Privacy Policy

When you invest in Hamon products, you provide us with your Personal Data. We collect and use this information to service your accounts and respond to your requests. The Personal Data we collect includes such information as the following: 

• Information we receive from you on applications or other forms, whether we receive the form in writing or electronically. For example, this includes such information as your name, address, tax identification number, birth date, investment selection, beneficiary information, and possibly your personal bank account information and/or email address if you are signing up for certain account related options.
• Your email address, which we collect when you request for further information regarding Hamon’s investment products or services shown in Hamon’s website or request subscription to our newsletters.
• Information about your transactions and account history with us, or with other companies that are part of Hamon, including transactions you request on our website. This category also includes your communications to us concerning your investments.
• Other general information that we may obtain about you, such as demographic information.

Hamon uses the Personal Data for the purpose of fulfilling the services required by the individuals visiting this website, current and former investors, and complying with its legal obligations, such as: 

• maintaining the register of investors;
• processing subscriptions, redemptions, and conversions of shares and payments of dividends to investors;
• maintaining controls in respect of late trading and market timing practices;
• complying with applicable anti-money laundering rules;
• marketing purposes;

As permitted by law, it is sometimes necessary for us to share your information with companies that perform administrative or marketing services on our behalf, such as transfer agents and/or mail facilities that assist us in shareholder servicing or distribution of investor materials, as well as other Hamon entities, the distributors of Hamon, and financial service providers offering banking, trust, and custodial products and services, to better service your account. These companies will use this information only for the services for which we hired them and are not permitted to use or share this information for any other purpose.
We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with standards to protect your personal information.

To better service your accounts, as mentioned, we may share your Personal Data with Hamon data recipients (the “Recipients”), which include other Hamon entities, the distributors of Hamon, and financial service providers offering banking, trust, and custodial products and services.

We will only share Personal Data with outside parties in the limited circumstances permitted by the Data Protection Law stipulated in The Personal Data (Privacy) Ordinance (the “PDPO”) of Hong Kong. For example, this includes situations where we need to share information with Recipients who work on our behalf and upon our written instructions to service or maintain your account or process transactions you’ve requested, when the disclosure is to a party representing you, or when required by law (for example, in response to legal process). 

Additionally, we will ensure that any Recipient assisting us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your Personal Data and ensure its security, and to use it only to provide the services we’ve asked them to perform. 

Hamon might share some of your Personal Data to Recipients that may be located in countries that do not offer an adequate level of protection to personal data. In such cases, said transfers shall be made on the basis of adequate contractual arrangements.

The Recipients may, as the case may be, process Personal Data as data processor (when processing Personal Data upon our instructions, to assist Hamon in the context of the aforementioned purposes) or as distinct data controllers (when processing Personal Data for their own purposes).

Hamon also adheres with the provisions of the EU General Data Protection Regulation (GDPR), adopted in 2016, which replaces the EU Directive 95/46/EC on the protection of individuals with regard to the processing and free movement of personal data. Please refer to https://gdpr-info.eu for further details and information on the GDPR.

Hamon is committed to protecting your privacy and maintaining confidentiality of your personal information and devote a significant amount of resources to help ensure that we deliver on our commitment.

Measures that have been implemented for this purpose include:-

1. Regular compliance training for all employees on the protection of private and confidential information, specific privacy regulations and on cybersecurity;
2. Maintaining physical, electronic, and procedural safeguards that comply with government and industry standards to protect your personal information;
3. Limiting access to your personal information to authorized Hamon employees or agents and, as described above in clause 3 (Disclosures), our service providers are held to stringent standards of privacy; 4) Maintaining physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure;
4. Maintaining an Information Security program whose key features are:
   1. A dedicated group, Hamon’s Information Technology Department, that designs, implements and provides oversight of our information security program;
   2. The use of specialized technology for cybersecurity protections;
   3. Testing of the security and operability of services before they are introduced on our systems, such as ongoing scanning for publicly known vulnerabilities in the technology;
   4. Monitoring of our systems’ infrastructure to detect weaknesses and potential areas for intrusions, and
   5. Implementing controls to identify and authorize access to various systems or site.

Our employees are required to follow procedures with respect to maintaining the confidentiality of our investors’ non-public personal information. Additionally, we maintain physical, electronic, and procedural safeguards to protect the information. This includes performing ongoing evaluations of our systems containing investor information and making changes when appropriate.

We will only share Personal Data with outside parties in the limited circumstances permitted by the PDPO, as mentioned in clause 3 above (Disclosures). Please refer to clause 3 on Disclosures for further examples of how and where the Personal Data may be used.

Under certain conditions set out by the Personal Data (Privacy) Ordinance, you have the right: 

• to access your Personal Data (i.e. the right to obtain from Hamon Investment Group confirmation as to whether or not Personal Data are being processed, to be provided with certain information about Hamon Investment Group’s processing of the Personal Data, to access to that data, and to obtain a copy of the Personal data undergoing processing (subject to legal exceptions));
• to ask for a rectification thereof in cases where such Personal Data is inaccurate or incomplete (i.e. the right to require from Hamon Investment Group that inaccurate or incomplete Personal Data be updated or corrected accordingly);
• to object to the processing of your Personal Data (i.e. the right to object, on grounds relating to your particular situation to processing of Personal Data which is based on the performance of a task carried out in the public interest or the legitimate interest of Hamon Investment products. Hamon Investment Group shall stop such processing unless it can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or that it needs to process the data for the establishment, exercise or defense of legal claims);
• to ask for deletion of such data (i.e. the right to require that your Personal Data be erased in certain circumstances, including where it is no longer necessary for Hamon Investment Group to process this data in relation to the purposes for which it collected or processed); and
• to ask for data portability (i.e. the right to have the data transferred to you or another data controller in a structured, commonly used and machine-readable format, where this is technically feasible).

Personal Data shall not be held for longer than necessary with regard to the purpose of the data processing, subject to statutory periods of limitation.

You may exercise the rights thereto by contacting us in writing in this regard at the following address: Hamon Investment Group, The Data Privacy Officer, Room 1001, 10th Floor, Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Hong Kong or at privacy@hamon.com.hk

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong Data Protection Commission (“DPC”), or with any competent data protection supervisory authority in your country of residence.

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