This website (https://foahk.org/) is owned and operated by Family Office Association Hong Kong (“FOAHK”, “we”, “us”, or “our”). Our registered office is at Unit 2306 – 2313, 23/F, The Center, 99 Queen’s Road Central, Central, Hong Kong and we are a company incorporated under the laws of Hong Kong (registered number 297259938).

This Privacy Policy (the “Policy”) sets out and informs how Family Office Association Hong Kong collects, uses and shares the information you provide to us and the information we collect in the course of operating this website (the “Site”). By accessing and using this Site, you agree to be bound by the terms of this Policy. FOAHK reserves the right to revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make.

Collecting Personal Information

“Personal Information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control – i.e., data we collect from you, the way in which it is collected and the purposes for which it is collected and used.

As we operate the Site, we may collect, retain and process the following Personal Information:

Personal Information provided by you

We will process Personal Information that you provide us including when you email us or contact us through various channels as follows:

• Signing up for services on FOAHK website: when you sign up for newsletters, webinars, events or obtain other member services from us or when you contact us with queries or respond to our communications, the Personal Information you provide may include your full name, job title, company name, telephone number, email address, content, date and time of your correspondence and information about your firm or your business.
• Provision of member services: if you are a member of FOAHK, you will provide us with Personal Information when you or the firm you represent becomes a member. If you are not a member, we may collect or receive your Personal Information because you are involved in one of our member’s matters.
• Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, gender, CV, photograph, passport details, marital status, home address, home and mobile telephone number and other details set out in the job application.

Personal Information obtained from other sources

• In connection with recruitment application: when you apply for a position with us, we may collect Personal Information relating to past employment, qualifications and education, opinions from third parties about you, past employment history and other details about you, which may be provided to us by a third party that provides background screening services to us.
• In connection with the provision of member services: we may collect or receive your Personal Information from third parties such as your firm, other parties relevant to the services we are providing (e.g., a colleague might request to sign up for you for an event) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our members.

Using Personal Information

We may use your Personal Information for the following purposes:

1. to provide services to the relevant member or groups of members;
2. to engage in activity in relation to our member services, this may include sending you newsletters, updates, event invitations and other information that may be of interest to you;
3. to review and process your job application when you have applied for a position with us;
4. to comply with legal or regulatory obligations that we must discharge;
5. to establish, exercise or defend our legal rights, or for the purposes of legal proceedings;
6. to look into any complaints or queries you may have;
7. to prevent and respond to actual or potential fraud or illegal activities; and
8. to collate, process and share any statistics based on an aggregation of information held by us, provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

Grounds for using Personal Information

We rely on the following legal grounds to process your Personal Information, namely:

• Performance of a contract – we may need to collect and use your Personal Information to enter into a contract with you or to perform our obligations under a contract with you.
• Legitimate interests – we may use your Personal Information for our legitimate interests, some examples of which are given above.
• Compliance with law or regulation – we may use your Personal Information as necessary to comply with applicable laws or/and regulations.
• Consent – we may (but usually do not) need your consent to use your Personal Information. You can withdraw your consent by contacting us (see below).

Sharing Personal Information with third parties

We share Personal Information with the various companies and entities that make up our network. As a result, your Personal Information may be transferred to locations outside Hong Kong as well as within it for the purposes described above.

We may also share your Personal Information outside FOAHK. This may include:

• Third-party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
• Third parties relevant to the services that we provide. This may include, but is not limited to, counterparties to litigation, professional service providers, sponsors of our events, regulators, authorities and governmental institutions.

Protecting your Personal Information outside Hong Kong

We may transfer Personal Information that we collect from you to third-party data processors in countries that are outside Hong Kong. This might be required, for example, in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your Personal Information receives the same protection as if it were being processed in Hong Kong. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact us (see below).

Any transfer of your Personal Information will follow applicable laws and we will treat the information under the guiding principles of this Policy.

Retaining Personal Information and Security of Personal Information

The period we hold your Personal Information for will vary and will depend principally on:

• the purpose for which we are using your Personal Information – we will need to keep the information for as long as is necessary for the relevant purpose, and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Information.

We will ensure that the Personal Information that we hold is subject to appropriate security measures.

Your choices and rights

You have a number of legal rights in relation to the Personal Information that we hold about you and you can exercise your rights by contacting us using the details set out below.

These rights include:

• Obtaining information regarding the processing of your Personal Information and access to the Personal Information which we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of Personal Information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our member and as authorised by our member.
• Requesting the correction of our Personal Information if it is inaccurate or incomplete.
• Requesting that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information but we are legally entitled to retain it.
• Objecting to, and requesting that we restrict, our processing of your Personal Information in certain circumstances. Please note that there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Information but we are legally entitled to refuse that request.
• In some circumstances, receiving some Personal Information in a structured, commonly used and machine-readable format and/or requesting that we transmit such information to a third party where this is technically feasible. Please note that this right only applies to Personal Information which you have provided to us.
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
• Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
• We can, on request, tell you which data protection authority is relevant to the processing of your Personal Information.

Contacting Us and Other Important Information

If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Information or the exercise of any of the rights listed above, please contact us by writing to us at enquires@foahk.org

If there is any inconsistency or ambiguity between the English version and Chinese version of this Policy, the English version shall prevail.

© 2023 Family Office Association Hong Kong

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