PRIVACY POLICY & PRIVACY STATEMENT


1. Our privacy commitments

1.1 This privacy statement (“Privacy Statement”) applies to our website www.hedgevista.com("Website"). For the purposes of this Privacy Statement "Group Company" shall mean HedgeVista Limited (“HedgeVista”) or any of its subsidiary or related companies (collectively, “Group Companies”).

1.2 HedgeVista respects the privacy of every person who visits, registers with or subscribes to our Website and/or services and online publications (“Services”), and is committed to ensuring a safe online experience.

1.3 Please note that the Website may contain links to external websites and advertisements for your reference and/or the opportunity for you to purchase products or services from third parties. This Privacy Statement does not cover the activities of such third parties or the content of their websites and you should consult those third-party websites’ privacy policies for information on how your Personal Data (as defined in clause 1.4 below) is used by them.

1.4 This Privacy Statement outlines the information we may collect about you in relation to your use of our Website and related publications and Services, including but not limited to your name, contact details, address, email address, transaction pattern and behavior, background and demographic data ("Personal Data") and how we may use that Personal Data. It also outlines the methods by which we and our service providers may (subject to necessary consents) monitor your online behavior in order to deliver customized advertisements and marketing materials and other tailored services. This Privacy Statement also tells you how you can verify the accuracy of your Personal Data and how you can request that we delete or update it.

1.5 By using our Services or visiting our Website, you consent to the collection and use of your Personal Data and other activities as outlined in this Privacy Policy.

1.6 Every effort has been made to ensure that this Privacy Policy is in compliance with the Hong Kong Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong) (“Ordinance”). This Privacy Policy is subject to and should be interpreted in accordance with the provisions of the Ordinance.

2. Information about Us

2.1 Our principal business activities include hosting or accessing the hosted information on HedgeVista platform

2.2 Our address is:

HedgeVista Limited

22/F, 3 Lockhart Road,

Wan chai, Hong Kong.

Please note that our address may change from time to time.

2.3 The details of the officer handling Personal Data-related enquiries/matters (“Data Controller”) are as follows:

Name: Devi Chinthireddy

Title: COO

Email address: info@hedgevista.com

Tel” +852 54107009

Please note that the details of the Data Controller may change from time to time.

3. Collection of Personal Data

3.1 Our primary goal in collecting Personal Data from you is to give you a convenient and enjoyable customized experience whilst allowing us to provide services and features that most likely meet your needs.

3.2 We collect certain Personal Data from you, which you provide to us when using our Website and/or registering or subscribing for our Services.

3.3 Please note that the Personal Data marked with asterisks is required for our account handling purposes. In the event that you do not supply such Personal Data, we may not be able to provide our Services to you.

3.4 We also collect certain Personal Data from other Group Companies to whom you have given information through their Websites.

3.5 Please note that we do not intend to collect any Personal Data from minors (individuals under eighteen years of age) or mentally incapacitated persons. Minors and mentally incapacitated individuals should not submit any Personal Data to any of the Website, unless their legal guardians provide their written consent for the supply of such information to HedgeVista. Should we discover that any such Personal Data has been delivered to the Website, we will remove that information as soon as possible.

4. Types of Personal Data held and their use

4.1 HedgeVista collects Personal Data such as your name, job title, work and/or home address, telephone number and email address in order to register you for access to certain content and subscriptions. This Personal Data may be supplemented with demographic information you provide through your use of our Website such as your postal area, age, gender, purchasing preferences and interests.

4.2 The purposes for which Personal Data may be used by us in and outside the Hong Kong Special Administrative Region (“Hong Kong”) include, among others:

(a) administering and delivering to you the products and/or Services you have requested;

(b) operating our Website efficiently and improving our Services;

(c) retaining records of our business transactions and communications;

(d) providing you with alerts, newsletter, education materials or information that you requested or subscribed for;

(e) carrying out our obligations arising from any contracts entered into between you and us;

(f) allowing you to participate in interactive features of our Services, when you choose to do so;

(g) designing and conducting surveys/questionnaires for client profiling/segmentation and statistical analysis;

(h) complying with laws and regulations applicable to us or any of our affiliates in or outside of Hong Kong;

(i) researching, designing and launching services or products including seminars/events/forums;

(j) legal proceedings, including collecting overdue amounts and seeking professional advices;

(k) promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in clause 6 below); or

(l) purposes directly related or incidental to the above.

4.3 HedgeVista will only use Personal Data provided by you for the purposes explicitly stated in this Privacy Statement and for the specific purposes indicated at the moment HedgeVista requests you to supply of your Personal Data. Personal Data will not be used for a new or different purpose without your explicit prior written consent (including by way of an opt-in option).

