This Notice sets out the data policies of  YY ADVISORY (“the Company”) in respect of their respective data subjects (as hereinafter defined).

1. The term “data subject(s)”, wherever mentioned in this Notice, includes the following categories of individuals :
   1. applicants for or customers, authorized signatories, and other users of financial/related services or products and so forth provided by the Company; and
   2. directors, shareholders, officers and managers of any corporate applicants and Data Subjects/users.
2. “Data subjects” does not include any incorporated entities. The contents of this Notice shall apply to all data subjects and form part of any contracts for services that the data subjects have or may enter into with the Company from time to time. If there is any inconsistency or discrepancy between this Notice and the relevant contract, this Notice shall prevail insofar as it relates to the protection of the data subjects’ personal data. Nothing in this Notice shall limit the rights of the data subjects under the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”).
3. From time to time, it is necessary for the data subjects to supply the Company with personal data in connection with the opening or renewal or termination of accounts; the establishment or renewal or termination of financial/related services or products.
4. Failure to supply respective personal data may result in the Company being unable to open or renew or terminate accounts; or establish or renew or terminate financial/related services or products.
5. Data relating to the data subjects are collected or received by the Company from various sources from time to time. Such data may include, but not limited to, data collected from data subjects in the ordinary course of the relationship between the Company and the Data Subject, for example, when Data Subject effects or executes the financial/related services or products serviced by the Company or generally communicate verbally or in writing with the Company.
6. The purposes for which the data relating to the data subjects may be used are as follows:
   1. assessing the suitability of the Data Subject as actual customer or potential applicants for financial /related services and products and/or processing and/or approving their applications, variation, renewals, replacements, cancellations, redemptions, reinstatements and claims;
   2. facilitating the daily operation of the services provided to the Data Subjects;
   3. conducting background checks whenever appropriate (including, without limitation, at the time of application and at the time of regular or special reviews which normally will take place one or more times each year) and carrying out matching procedures (as defined in the Ordinance);
   4. creating and maintaining the Company’s scoring models;
   5. ensuring ongoing credit worthiness of Data Subjects;
   6. researching, customer profiling and segmentation and/or designing financial and related services and products for Data Subjects’ use;
   7. marketing services, products and other subjects (please see further details in paragraph 9 of this Notice);
   8. determining amounts owed to or by the Data Subjects;
   9. enforcing Data Subjects’ obligations, including without limitation the collection of amounts outstanding from Data Subjects’ obligations;
   10. complying with the obligations, requirements or arrangements for disclosing and using data that apply to the Company or any of its offices or authorized agents or that it is expected to comply according to:
       1. any law binding or applying to it within or outside the Hong Kong Special Administrative Region existing currently and in the future;
       2. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside the Hong Kong Special Administrative Region existing currently and in the future;
       3. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on the Company or any of its offices or authorized agents by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
   11. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Company and/or any other use of data and information in accordance with the compliance program for sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
   12. maintaining a history or otherwise, a record of Data Subjects (whether or not there exists any relationship between Data Subjects and the Company) for present and future reference; and
   13. purposes incidental, associated or relating to the abovementioned purposes.
7. Data held by the Company relating to data subjects will be kept confidential but the Company may provide and disclose (as defined in the Ordinance) such data to the following parties for the purposes set out in the previous paragraph:
   1. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or settlement or other services to the Company in connection with the operation of its business, wherever situated;
   2. any other person under a duty of confidentiality to the Company which has undertaken to keep such information confidential;
   3. any person to whom the Company is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to the Company, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which the Company or any of its branches are expected to comply, or any disclosure pursuant to any contractual or other commitment of the Company or any of its branches with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside the Hong Kong Special Administrative Region and may be existing currently and in the future;
   4. any member of the Group;
   5. third party reward, loyalty, co-branding and privileges programme providers;
   6. co-branding partners of the Company (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be);
   7. external service providers (including but not limited to mail service companies, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that the Company engages for the purposes set out in paragraph (8)(a) above, wherever situated.

The Company may from time to time transfer the data relating to the data subjects to a place outside Hong Kong Special Administrative Region for the purposes set out in paragraph 7 above.

8. USE OF DATA IN DIRECT MARKETING
   
   The Company intends to use the data subject’s data in direct marketing and the Company requires the data subject’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
   1. the name, contact details, products and services information, transaction pattern and behaviour, financial background and demographic data of the data subject held by the Company from time to time may be used by the Company in direct marketing;
   2. the following classes of services, products and subjects may be marketed:
      1. financial and related services and products and facilities;
      2. reward, loyalty or privileges programs and related services and products; and
      3. services and products offered by the Company’s co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be).
   3. in addition to marketing the above services, products and subjects itself, the Company also intends to provide the data described in paragraph 9(a) above to all or any of the persons described in paragraph 9(b) above for use by them in marketing those services, products and subjects, and the Company requires the data subject’s written consent (which includes an indication of no objection) for that purpose;

If a data subject does not wish the Company to use or provide to other persons his data for use in direct marketing as described above, the data subject may exercise his opt-out right by notifying the Company.

9. Under and in accordance with the terms of the Ordinance, any data subject has the right:
   1. to check whether the Company holds data about him and of access to such data;
   2. to require the Company to correct any data relating to him which is inaccurate; and
   3. to ascertain the Company’s policies in relation to data and to be informed of the kind of personal data held by the Company.
10. In accordance with the terms of the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
11. Please address your requests for data access or correction, or for information about the data policy or kinds of data held, to the personnel stated below:

12. In case any inconsistency between the English and Chinese versions of this Statement, the English version shall prevail.

January 2020