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Privacy

We are committed to safeguarding your privacy and ensuring that your Personal Data is protected. This Privacy Policy Statement explains the types of Personal Data we collect and how we process and protect that data. We will keep your Personal Data confidential and ensure that our policies and practices regarding the collection, use, retention, disclosure, transfer, security, and access of your Personal Data comply with the laws and regulations of Hong Kong.

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Personal Information Collection Statement (“PICS”)

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  • This PICS is issued pursuant to the PDPO in relation to the operation of our business by Alpha Nova Capital Management Limited and its subsidiaries (together referred to as “we” or “our” or “us”).

  • This PICS is last updated on the Effective Date.

  • Definitions

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Under this PICS, unless the context otherwise requires, the following words and expressions shall have the following meanings:

  1. “Database” means the database of our customers’ Personal Data

  2. “Effective Date” means June 5th, 2023

  3. “Affiliates” means any subsidiary or holding company of Alpha Nova Capital Management Limited or any other subsidiary of such holding company, which operates the Services business

  4. “Website” means Alpha Nova Capital Management Limited's website

  5. “Subsidiary” means all the entities controlled by and operating under Alpha Nova Capital Management Limited, offering Services to customers

  6. “PDPO” means the Personal Data (Privacy) Ordinance (Cap.486), laws of Hong Kong

  7. “Personal Data” has the meaning ascribed to it in this PICS

  8. “Services” means the provision of services in relation to any of the following (whether through physical or online channels): financial and related training and services.​

 

Personal data: what we collect, why, and how

 

  • To become a Registered Customer and enjoy our various services, it is necessary for you to provide us with the essential Personal Data as indicated at the time of collection. We may also request additional information that helps us provide you with tailored services that we believe may be of interest to you. The types of personal data (“Personal Data”) we may collect include the following:​

    • Information about you: Your personal information, such as your name, gender, date of birth, nationality, contact details (i.e., residential and corresponding addresses), telephone number, and email address.

    • Your payment details: Payment details such as cardholder name, credit or debit card number, expiry date, account information relating to other payment services, and billing information.

    • Your interests, preferences, habits, and opinions: Information that we collect about your interests, preferences, habits, and opinions, such as your hobbies, destinations, and awards, including services and events you are interested in, your opinion on our offers, and your feedback.

    • Our interactions with you: A record of any interactions and correspondence between us, such as calls made through our call center, any interactions you have with our staff or representatives, and interactions on social media.

    • Survey information: Your responses to surveys, research, and contests conducted by us or on our behalf.

    • Your use of our website and social media platforms: Details of your visits to our website and your use of social media platforms and other information collected through cookies and tracking technology.

    • Certain Personal Data (particularly payment details, contact information) is required for our services. You agree to provide such Personal Data on a voluntary basis, understanding it is optional. If you fail to supply such Personal Data as requested for specific services, we may be unable to deliver our services fully.

    • We shall have the right to collect, hold, process, and/or use the Personal Data in the Database for the purposes set out in this PICS. If you are unable or unwilling to provide complete and correct Personal Data, we may not be able to provide or continue to provide our services to you.

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Use of your personal data

  1. You agree that the Personal Data you provide to us may be used and retained by us:

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  • to process your application as a Registered Customer;

  • to provide you with our services;

  • to provide you with regular communications from us with details of our business and relevant benefits;

  • to provide you with services which you have requested;

  • to operate and facilitate your participation in membership programs, such as processing your membership application, and to ensure that you get the benefit of our membership programs;

  • to administer your earning and redemption arrangements, to send you service-related communications, to identify and verify your identity in connection with the services we provide, and to provide or facilitate any special assistance you may have asked for;

  • to carry out data sorting and analysis to enable us to better understand your characteristics and buying behaviou,r and to provide other services better tailored to your needs, and to assist us in selecting services that are likely to be of interest to you. To conduct aggregated behavioural analysis and tailor and personalize the awards and offers that we provide to you. We may also tailor our communications to you and tailor what we present to you to match your preferences and interests better;

  • to provide member support, including responding to your enquiries, providing general assistance;

  • for marketing purposes to provide you with marketing communications;

  • for legal and administrative purposes such as to comply with our legal and regulatory obligations, disclosure as required by applicable laws and regulations, prevention and detection of crime, verifying and processing payment, screening against fraud, criminal or unlawful activities, investigation of complaints, suspected suspicious transactions, and research for service improvement, accounting, billing and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.

