may be payable. If you would like to get a copy of the Personal Data held about you, please write to Blue Concept Asia Limited, Unit B, 5/F, Winning Centre, 46-48 Wyndham Street, Central, Hong Kong.
If you believe that any information, we are holding about you is incorrect, incomplete, or outdated, please write to, or email, us as soon as possible at the above address. We shall update your Personal Data as soon as practicable.