4.4 HedgeVista will retain your Personal Data for as long as it is reasonably necessary to perform the Services.

5. Monitoring use of our Website

5.1 Where we enable you to post information or material on our Website, we may access and monitor any information which you upload or input, including in any password-protected sections. If you are a registered user (e.g. a subscriber or taking a trial), when you log on, this places a cookie on your device. This enables your access to content and services that are not publicly available. Once you are logged on, the actions you take - for example, viewing an article - will be recorded (subject to any necessary consents). We may use technology or a service provider to do this for us. This information may be used for one or more of the following purposes:

(a) to fulfil our obligations to you;

(b) to improve the efficiency, quality and design of our Website and Services;

(c) to see which articles, features and Services are most frequently read and used;

(d) to track compliance with our terms and conditions (e.g. to ensure that you are acting within the scope of your user license);

(e) to market material to you (subject to your rights to opt-in and opt-out of receiving certain marketing communications) - see paragraph 6 below;

(f) for the purpose of advertising our Services, although the information used for these purposes does not identify you personally;

(g) to protect or comply with our legal rights and obligations; and

(h) to enable our personnel to contact and interact with you online in connection with any content you may post to our Website.

6. Direct marketing

6.1 We intend to use your Personal Data in direct marketing and we require your express written consent (including through an opt-in option on our Website) for that purpose. An option for you to give or deny consent to the disclosure of your Personal Data will be shown on our Website at the time when we intend to collect your Personal Data. In connection to this, please note that:

(a) among others, the following classes of services and products may be marketed in direct marketing:

(i) services and products related to our Website (including marketing affiliates programs we are a part of);

(ii) reward, loyalty or privileges programs, promotional offers and related services;

(b) we and/or other Group Companies may conduct direct marketing via fax, email, direct mail, newsletters, telephone, and/or post.

6.2 You can give your consent to or opt-out of particular uses of your Personal Data as indicated above by:

(a) indicating your preference at the relevant point on the Website where Personal Data is collected through an opt-out option;

(b) informing us by email, post or phone; or

6.3 You may choose not to receive promotional material, by simply informing our Data Controller (whose contact details are listed at clause 2.3 above) and we will cease to do so, without charge.

7. Cookies and similar technologies

7.1 Our Website uses cookies and similar technical tools to collect information about your access to the Website and the services we provide.

7.2 Cookies are pieces of computer code which include a unique reference code that Websites transfer to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer. Cookies cannot be used to run programs or deliver viruses to your computer. They are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie.

7.3 We may, without limitation, use cookies to:

(a) remember that you have used the Website before; this means we can identify the number of unique visitors we receive to different parts of the Website. This allows us to make sure we have enough capacity for the number of users that we get and make sure that the Website run fast enough;

(b) remember your login session so you can move from one page to another within the Website;

(c) store your preferences, your username and/or password so that you do not need to input these every time you visit the Website;

(d) customize elements of the layout and/or content of the pages of the Website for you;

(e) record activity on our Website so that we understand how you use our Website, which enables us to better tailor our content, services and marketing to your needs;

(f) collect statistical information about how you use the Website so that we can improve them;

(g) gather information about the pages on the Website that you visit, and also other information about other websites that you visit, so as to place you in a “market segment”. This information is only collected by reference to the IP address that you are using, but does include information about the country and city you are in, together with the name of your internet service provider. This information is then used to place interest-based advertisements on the Website which may be relevant to your market segment based on computer algorithms;

(h) email tracking, so that we can better understand our users’ needs, for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages.

7.4 Some of the cookies used by our Website are set by us, and some are set by third parties who are delivering services (such as interest based advertising directed at your market segment) on our behalf.

7.5 Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note however, that by blocking, deleting or turning off cookies used on the Website you may not be able to take full advantage of the Website’s features.

7.6 We may revise this use of cookie 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, as they are legally binding on you. Some of the provisions contained in this cookie policy may also be superseded by provisions or notices published elsewhere on our Website.

8. Disclosure and transfer of your Personal Data

8.1 For purely administrative purposes, some of your Personal Data may be stored overseas but if so, will continue to be managed by us.

8.2 Some of your Personal Data may be collected and processed with the intention of transferring/selling it to other organizations including, without limitation, the individuals and the organizations listed in clause 8.2 below, but this will not be done unless you have given your express consent, separately to this Privacy Statement, in writing to our Data Controller or through an opt-in option that may appear on our Website.

8.3 We will keep all of the Personal Data we hold confidential but may provide information to, among others:

(a) personnel, agents, advisers, auditors, contractors, financial institutions, professional advisers and service providers in connection with our operations or Services;

(b) HedgeVista’s Group Companies, our overseas offices, affiliates, business partners and counterparts (if any);

(c) persons under a duty of confidentiality to us;

(d) persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Hong Kong, such as governmental regulatory authorities; or

(e) actual or proposed transferees or participants of our Services in or outside of Hong Kong.