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Who do we share your Personal Data with

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In certain circumstances, we will disclose your personal data to the following parties (“Data Transferees”) as described below:

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  • We will permit our third-party service providers, including agents, contractors, and our Affiliates, to use your Personal Data on our behalf for the purposes set out in this PICS. Such agents and contractors include operators of our IT systems.

  • We may disclose your Personal Data to our Affiliates, so they can provide marketing services or conduct marketing or social interaction activities on our behalf, such as campaigns, market research, member surveys, and data analytics to help us improve and tailor our marketing activities and services. Subject to us having obtained appropriate consent from you, we may also disclose your Personal Data to any third party providing the following services, in order that they may direct market their services to you

    • (a) aforesaid Services;

    • (b) financial, investment, insurance, banking, and credit cards;

    • (c) transportation, travel, and accommodation;

    • (d) sports, leisure, recreation, and entertainment;

    • (e) telecommunications products and services;

    • (f) e-commerce (including trading and payment platforms and online auctions); and

    • (g) donations and contributions for charitable and/or non-profit making purposes

  • We may disclose and transfer (whether in Hong Kong or abroad) your Personal Data to our agents or contractors, who are under a duty of confidentiality to us, to provide administrative, data processing, research, marketing, distribution, telecommunications, professional, or other similar services to us.

  • We may also disclose and transfer (whether in Hong Kong or abroad) to any of our actual or proposed assignees or transferees of our rights with respect to your Personal Data in connection with restructuring of our business, merger (as between us and a third party), sale, or transfer (whether of assets or shares, in whole or in part), to use, hold, process or retain such Personal Data for the purposes set forth in this PICS.

  • We may disclose your Personal Data to governments, regulatory authorities and bodies, and to other individuals, bodies and organisations, such as dispute resolution, prosecution and law enforcement bodies, legal advisers, and organisations which conduct credit and fraud checks, for the purposes of complying with our legal obligations. We may also disclose your Personal Data to such individuals, bodies, and organisations to enable us to provide our services to you, as well as for any legal and administrative purposes.

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Direct marketing and promotion

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  • With your consent or indication of no objection, we may use Personal Data for direct marketing and promotional purposes, including:

    • ​(a) for sending or showing you updates on the latest news, offers, and promotions, and relating to parties, including:

    • (i) us and/or our Affiliates;

    • (ii) any third party that we cooperate with to provide benefits to you in relation to the following types of services:

    • financial, investment, insurance, banking, and credit cards;

      • transportation, travel, and accommodation;

      • sports, leisure, recreation, and entertainment;

      • telecommunications products and services;

      • e-commerce (including trading and payment platforms and online auctions); and

      • donations and contributions for charitable and/or non-profit making purposes.

    • (b) for tailoring and tracking your interactions with internet banner advertisements and links from our Website to third-party websites.

  • We may also use Personal Data to analyse your preferences and market trends and derive insights, which we may use to tailor the types of services and offers that we present to you. This may involve us combining Personal Data that we hold about your use of our services with information that we have collected about your web usage. We may also combine the information we have collected about you with information we have collected about our other customers to derive these insights and establish market trends. We may provide these insights to our Affiliates and Data Transferees for their direct marketing and promotional purposes, which may involve us sharing Personal Data that we hold about you with them.

  • We may communicate marketing, promotions and research invitations to you by post, email, phone, SMS, online (including by email or through your mobile device or via online banner advertisement) or other media and such other means whether now known or available in the future and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.

  • You are provided an option for you to unsubscribe or opt out of further communication on any direct marketing communication sent to you. It is your choice to restrict your consent to provide certain kinds of Personal Data, certain classes of marketing subjects offered by us, and certain classes of persons to whom we intend to provide for use in direct marketing.

