This Privacy Policy (the “Policy”) sets out our data protection and privacy policy of Bowman and Fitzhugh Capital Limited (“BFCL”) and Bowman and Fitzhugh Asset Management (“BFAM”), collectively (“we” and “us” and/or “our”). Please read this carefully as this Policy is legally binding when you use our Services. You should understand why and how we collect, use, disclose and or/process your Personal Data.
The “Data Subject”, which is the individual who is the subject of the data as defined in PDPO, in this policy refers to the customers and various other individuals, including but not limited to applicants for our services, shareholders, directors, corporate officers and managers, and other contractual counterparties who supply BFAM and BFCL with their Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by us in connection with and/or for the purposes of our operations. The scope of Personal Data is as defined in the PDPO.
This Policy adds to, but does not supersede or replace any previous Personal Data usage consents which you may have given to us. It does not affect any legal rights we have regarding the collection, use, processing, and disclosure of your Personal Data.
We may from time to time update this Policy to align with business needs or changes in legal and regulatory requirements. All updates to this Policy will be published on our website, with notifications of significant revisions also published there. By continuing your relationship with us after any amendments are published, you shall be deemed to have accept the revised Policy.
(A) Purposes
Personal data may be used for the following purposes:
- The operation of the services and products provided to you.
- The administration and management of accounts, including but not limited to debt collection and the enforcement of guarantees, charges, or other rights and interests.
- To ensure your ongoing credit worthiness.
- Processing payments and receipts.
- To execute your instructions and requests, including instructing any third party in order to provide you with services.
- To provide you with marketing materials related to the products and services we may provide;
- To design new, or improve existing, products, services and information provided by us.
- To understand your needs and preferences.
- To establish and maintain our risk management standards.
- To assist us, regulators, other relevant professionals, or institutions to verify certain facts related to services provided by us.
- To conduct due diligence, screenings, or credit checks as required by any applicable laws or our internal policies and procedures.
- To comply with relevant laws and regulations.
- To respond to requests from any relevant governmental or regulatory body.
- To carry out financial reporting, regulatory reporting, management reporting, risk management, auditing, and record-keeping activities and other requirements by any relevant governmental or regulatory body and/or our internal policies.
- To communicate with you, including providing you with administrative and technical information about any account you may have with us and updates or changes to our services or products.
- To communicate with you or to investigate any complaints, claims, or disputes.
- Other purposes incidental to any of the above.
- Other purposes that are appropriate or allowed under any applicable law.
- Other reasonable purposes related to the provision of our services.
- We intend to use your personal data for direct marketing purposes or transfer such personal data to our group of companies and/or our affiliates for direct marketing purposes. Direct marketing may include our communication with you in order to keep you up to date with our products, services, and other information, and for the marketing purpose of our services and products. We will ensure that your Personal Data remains confidential.
By continuing to use our website you are agreeing to this Policy, and the data subject (you) are deemed to have granted us consent for the uses and purposes described above in this Policy. Unless allowed by applicable laws and regulations or with the Data Subject’s consent, we will not use your personal data for purposes other than those stated in this Policy.
Regarding direct marketing purposes, we shall cease using your Personal Data for direct marketing purposes if so requested by you without any charge. Any such request can be sent to us at contact@bfcapital.com.
We may retain your personal data for as long as necessary to achieve the purposes for which it is collected, or as required to comply with relevant laws and regulations. We use reasonable security measures to keep your personal data safe and secure, including encryption and other forms of security. Once the information is no longer necessary for the aforementioned purposes, we will take reasonable steps to delete or destroy it.
(B) The Users of Your Personal Data
Personal Data held by us relating to you or your agents, if any, may be used for the purposes set out in Section A and will be kept confidential, but we may provide such Personal Data to the following parties:
- Any agent or third-party service provider who provides services to us in relation to our business operations.
- Any other group companies.
- Any other person under a duty of confidentiality to us including any company group which has undertaken to keep such information confidential.
- Any person or institution with which you have or proposes to have dealings.
- Any person to conduct credit checks.
- Debt collection agencies (in the event of default payment).
- Any regulatory authorities in compliance with their requirements or requests for information in accordance with applicable laws and regulations.
- Any of our actual or proposed assignee or participant or sub-participant or transferee of our rights in respect of us.
- Any assignee, transferee, delegate, successor, or individual to whom your account is transferred, as well as your authorized representative.
- Any person with your express or implied consent.
Your personal data may be provided to any of the aforementioned parties, who may be located in any place outside Hong Kong, for processing, holding, or use of such data, as well as to service providers which offer services to us in relation to our business operations.
(C) Access to Personal Data
As provided for in the PDPO, you have a right to
- request access to your Personal Data, including the right to obtain a copy of your Personal Data provided in the application form subject to payment of a fee.
- require correction of your Personal Data which is inaccurate; and
- ascertain our policies and practices regarding Personal Date and to be informed about the types of Personal Data we hold.
In accordance with the PDPO, we have the right to charge a reasonable fee for the processing of any data access request. Any such request, including making of access and corrections, must be made in accordance with the terms of the PDPO and should be addressed to contact@bfcapital.com.