This Privacy Policy describes how Sino Group collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our websites. Our Group is committed to complying with the relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance, the Cayman Islands Data Protection Law, the EU General Data Protection Regulation, the British Virgin Island’s Data Protection Act, the Personal Information Protection Law of the People’s Republic of China and any applicable data protection laws in other jurisdictions.

“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control, including but is not limited to:

• 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, assets and
  liabilities, sources of wealth, as well as your bank account details;
• 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 or money laundering risk.

We will collect and process the following personal information about you:

We will process personal information that you give to us including when you email us or contact us through various channels as follows:

We will also collect information about when you use our services or when we otherwise interact or correspond with you. If you visit any of our offices in person, your image may be captured on our CCTV system. We operate a CCTV system to protect our buildings and assets from damage, for the personal safety of our staff and visitors and to support law enforcement bodies in the prevention, detection and prosecution of crime.

We will also collect your information that you have chosen to make public (e.g. via public websites and registers and other public sources.). We will also receive your information third parties who provide it to us such as your advisers, intermediaries, relevant legal and regulatory authorities or other third parties. This might include information obtained for the purposes of our “know your client” procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-persons checks, sanctions checks, amongst other things).

We may do the following with your personal information:

We rely on the following legal grounds to process your personal information, namely:

• • Consent – we may need your consent to use your personal information. You can withdraw your consent by contacting us.
  • Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
  • Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above.
  • Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation.

 

 

• Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
• Any relevant party, bound by obligations of confidentiality, in connection with our anti-money laundering requirements (e.g. World-Check which carry out sanctions checks on our behalf).
• Third party service providers (such as payment services providers and banks).
• Third parties to whom you request us to send your personal information;
• Our professional advisers (such as our auditors, accountants and lawyers);
• Regulators, government bodies and tax authorities, when required by applicable laws and regulations (this includes the US Foreign Account Tax Compliance Act (FATCA) and associated inter-governmental agreements and the EU Directive 2014/107/EU on the automatic exchange of information in the field of taxation);
• Any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law and regulation; and
• Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law and regulation.

Due to the international nature of our business, we may transfer, store, or process your personal information in locations outside the jurisdiction in which you are based. When we do this, we will ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and/or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities. Even in these cases, we will only share your information with people who have the right to see it.

 

Keeping your information and information security

How long we hold your personal information for will vary and will depend principally on:

• the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information, in particular, we are required to keep your personal information that we have collected for the purpose of discharging our money laundering obligations for at least 5 years from the end of the relevant client relationship while with regard to any of your information forming part of our tax records, those records are required to be kept for at least 7 years.

We will ensure that the personal information that we hold is subject to appropriate security measures.

You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us.
Subject to the data protection laws applicable to you, these rights include:

• Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
• Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
• Requesting that we correct your personal information if it is inaccurate, incomplete, misleading or not-up-to-date.
• Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
• In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
• Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
• We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

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If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us at dataprotection@sinocsl.com.