Privacy Notice, Hong Kong
Sona Asset Management (HK) Limited (the “Sona Asset Management”, “we”, “us” or “our”) is providing you with this privacy notice to help you understand our privacy policies and practices and how they relate to the personal data that we receives and/or collects from you.
In accordance with the Personal Data (Privacy) Ordinance of Hong Kong (Cap. 486), the term “personal data” means 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.
What personal data does Sona Asset Management collect and/or process?
Sona Asset Management collects personal data about you from the following sources:
- Information Sona Asset Management receives from you in subscription documents or other related forms;
- Information about your transactions with Sona Asset Management, our affiliates, or others;
- Information about you that Sona Asset Management receives from third parties, such as consumer reporting agency, credit reference agency, verification service provider and other publicly available sources, etc.;
- Any other information you have provided to Sona Asset Management; and/or
- Any other information we collect or generate about you, when communicating with or providing services to you. Your communication with Sona Asset Management will be subject to monitoring in accordance with and to the extent permitted by applicable laws.
Sona Asset Management may collect and/or process certain types of your personal data, including but not limited to the following:
- Name, address, email address, phone number, date of birth;
- Personal identification information, such as identity card or passport details, proof of address;
- Information about your source of wealth and source of funds; and/or
- Other personal data that you may choose to share with Sona Asset Management.
What are our purposes of collecting and/or processing your personal data?
Sona Asset Management may process the above categories of personal data for some or all of the following purposes:
- To verify your identity and comply with applicable law, including know-your-client and anti-money laundering and sanctions requirements;
- To effect client transactions (including accepting subscriptions);
- To comply with any applicable legal or regulatory obligations, including information disclosure requirements;
- To conduct statistical analysis and market research;
- To allow service providers retained by Sona Asset Management or our affiliates to provide services associated with your transactions with us;
- To improve our products and services and defend our legal rights and interests;
- With your valid consent, to conduct direct marketing of products and services that Sona Asset Management or any of our affiliates considers may be of interest to you; and/or
- Any other uses relating to the above to which you have consented.
Providing your personal data to third parties
Sona Asset Management may disclose personal data to the following third parties for the above mentioned purposes:
- Sona Asset Management’s affiliates;
- Any agent, contractor or third party firms engaged by Sona Asset Management or our affiliates, including without limitation, brokers, fund administrators, accounting support firms and compliance/operational support service providers;
- Any agents of Sona Asset Management who need to know that information in order to provide services to its investors;
- Any third party for promotional or marketing purposes in relation to the products and services of Sona Assessment Management and/or our affiliates, with your consent;
- Any applicable regulators, exchanges, government bodies, tax authorities or other industry recognized bodies located inside or outside Hong Kong;
- Any third party as required by any applicable law, rules and regulations, codes of practice or guidelines of any applicable jurisdiction, or as required by an order by a court of competent jurisdiction; and/or
- Any other third parties who you consent to share your data with.
Sona Asset Management will require such third parties to protect the confidentiality of your personal data and to use the personal data only for the purposes for which it is disclosed to them. Where we share or transfer your personal data outside of Hong Kong, we will ensure that the overseas recipients’ processing of your personal data meets the personal data protection standards prescribed by applicable laws and regulations.
Will your personal data be used for direct marketing?
Subject to obtaining your consent where required by law, we may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds that Sona Asset Management and/or its affiliates manages and/or advises, subject to obtaining your consent where required by law.
If you change your mind on which communications you would like to receive or how you would like to receive them or you decide that you do not wish to receive direct marketing communications any more, you can unsubscribe at any time by contacting us at ir@sona-am.com.
What are your rights?
You have a right to request access to, and request correction of, your personal data. Requests for access and correction should be
addressed to Sona Compliance at compliance@sona-am.com .
Who should I direct questions to?
If you have any questions about this privacy policy or how we handle your personal data, you can contact the offices of Sona Asset
Management at compliance@sona-am.com / +44 (0)20 3872 4572 .
