Data Policy (for Hong Kong Clients)

DBS Vickers (Hong Kong) Limited values the protection of your personal data. All personal data collected by the Company shall be treated in accordance with the Personal Information Collection Statement (“Collection Statement”) set out below and the provisions of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance"). For the avoidance of doubt the Collection Statement replaces any personal data statement provided to you previously by the Company.

Personal Information Collection Statement

DBS Vickers (Hong Kong) Limited (the "Company") may collect personal data (as defined in the Personal Data (Privacy) Ordinance, (Cap 486) (“the Ordinance”)) (which data may relate to yourself or your authorised signatories or other persons) from you, in connection with its dealings with you. You must supply the personal data as required by the Company. If you fail to supply the required personal data, the Company may refuse to open an account for you.

1. Purposes of Collection

The Company may use your personal data (whether provided by you or any other person, and whether provided before or after the date you receive this document) for the following purposes: (a) activities relating to operating your account such as purchasing, investing, advising, exchanging, acquiring, disposing of and generally dealing in and with all kinds of securities, futures and options on your behalf, carrying out transactions at your instructions, ongoing account administration and contacting you; (b) activities relating to the processing of your application to open an account with the Company and maintaining your account, including but not limited to client verification, anti-money laundering and other client due diligence procedures, conducting credit reporting, processing your application for grant of credit or margin facilities or the continuation and review of such credit or margin facilities; (c) maintenance and verification of particulars and data; (d) any other purpose relating to the provision of banking, investment and/or other financial services and facilities by the Company and/or any holding company, subsidiary or affiliate (within or outside Hong Kong)(the “Group”); (e) to provide you with information about your account and account statements; and (f) to conduct research and statistical analysis; and (g) complying with the obligations, requirements or arrangements, whether voluntary or mandatory, for disclosing and using data, including notification requirements that apply to the Company or any member of the Group, according to any law binding or applying to them within or outside Hong Kong or pursuant to any treaty or undertaking between any governmental, regulatory, tax, law enforcement or other authorities within or outside Hong Kong, and in particular the reporting and exchange of information requirements pursuant to the United States Foreign Account Tax Compliance Act (“FATCA”) and the OECD’s standard for Automatic Exchange of Financial Account Information (“AEOI”).

With your consent, the Company may use your name, contact information, account number and information about the products/services you have purchased ("Marketing Data") to provide you with marketing materials relating to the Group's banking, investment and/or other financial products and services ("Marketing Materials").

2. Classes of Transferees

Personal data held by the Company will be kept confidential but may be transferred to the following persons within or outside Hong Kong solely for the purposes set out at 1 (excluding direct marketing purposes): (a) other entities within Group (including direct and indirect subsidiaries) providing banking, investment and/or other financial services and/or outsourced activities that facilitate the provision of such services; (b) the Company's agents, nominees, professional advisers, researchers and other third party service providers that offer services to the Group in connection with the operation of its banking, investment and/or financial services business; (c) credit reporting agencies; (d) financial regulators, government bodies, law enforcement bodies or other regulatory authorities, individuals or corporations who have the right to such data and information as prescribed by law within or outside Hong Kong; (e) the Hong Kong Inland Revenue Department, the United States Inland Revenue Service and any other taxing authority of any jurisdiction to whom the Company or any member of the Group is under an obligation or otherwise required to make disclosures under the requirements of any law or pursuant to any treaty or undertaking between governmental, regulatory, tax or other authorities within or outside Hong Kong ( in particular the reporting and exchange of information requirements pursuant to FATCA and the AEOI); (f) where transactions are executed outside of Hong Kong, the relevant stock exchange, clearing house or regulatory bodies; and (g) authorized employees of the Company.

The Company may transfer your Marketing Data to other entities that offer banking, investment and/or other financial services within the Group for the purpose of providing you with Marketing Materials. The Company will not disclose your personal data to those entities or other third parties for marketing purposes without your consent.

3. Transfers of Personal Data Outside Hong Kong

To facilitate the purposes set out in paragraph 1 above, the Company may transfer, disclose, grant access to or share your personal data with the parties set out in paragraph 2. You acknowledge that those parties may be based outside Hong Kong and that your personal data may be transferred to places where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Ordinance.

4. Under the Ordinance you have the right to enquire whether the Company holds personal data in relation to you, and to request access to and correction of your personal data. You may make such a request to the Privacy Officer, DBS Vickers (Hong Kong) Limited, 18/F Man Yee Building, 68 Des Voeux Road Central, Hong Kong, Tel: (852) 2820 4888, Fax: (852) 2523 6055. In accordance with the terms of the Ordinance, a reasonable fee may be charged for processing any data access request.