Privacy policy

Last updated: 24 October 2019

This Privacy Policy applies to all the services provided by Planetree Capital Limited, its affiliates and subsidiaries (“Planetree Capital”, “we” or “us”).

This policy informs you about what type of information we collect, and explains how and why we collect, use and disclose the information that you share with us in accordance with the Personal Data (Privacy) Ordinance (Cap. 486).

1. WHICH INFORMATION IS COLLECTED

Personal Information refers to any data relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable.

We collect and store information that you provide when you complete and submit an account opening information form, use our services, use our Website, send us correspondences and when you otherwise interact with us.

When you use our services

To obtain access to the services, you must register and obtain an account or a joint account with Planetree Capital by completing an account opening information form. The provision of your Personal Information is necessary for us to provide our services to you. If you do not wish to provide your Personal Information to us, we may be unable to open or maintain an account for you.

You must provide the following information:

We also collect and store the full name, unique identification number (e.g. identity card number or passport number) and identification document’s place of issue, and address of the ultimate beneficial owner(s) of the account.

We also collect and store the full name, occupation information and address of the persons witnessing account openings by post.

When you use our Website

Contact form. When you use our Website, we collect and store any information you provide through our contact form, including your full name, email address and the contents of your communications with us.

Cookies. We may also collect information from you automatically through cookies or other similar technologies. Cookies are small text files that are stored on users’ computer hard drive or device when they visit a website.

There are a number of different types of cookies. Our Website use functionality cookies in order to improve your experience on our Website (including to understand how you use our Website and remembering your previously selected preferences), cookies to provide us with general analytics and gather demographic information in a non-identifiable form, and security cookies in order to keep your data secure.

We automatically collect and store usage information about your browsing habits, including:

Logs containing (a) and (b) are preserved for up to one month. Data in (c) through (f) can persist indefinitely.

Our Website also use third-party cookies such as Google Analytics, a service which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

The processing of data and Personal Information by Google is governed by Google's privacy policy. You can opt out of Google Analytics by using the opt-out service provided by Google-external site.

You can disable and/or delete cookies on your device by indicating this in the preferences or options menu in your browser. However, doing so may limit your ability to use our Website.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the purposes identified below:

In the event we intend to further process your information for a purpose other than for which it was collected, we will provide you with information on that other purpose and obtain your consent before processing your information. You may withdraw your consent previously given by notifying us in accordance with the “Contacting us” section below.

3. HOW WE SHARE YOUR INFORMATION

We do not sell any of your Personal Information to anyone. We may share it with third parties but only as expressly stated in this Privacy Policy.

Within the group

Planetree Capital works in close collaboration with its affiliated companies in order to develop the products and the services. As such we may share and process your Personal Information within our group companies.

Third party providers

Where necessary, third-party providers who help provide our products and services, such as information technology managed services providers, may have access to Personal Information. We ensure to obtain contractual commitments from them to protect your Personal Information.

Sharing for legal purposes

We may disclose any information, including your Personal Information and any other information or data collected, stored or processed on our servers, if required to do so by law or in the good-faith belief that such action is necessary to (i) comply with any law, regulation, legal process or lawful governmental requests, (ii) protect the rights or property of Planetree Capital or our customers, including the enforcement of our agreements or policies governing your use of the service, and (iii) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of Planetree Capital’s employees, customers, or the public.

Change of ownership or restructuring

In the event of a proposed or actual business transaction, corporate restructuring, sale or merger of Planetree Capital, or involving some or all of our business, assets or equity, we may disclose and/or transfer information we have collected to those involved in assessing, planning and completing the sale (including the buyer and its employees, agents and representatives).

4. USE OF DATA IN DIRECT MARKETING

We intend to use and to transfer your Personal Information to affiliated companies within our group for direct marketing. We may not use your Personal Information for direct marketing unless we have received your consent for that purpose. In this connection, we and our affiliated companies shall use the following Personal Information for marketing products and services:

If you do not wish Planetree Capital to use and /or transfer your data for use in direct marketing, you may, without charge, exercise the right to opt-out by notifying us in accordance with the “Contacting us” section below.

5. HOW YOU CAN MANAGE YOUR INFORMATION
Your right to access your Personal Information

You have a right to access your Personal Information. You may request and obtain a copy of your Personal Information.

Your right to rectification

You may request that we correct any inaccurate Personal Information or that we complete any incomplete Personal Information.

If you would like to exercise any of these rights, please notify us in accordance with the “Contacting us” section below. We will ensure to comply with your requests free of charge, as soon as practicable and consistently with applicable law. However, in the event your requests are manifestly unfounded or excessive, we may charge an administrative fee or refuse to meet your request.

Please note that, in order to protect your Personal Information, we may need to verify your identity before fulfilling your request.

6. CHILDREN

Our Website and our services are not targeted for use by individuals under the age of 18.

7. RETENTION OF YOUR PERSONAL INFORMATION

We store your Personal Information as long as necessary to provide our services to you or until your account is terminated. We will retain your Personal Information and all communications between you and us for the period necessary to comply with applicable legal and regulatory obligations and recordkeeping requirements, or to address any complaints related to the information. When your Personal Information is no longer required, it will be securely destroyed.

8. SECURITY

Planetree Capital takes administrative and technical measures to protect your Personal Information from unauthorized or accidental access, processing, erasure, loss or use, including applying generally accepted industry standards, encryption, access controls and security breach protocols.

We ensure that only the relevant personal, related entities and agents that are strictly necessary to the provision of the services have access to your Personal Information. All recipients are subject to strict confidentiality obligations.

9. CHANGES TO THIS PRIVACY POLICY

We regularly review and update this Privacy Policy to ensure it remains in line with our information practices and applicable regulations and will place any updates on the Website. Those changes will go into effect on the “Last updated” date shown at the top of the updated Privacy Policy, and any information being held will be governed by the most recent policy. Your continued use of the Website and our services after the last updated date will be considered as acceptance of the revised Privacy Policy.

CONTACTING US

If you have any questions about this privacy policy or any information we have collected about you, please contact us by email at [email protected], or by postal mail at:

Attention: Privacy and Compliance Officer

9/F, Global Trade Square

21 Wong Chuk Hang Road

Wong Chuk Hang

Hong Kong

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