PRIVACY POLICY

 

 

General 

CAP TRUST LIMITED (CAP TRUST) registered number 3161077, with its registered office at 20/F, One International Finance Centre, 1 Harbour View Street, Central, Hong Kong ( "the company", "we" or "us") is committed to maintaining robust privacy protections for its users.  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.

 

This Privacy Policy together with any other documents referred to therein set out the basis on which any personal data we collect from you, or which you provide to us, through our website www.captglobal.com ("Website") or in connection with your account will be processed by us. When you complete any form, speak with our staff or submit any details to us or using our Website, we will collect, use and disclose your personal information in the manner described in this Privacy Policy. 

 

Please read this Privacy Policy carefully to understand our views and practices regarding your personal data, how we use it and how we will treat it. If you do not agree with this Privacy Policy, please do not use our services. 

 

Changes to this Privacy Policy Any changes we make to this Privacy Policy in the future will be posted on this page. Any new Privacy Policy will be effective from the time that it is posted on the Website. We reserve the right to make changes to our Privacy Policy at any time, without notice, where such change is required by applicable legislation. If we make any material changes to the way your personal data is used, we will notify you by email prior to the change becoming effective. You may object to any new use or change in use of your personal data by contacting us as set out in Contact Us below. We will treat such objection as a notice to terminate your account which will be closed.

 

I.               INFORMATION WE COLLECT

We collect your data (i) when you interact with us and use our products and services; (ii) visit our websites; and (iii) from other people and companies, including other CAP TRUST Group companies, with the following personal data, including but not limited to:-

1. Personal data including your title, full name, nationality, current address, email address, mobile telephone number, home telephone number, date of birthand any proof of your identity and/or address that we may request. This information is collected through the application process. 

2. transaction data about bank account details and payments to and from you and other details of products and services you have purchased from us;

3. technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website;

4. biometric data such as your voice ID, thumb print and facial recognition data;

5. your geographic data and location data based on your mobile or other electronic device;

6. data from people who act for you or who you deal with through our services;and

7. data from public sources, credit reference, debt collection and fraud

8. prevention agencies, and other aggregators;

If you don’t give us data then we may be unable to provide products or services.

We may also generate data about you  by combining information that CAP TRUST Group have collected about you based on the analysis of your interactions with us through the use of cookies and similar technology when you access our website or apps.

As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

 

II.             HOW WE USE AND SHARE INFORMATION

We will use your personal data to provide information on services requested or products ordered. Data is collected and used on a lawful basis only which is outlined below. 

Lawful basis 

Purpose 

1. To perform a contract with you 

• To take steps at your request prior to entering into a contract 

• To decide whether to enter into a contract 

• To manage and perform the contract 

• To ensure our records remain relevant 

1. Our legitimate interest 

• For good governance, accounting, managing and auditing our business operations 

• For market research, analysis and developing statistics 

• To send you marketing communications with your consent ​

1. Legal obligation 

• When you exercise your rights under data protection law and make requests 

• For compliance with legal, regulatory requirements and related disclosures 

• For establishment and defence of legal rights 

• For activities relating to the prevention, detection and investigation of crime 

• To verify your identity, engage in fraud prevention and anti-money laundering checks 

• To monitor emails, calls, other communications, and activities on your account 

1. Your consent 

• When you request we disclose your personal data to other people or organisations 

• When we process any special categories of personal data at your request 

• To send you marketing communications where we have asked for your consent to do so 

 

III.           Disclosure of Your Information

CAP TRUST will devote effort to maintain Personal Data of yours or, where appropriate, third party, held by CAP TRUST confidential but CAP TRUST may, at its sole discretion, provide such information to the following persons for direct marketing purposes (where consented (including an indication of no objection) by you) or any other purposes permitted by this Privacy Policy:-

1. any local or overseas law enforcement agency, industry body, regulator or authority;

2. any agent, contractor or third party service provider (whether in Hong Kong or elsewhere) who provides banking, financing, insurance, administrative, custodian, telecommunications, computer, payment, debt collection or securities clearing, audit, business consulting, outsourcing, or other services to CAP TRUST in connection with the operation of its business;

3. any branch or office of any member of the CAP TRUST Group, whether in Hong Kong or elsewhere;

4. any person acting or proposing to act as surety;

5. any person under a duty of confidentiality to CAP TRUST (or any member of the Group) or who has undertaken to keep such information confidential;

6. any financial institution with which you have or propose to have dealings;

7. any third party who you consent to us sharing the data with;

8. any partner and provider of reward, co-branding or loyalty programs, charity or non-profit organization;

9. credit reference agencies and, in the event of default, to debt collection agencies;

10. any actual or proposed assignee or transferee of any member of CAP TRUST;

11. any person in accordance with applicable laws and regulatory requirements including through or pursuant to any rules, judgment, decision or ruling of the courts, arbitral tribunals, governmental, regulatory or other bodies or institutions, whether as required by the laws and regulatory requirements that are applicable to any member of the CAP TRUST; and

12. CAP TRUST may from time to time transfer the data relating to you to a place outside Hong Kong, and share the anonymised data with other parties not listed above for any of the purposes set out in above.

 

IV.           YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

1. The right to be informed

2. The right of access

3. The right of rectification

4. The right of erasure

5. The right to restrict processing

6. The right to data portability

7. The right to object

8. Rights in relation to automated decision making and profiling

 

V.             DIRECT MARKETING

This is when we use your data to send you details about financial, insurance or related products, services and offers provided by us or our co-branding, rewards or loyalty programme partners or charities.

We may use data such as your demographics, the products and services that you’re interested in, transaction behaviour, portfolio information, location data, social media data, analytics and information from third parties when we market to you.

 

VI            LINKS TO OTHER WEBSITES

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

 

VII.          ACCESSING AND UPDATING YOUR INFORMATION
If your personal details (such as your name, address, or telephone number) change you should inform Customer Services via the "Contact" section of the Website as soon as you can. We shall not be liable for any loss arising out of your failure to keep your personal details up to date. Your address and phone number can only be changed once in any 3 month period. You have the right to access information that we hold about you. To do so, please contact us at the address given at the end of this policy. 

 

 

VIII.         CONTACT US

If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to cap@captglobal.com.