At Hooray Group, we want to provide the best service possible to our clients. This Statement is made by Hooray Group in accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region ('the Ordinance'). The Statement is intended to notify clients of why personal data is collected, how it will be used and to whom data access requests are to be addressed.

1. From time to time, it is necessary for customers to supply Hooray Group with data in connection with the opening or continuation of accounts and the establishment or continuation of trading or credit facilities or provision of financial, securities, derivatives, investment, financing and related services, products and facilities.


2. Failure to supply such data may result in Hooray Group being unable to open or continue accounts or establish or continue trading or credit facilities or provide the services, products or facilities mentioned in clause 1 above.


3. From time to time, it is necessary for clients who are individuals to supply with Hooray Group data which are personal data for the purposes of and therefore protected by the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong). The purposes for which Data (and other information) relating to clients may be used are as follows:
   1. the daily operation of the services and facilities provided to clients;
   2. conducting credit checks;
   3. assisting other institutions to conduct credit checks;
   4. ensuring clients' ongoing credit worthiness;
   5. designing financial services or related products for clients' use;
   6. marketing financial services or related products to clients;
   7. collection of amounts outstanding from the clients, enforcement of securities, charges or other rights and interests against the clients;
   8. determining the amount of indebtedness owed to or by clients;
   9. meeting the requirements to make disclosure under the requirements of any legal and/or regulatory requirements or court orders binding on Hooray Group; and
   10. any purposes relating to any of the foregoing.


4. Data (and other information) held by Hooray Group relating to clients will be kept confidential but Hooray Group may disclose, and it is a condition of Hooray Group providing services, products and information to clients that each client consents to the disclosure of, all Data (and other information) to:
   1. any officer, employee, agent, contractor or third party who provides administrative, credit information, debt collection, telecommunications, computer, payment, trade execution, cash, securities and/or clearing or settlement or other services to Hooray Group in connection with the operation of their business;
   2. any other person under a duty of confidentiality to Hooray Group including but not limited to any member of the Hooray Group which has undertaken to keep such information confidential;
   3. any financial institution or dealer with which the client has or proposes to have dealings;
   4. any credit reference agency and in the event of default, any debt collection agency;
   5. regulatory or judicial authorities and other relevant government or statutory bodies;
   6. We do not share information about our clients with other companies except in order to conduct our business, comply with applicable law, protect against fraud or make available special offers of products and services that we feel may be of interest to our clients;
   7. We may also provide information to regulatory authorities and law enforcement officials in accordance with applicable law; and
   8. any exchange, entity, agency, regulatory or government body in any jurisdiction if required by law or pursuant to any court orders, rules or regulations to which Hooray Group is subject. In such cases, Hooray Group is usually under a duty of secrecy and will not be able to notify a client or seek his/her consent in relation to such release of information.


5. USE OF DATA IN DIRECT MARKETING
   Hooray Group may use a client's personal data in direct marketing with the client's consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
   1. the client's personal data such as the client's name, telephone number, email address, correspondence address, account number, products and services portfolio information, transaction pattern and behaviour, risk profile, financial background and investment objectives and experience may be used by Hooray Group in direct marketing;
   2. the following classes of services, products, facilities and marketing subjects may be marketed:
      • financial, securities, commodities, derivatives, investment, financing and related services, products and facilities;
      • reward, loyalty or privileges programmes and related services, products and facilities;
      • services, products and facilities offered by business partners of any member of Hooray Group providing any of the services, products and facilities referred to in clause 5(ii)(a) above; and
      • donations and contributions for charitable and/or non-profit making purposes;
   3. the above services, products, facilities and marketing subjects may be provided or (in the case of donations and contributions) solicited by Hooray Group and/or any of the following persons:
      • any member of the Hooray Group;
      • third party financial institutions and providers of any of the services, products and facilities referred to in clause 5(ii)(a) above;
      • third party reward, loyalty, co-branding or privileges programme providers;
      • business partners of any member of Hooray Group providing any of the services, products and facilities referred to in clause 5(ii)(a) above; and
      • charitable or non-profit making organisations;
   4. Hooray Group may, with the client's written consent (which includes an indication of no objection), also provide the personal data described in clause 5(i) above to any of the persons referred to in clause 5(iii) above for use by any of them in direct marketing of the services, products, facilities and marketing subjects referred to in clause 5(ii) above. Hooray Group may so provide the personal data to such persons for direct marketing purposes for gain.
   If a customer wishes Hooray Group to cease to use and provide his/her personal data to other persons for use in direct marketing, the client may notify Hooray Group in writing by mailing or faxing the written notification to the postal address or fax number provided in clause 10 below. Hooray Group shall then cease to use and provide his/her personal data for direct marketing purposes without any charge.


6. Hooray Group may, in accordance with the Personal Data (Privacy) Ordinance and any other applicable law:
   1. match, compare or exchange any Data or other information provided by, or in respect of, a client with Data (or other information) held by Hooray Group or any other person for the purpose of:
      • credit checking;
      • Data (and other information) verification;
      • otherwise producing or verifying Data (and other information) which may be used for the purpose of taking adverse action against the client or any other person at any time;
   2. transfer such Data (and other information) to any place outside Hong Kong (whether for the processing, holding or use of such Data (and other information) outside Hong Kong).


7. Under and in accordance with the terms of the Personal Data (Privacy) Ordinance each client has a right to:
   1. check whether Hooray Group hold Data about the client and the right of access to such Data;
   2. require Hooray Group to correct any Data relating to the client which is inaccurate; and
   3. ascertain Hooray Group ’s policies and practices in relation to Data and to be informed of the kind of personal data relating to the client held by Hooray Group; and
   4. request Hooray Group to cease using Data about the client for direct marketing purpose.


8. In accordance with the terms of the Personal Data (Privacy) Ordinance, Hooray Group has the right to charge a reasonable fee for the processing of any Data access request.


9. At Hooray Group, all information regarding our clients is used solely in the legitimate conduct of our business, to deliver superior service and to design products and special offers that demonstrate our understanding of our clients and their needs. None of the members of Hooray Group shall have any liability to the clients if any information supplied by the clients or on their behalf is incorrect or inaccurate.


10. The person to whom requests for ceasing to use of personal data in direct marketing, access to data, correction of data or information regarding policies and practices and kinds of data held are to be addressed as follows:
    
    Hooray Securities Limited - Compliance Officer
    1/F, Guangdong Investment Tower,
    148 Connaught Road Central,
    Hong Kong

As we move forward in developing new products and services in an era of vast technological change, we will continue to maintain our dedication to assuring that client information is properly used and appropriately safeguarded.