8.3 Your Personal Data may also be sold to third parties in the form of lists and directories, but only after obtaining written permission from you (including in the form of opt-in options on our Website) in accordance with the provisions above.

8.4 We may transfer, sell or assign any of the information described in this Privacy Statement to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.

9. Public forums, message boards and blogs

9.1 Our Website may make message boards, blogs or other facilities for user generated content available and users are encouraged to participate in these. Any information that is disclosed in these areas becomes public information and falls outside of the scope of this Policy, therefore you should always be careful when deciding to disclose your Personal Data when making use of these facilities.

10. Transfers outside of Hong Kong

10.1 Services on the Internet are accessible globally, so collection and transmission of Personal Data is not always limited to one country. HedgeVista may transfer your Personal Data, for the purposes listed above, to Group Companies, service providers or other third parties which may be located in countries outside of Hong Kong, whose laws may not give the level of protection to Personal Data as within Hong Kong. This will include transfers to third parties who provide us with email and marketing services. Whenever we conduct any transfers we will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Statement.

11. Confidentiality and Security of Your Personal Data

11.1 We are committed to keeping the Personal Data you provide us secure. We have implemented information security policies, rules and technical measures to protect all Personal Data that is reasonably under our control from:

(a) unauthorised access;

(b) improper use or disclosure;

(c) unauthorised modification;

(d) unlawful destruction or accidental loss.

11.2 The transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Every transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and commercially reasonable security features described above to try to prevent unauthorised access.

11.3 All our employees, contractors and data processors (i.e. those who process your Personal Data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your Personal Data, are obliged to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.

12. How to Access, Update and Erase your Personal Data

12.1 Under the Ordinance you have the right:

(a) to check whether we hold Personal Data about you and to access such Personal Data;

(b) to challenge the specifics of any Personal Data that we hold about you and where appropriate to require us to correct, amend, complete or erase as soon as reasonably practicable any Personal Data relating to you that is inaccurate;

(c) to ascertain our policies and practices in relation to Personal Data and the kind of Personal Data held by us; and

(d) to object to our use of your Personal Data for marketing purposes and protection from using your Personal Data for marketing purposes after you communicate your objection to us.

12.2 If you wish to know whether we are keeping Personal Data about you, or if you have an enquiry about our Privacy Policy or your Personal Data held by us in relation to our Website or Services, or would like us to amend/erase your Personal Data or perform any of the actions listed in clause 12.1 you can contact the Data Controller, whose details are included in clause 2.3 above.

12.3 Upon your filing of such Personal Data request (“Personal Data Access Request”), we will provide you with a readable copy of all Personal Data which we keep about you. We may require proof of your identity and may charge a small fee (not exceeding the statutory maximum fee that can be charged) to cover administration and postage.

12.4 All Personal Data Access Requests must either be in the English or Chinese language.

12.5 HedgeVista will take all reasonable measures necessary to comply with your Personal Data Access Request within 40 days from the receipt of the same, by:

(a) if HedgeVista holds any Personal Data which is subject to the Personal Data Access Request:

(i) informing you in writing that it holds the Personal Data; and

(ii) supplying a copy of the Personal Data; or

(b) if HedgeVista does not hold any Personal Data, by informing you in writing that it does not hold the same.

12.6 HedgeVista may refuse to comply with a Personal Data Access Request where:

(a) it does not hold the information that you require;

(b) you are unable to prove your identity with HedgeVista;

(c) disclosing the information may require disclosure of personal information of another individual who has not been informed and/or has not consented to such disclosure;

(d) you fail to provide any information which HedgeVista may reasonably require to locate the Personal Data you require to be disclosed;

(e) HedgeVista is entitled to not comply with your Personal Data Access Request under the Ordinance.

13. How to report (suspected) breaches of your Personal Data’s privacy

13.1 If you know or reasonably suspect that a breach of your rights in relation to your Personal Data, as provided for under this Privacy Policy or under the Ordinance, has taken/is about to take place, we recommend that you immediately contact HedgeVista’s Data Controller so that we may take all reasonably necessary actions to prevent/investigate/address such breach.

14. Governing law and jurisdiction

14.1 Nothing in this Privacy Statement shall limit your rights under the Ordinance. This Privacy Statement shall be governed by the laws of Hong Kong. You agree to submit to the exclusive jurisdiction of the courts of Hong Kong.

15. Changes to this Privacy Statement

15.1 We will occasionally update this Privacy Statement to reflect new legislation or industry practice, group company changes and customer feedback. We encourage you to review this Privacy Statement periodically to be informed of how we are protecting your Personal Data.

This Privacy Statement was last updated in February 2018.