DATA PROTECTION NOTICE
FIDINAM GROUP WORLDWIDE & SUBSIDIARIES
Through this data protection notice, we would like to inform you on how and why we use, store and otherwise process your Personal Data when you deal with us and/or our subsidiaries or affiliated companies.
The provisions set forth herein apply to you to the extent that Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “EU GDPR”) applies to our processing of your Personal Data. This will generally be the case if you are located in the European Union.
“Personal Data” is any information that relates to an identified or identifiable natural person (rather than to a legal entity, such as a company). Personal Data includes any information relating to an identifiable natural person (e.g. name, address, date of birth contact details, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information, etc.).
Who is providing this information?
This information is provided by Fidinam Group Worldwide Limited on its behalf and on behalf of its subsidiaries, namely:
- Fidinam (Hong Kong) Limited
- FIHK Corporate Services Limited
- Fidinam Hong Kong Trustee Limited
- Ever Decade Limited
- Sachio Limited
- Fidinam Corporate Services, Syndey
- Fidinam (Australasia) Real Estate
- Fidinam DMCC
- Fidinam Singapore
- Fidinam (Mauritus) Limited
- Fidinam (HCMC)
Fidinam Group Worldwide and its subsidiaries are hereinafter collectively referred to as “Fidinam”.
Fidinam is committed to protecting and respecting your privacy.
Where we use the terms “we“, “us” and “our” in this letter, we are referring to Fidinam.
When you provide us with your Personal Data, Fidinam acts as a “Data Controller“. In simple terms, this means that:
- we “control” the Personal Data that you provide – including use all reasonable endeavours to make sure that it is kept secure;
- we make certain decisions on how to use and protect your Personal Data – but only to the extent that we have informed you about the use or are otherwise permitted to do so by law.
What Personal Data do we collect about you?
The type of Personal Data we collect and share depends on the product or service you have with us. This can include or be related, for example, to :
- name, address, date of birth, contact details, gender, nationality, photograph, signature;
- professional information;
- your bank account(s) number(s);
- social security number and income;
- tax domicile and other tax-related information;
- if relevant, we may also collect information about your business partners, dependants or family members (such as the name of your spouse, partner, or children), representatives and agents;
- for corporate clients, information about directors, employees or shareholders;
- when you access our website, data transmitted by your browser and automatically recorded by our server. Additional information about how we use your information collected while you are visiting our website is available here https://fidinamgw.com/privacy-policy/.
Before providing Fidinam with Personal Data of other individuals (e.g. family members, representatives, agents, directors, employees, shareholders, etc.) located in the European Union, you should provide a copy of this notice to those individuals.
Where and how do we obtain your Personal Data?
We may combine Personal Data that you provide to us with Personal Data that we collect from external sources.
Why do we process your Personal Data ?
We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process Personal Data for the following purposes:
Who do we share your Personal Data with?
Your Personal Data may be shared with other persons (the “Recipients”).
Do you have to provide us with Personal Data?
Unless otherwise indicated, you should assume that we require the Personal Data for business and/or compliance purposes.
Some of the Personal Data we request is necessary for us to perform our contract with you and if you do not wish to provide us with this Personal Data, it will affect our ability to provide our products and services to you.
We have in place appropriate technical and organisational measures to prevent unauthorised or unlawful access to the Personal Data we hold. However, as complete data security cannot be guaranteed for communication via e-mails, instant messaging, and similar means of communication, we would recommend you sending any particularly confidential information to Fidinam by alternative secure means. Please note that we accept no responsibility or liability for the security of your Personal Data whilst in transit over the Internet to Fidinam.
Sending your Personal Data internationally
Fidinam entities are located outside the European Economic Area (the “EEA”). Furthermore, your Personal Data may be transferred to and stored by persons in or outside the EEA including countries which do not ensure an adequate level of protection according to the European Commission and where data protection laws might not exist or be of a lower standard than in the EEA. In particular, your Personal Data may be transferred to and stored by the Recipients and their affiliates outside the EEA.
Where Personal Data is transferred outside the EEA, Fidinam will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law.
Please contact us if you would like to know more about the the disclosure and/or transfer of your Personal Data. Please see below for our contact details.
Consent – and your right to withdraw it
We do not generally rely on obtaining your consent to process your Personal Data. However, if we do so, you have the right to withdraw this consent at any time. Please contact us or send us an email at firstname.lastname@example.org at any time if you wish to do so.
When Personal Data is processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketing at any time by clicking the “unsubscribe” link at the bottom of any marketing related emails we send to you, or by sending us an email at email@example.com.
Retention and deletion of your Personal Data
We keep your Personal Data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us. We will therefore usually delete your Personal Data (at the latest) after you cease to be a client of Fidinam and there is no longer any legal or regulatory requirement or lawful purpose for retaining your Personal Data.
In practice :
- We will generally retain Personal Data about you throughout the duration of our contractual relationship; and
- Certain Personal Data will be retained after your relationship with us ends and for a subsequent period of 10 years thereafter where necessary to comply with applicable laws and regulations or to establish, exercise or defend actual or potential legal claims, subject to the applicable statutes of limitation, unless a longer period is required by applicable laws and regulations.
You have certain data protection rights, including:
- the right to access your Personal Data;
- the right to restrict the use of your Personal Data;
- the right to have incomplete or inaccurate Personal Data corrected;
- the right to receive Personal Data we hold about you in a structured, commonly used and machine readable format;
- the right to ask us to stop processing your Personal Data for marketing purposes or for any other processing carried out on the basis of our legitimate interest where such legitimate interests are overridden by your interests or fundamental rights and freedoms;
- the right to require us to delete your Personal Data in some limited circumstances;
- you also have the right to request for us to “port” your Personal Data in a portable, re-usable format to other another data controller (where this is possible).
Concerns or queries
We encourage you to bring to our attention any concerns you may have about our processing of your Personal Data.
This data protection notice was drafted with simplicity and clarity in mind. We are, of course, happy to provide any further information or explanation needed. Our contact details are below.
If you want to make a complaint, you can contact the body regulating data protection in your country.
For instance, in Hong Kong, the Personal Data (Privacy) Ordinance, Laws of Hong Kong (Cap 486) (the “PDPO”) protects the privacy of individuals in relation to Personal Data. The PDPO and the GDPR share a number of common features.
The body regulating data protection in Hong Kong is the Office of the Privacy Commissioner for Personal Data.
Please contact us if you have any questions about Data Protection or the Personal Data we hold about you.
Contact us by email at firstname.lastname@example.org
Contact us in writing using this address:
Fidinam Group Worldwide Limited
Room 1501, Prosperity Tower,
39 Queen’s Road Central, Hong Kong
This notice was updated in Mai 2019. It is meant for information purposes and doesn’t bind Fidinam or any other party contractually. We reserve the right to amend it from time to time. We will keep you informed of any changes or updates concerning the way we process your Personal Data.