  • You understand and acknowledge that we may obtain a gain by way of commission, reward, fees, or such other benefit from the use and provision to third parties of the Personal Data in the manner and for purposes as specified in this provision.

  • Please note that if you choose to unsubscribe or opt out of marketing communication, you will still continue to receive administrative emails, account summaries, and updates to our services (where applicable).

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Browsing information collected from you (cookies)

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  • We use cookies and similar technologies to collect data about you when you visit our Website and our other related websites (“Sites”). Cookies are files that store information on your computer's hard drive or browser, allowing us to recognize your visit to our Sites at any time. We use cookies to provide you with the best possible experience on our Sites by evaluating the use of our Sites and reviewing your browsing and purchase habits, personalizing your website experience, analyzing website activity on our Sites, and generally making our Sites easier to use.

  • The types of data we may collect from you when you visit the Sites include:

    • Information about the type of browser you use;

    • details of the web pages you have viewed;

    • your IP address and origins;

    • the hyperlinks and services you have clicked;

    • the duration and frequency of your visit, and;

    • the websites you visited before arriving at our Site.

  • You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but to do so you may not be able to utilize or activate all of the functions and services of our Sites. For detailed information on how we use cookies and the purposes for which we use them, please see our Cookies Policy.

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Transmission, storage, and security of your Personal Data​​

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  • No data transmission over the Internet, whether via a website, mobile application, email, or other message service, can be guaranteed to be secure from intrusion. However, we endeavour to maintain commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.

  • All Personal Data we collect about you is stored on our or our separate secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of.

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Exporting your Personal Data

  • Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located. You hereby acknowledge any risk arising from and/or in connection with such transfer.

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Retention period

  • We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example, where we are required to retain personal data for longer than the purpose for which we originally collected it in order to comply with specific regulatory requirements). Our retention periods are based on business needs, and any information that is no longer needed is either irreversibly anonymized (with the anonymized data retained) or securely destroyed.​

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Your rights in relation to your Personal Data

  • You have the right to:

    • not providing any Personal Data to us;

    • check whether we hold any of your Personal Data;

    • access your Personal Data held by us;

    • require us to correct any Personal Data that is inaccurate;

    • ascertain our policies and practices (from time to time) in relation to Personal Data and the type of Personal Data held by us;

    • ask us to cease using your Personal Data for direct marketing purposes and opt out from receiving direct marketing materials from us at any time.

  • Any request in relation to the above shall be emailed to the contact below:

  • Alpha Nova Capital Management Limited Customer Service Department Email address: cs@alphanovacap.com.

  • In accordance with the PDPO, we have the right to charge a reasonable fee for processing any request for access to Personal Data.

  • We will take reasonable steps to try to ensure that your Personal Data is accurate. To assist us in this process, please notify us of any updates to your Personal Data.

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Protecting your Personal Data

  • We strive to maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful use, destruction, loss, alteration, or disclosure of, or access to, your Personal Data.

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Links to other sites​

  • Our Website may contain links to other sites that are operated by third parties with different privacy practices. You should remain alert when leaving our Website and reading the privacy statements of other websites. We have no control over Personal Data that you submit to or receive from these third parties.

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Miscellaneous

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  • Nothing in this PICS shall limit your rights under the PDPO.

  • If there is any inconsistency or conflict between the English and Chinese versions of this PICS, the English version shall prevail.

  • The PICS shall be governed by, and construed in accordance with, the laws of the Hong Kong Special Administrative Region.

  • We may change this Privacy Policy Statement and the PICS from time to time by posting an updated version on our Website.

  • You hereby acknowledge that during your interactions with us, you are not based in the European Economic Area, Australia, Canada, People’s Republic of China, Japan, Malaysia, Singapore, South Korea, Taiwan and the United States, and the laws and regulations on personal data protection applicable to such regions, such as the EU General Data Protection Regulation (GDPR), shall not be applicable.​

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