We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us (including but not limited to the bullion account and forex account), developing and providing various financial and consultation services and the billing and charging of our products and services (if applicable) (collectively, “Service(s)”)) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:
(a) the name, birth month and other details documented on your passport or other legal identity card and/or travel document;
(b) the nationality/place of residence/location/personal information declared by you and other relevant documents;
(c) contact details including but not limited to name, address, phone number, mobile telephone number and/or email address, etc.;
(d) Data that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details), etc.;
(e) payment details including but not limited to credit card, debit card and other electronic banking Data;
(f) account details or Data relating to Services registered with us including but not limited to the relevant PIN, username or password, account numbers and/or service numbers;
(g) device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
(h) information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
(i) your credit and service history to enable us to assess your eligibility to our offers of Services or to accommodate your request for transfer of Services or your account with us;
(j) all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
(k) any other Data as may be required by any members of us and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Services.
(l) In some instances, where required by law to do so, we may seek your consent to process the following types of “Special Data” to us so that we may further improve our Services and/or better tailor the type of information or content that we present to you:
(i) age;
(ii) gender and ethnicity;
(iii) marital status;
(iv) Month of birth;
(v) education and profession;
(vi) monthly income range;
(vii) hobbies and leisure activities;
(viii) the Services that you have subscribed for; and
(ix) contact details, etc.
We collect Data in a number of ways, including from:
(a) you directly, for example, when you provide Data by phone or via email, attend our functions, complete an application form or agreement for one of our Services, or when you submit your Data through our websites, mobile apps, or online chat sessions; or when you contact us with a query or request; or during the ordinary course of the continuation of our business relationship with you; or when we are legally required to do so;
(b) third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;
(c) publicly available sources;
(d) our own records of how you use our Services;
(e) your visits on our websites, or mobile apps (see “Privacy Data” section below); and/or
(f) your participation in surveys or marketing promotions organised by us or on our behalf, etc.
To better serve your needs and preferences, our web servers may collect Data relating to your website, device or app activity. We may also collect aggregated, anonymous, statistical data on the server's usage so that we may better cater to the behaviour of users of our websites and mobile apps. This type of Data may include, but is not limited to:
(a) browser type, version and user agent;
(b) operating system;
(c) IP (Internet Protocol) address and/or domain name;
(d) connection data, statistics on page views and/or referral URLs;
(e) device ID, location and phone contacts;
(f) videos watched or searched for;
(g) links or images clicked on;
(h) cookies and/or browser, app or web server log data; and
(i) device and software characteristics and/or configuration.
We may collect, retain and use your Data for the following purposes:
(a) to verify your identity;
(b) to submit your information (including but not limited to the application for the transfer of the account (if applicable)) and related documents to the designated third party institution according to your declared nationality/place of residence/location/personal information;
(c) to facilitate daily operations of services provided to you;
(d) to tailor-make services or related products in relation to your bullion transactions;
(e) to provide any Services in relation to your account held with us;
(f) to process your application to subscribe to our Services;
(g) to carry out matching procedures, as defined under the Ordinance;
(h) to verify your eligibility to our offers of Services, games and/or promotions or other events;
(i) to provide, activate and/or renew Services, membership program and/or relevant services or plans that you may have subscribed for;
(j) to provide you with promotional benefits, updates, offers and invitation to events;
(k) to promote and market our Services to you;
(l) to provide suitable advertisement and website contents to you;
(m) to provide suitable products or services to you;
(n) to provide anonymous report and to send member notice to us or our clients;
(o) to conduct credit checks and detect fraudulent activities in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615 of the Laws of Hong Kong) or any other relevant regulations and in relation to other compliance purposes;
(p) to perform statistical analyses or research or analyses so that we may improve and optimise the Services that can be made available to you;
(q) to conduct surveys and marketing, promotional, behavioural scoring for business operations and/or planning purposes;
(r) to carry out market and product analyses in order to generate statistical or actuarial reports (containing aggregated data that does not relate to any identified or identifiable individual);
(s) to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Services to you;
(t) to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
(u) to maintain, enhance and develop our products and service offerings;
(v) to determine the amount of debt owed by you or your default; (if any)
(w) to charge you arrears, interest and handling fees; (if any)
(x) to assist in daily lending matters; (if any)
(y) to assist in the required review of the loan; (if any)
(z) to evaluate the level of indebtedness owed to or by you from time to time; (if any)
(aa) to determine the amount of indebtedness owed to or by you;
(bb) to collect amounts outstanding from you and those providing security for your obligation;
(cc) to assist other financial institutions to conduct credit checks and collect debts;
(dd) to perform any acts in relation to any of the aforesaid;
(ee) to comply with applicable laws in or outside Hong Kong as may be required by applicable government authorities, courts, law enforcement, or regulatory or investigation bodies, in relation to the supply of Services and/or loyalty programs to you, including to assist in the prevention, detection of crime or possible criminal activities; and
(ff) to distribute our publications and research materials as well as those of our business partners and counterparties.
These Organisations provide support services to our businesses and operations including without limitation:
(a) customer enquiries;
(b) mailing operations;
(c) billing and debt-recovery functions;
(d) information technology services;
(e) installation, maintenance and repair services;
(f) marketing, advertising and telemarketing services;
(g) market research;
(h) customer usage and behavioural analysis;
(i) process management;
(j) surveys; and
(k) website usage analysis, etc.
In addition, we may disclose your Data:
(a) to us and the designated company for the purpose of providing services or product promotion;
(b) to any director, officer, employee or representative of the company (when performing the business of the company);
(c) to any person authorized by us to handle confidential information;
(d) to your authorised representatives and/or your legal advisers when requested by you to do so;
(e) for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties:
(i) telecommunications network operators;
(ii) administrative, telecommunications, computer, data processing contractors;
(iii) online network maintenance contractors;
(iv) securities settlement, agent, custodian;
(v) our affiliates, overseas offices, assignees, transferees and representatives;
(vi) our professional advisers, including our accountants, auditors, lawyers and insurers;
(f) to third party financial institutions, banks, hotels, insurance companies, insurance brokers, underwriters, securities and investment service providers, billing agents and various business collaboratros for reward redemption purposes and benefits applicable to members of our loyalty programs, including without limitation for the purpose of registering members for loyalty program related events;
(g) to any financial institution and its affiliates with whom you wish to establish or have a business relationship with;
(h) to a credit reference agency and (if there is a default) financial company;
(i) to government and regulatory authorities and other organisations, as required or authorised by law;
(j) to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business; and/or
(k) to charities or non-profit organisations, etc.
All required efforts are made to ensure that any Data held by us is stored in a secure and safe place and is accessible only by our authorised employees or other Organisations referred to in this Privacy Policy Statement.
When we pass your Data to third party Organisations for them to process, we seek to ensure that they have appropriate security measures in place to keep your Data safe and to comply with applicable principles in relation to data protection. Some of the people we share your Data with may process it overseas. You can contact us for more information about the safeguards we use to ensure that your Data is adequately protected in these circumstances.
We will retain your Data in accordance with our internal policies. Our policies are in compliance with the Ordinance where applicable, and cover the following principles:
(a) Data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
(b) Data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.
We take all reasonable precautions to ensure that the Data we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that Data depends to a large extent on the Data you provide. You have a right to request access to, and correction of, your Data and we recommend that you:
(a) let us know if there are any errors in your Data; and
(b) keep us up-to-date with changes to your Data.
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:
Data Protection Officer
DL Securities (HK) Limited
Unit 2801 Vertical Square, 28 Heung Yip Road, Wong Chuk Hang, Hong Kong
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