Privacy Policy

Introduction

Leadtone Asia Limited is committed to protecting all Personal Data obtained in the course of conducting our business. In this Privacy Policy, "we", "our", "us" and "Leadtone" refer to Leadtone Asia Limited, and "you" and "your" refer to each customer, guarantor or power of attorney, if applicable.

The term "Personal Data" refers to data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data user. Leadtone is accountable for all Personal Data in our possession.

This Policy explains:

• The types of Personal Data we collect.
• How your Personal Data is used.
• How your Personal Data may be shared.
• How you can access the Personal Data we retain and how to keep it accurate.
• The steps we take to ensure your Personal Data is handled in a safe and secure manner.
• How to contact us with any privacy concerns.

Collecting Your Personal Data

We collect information from you when you register on our website, respond to a survey, subscribe to a newsletter, or enter personal information on our registration page. We may process your Personal Data because:

• We need to perform a contract with you.
• You have given us permission to do so.
• The processing is necessary for our legitimate interests in conducting our business.
• For payment processing purposes.
• To comply with legal or regulatory requirements under Hong Kong law.

When you apply for or use any product or service, we may collect Personal Data such as:

• Information establishing your identity (name, address, email address, mobile telephone number, occupation, date of birth, HKID number and other identification documents required by law).
• Information to authenticate your identity such as knowledge-based information, biometric information, and device information.
• Information about your financial status including employment history, annual income, assets, liabilities, and credit history.
• Information reflecting your business dealings with us.
• Information about your balances and transactions, including account activity and payment history.
• Other information with your consent, or as permitted or required by law.

Using Your Personal Data

We may use your Personal Data for the purposes communicated to you at the time of collection or in your agreement(s) with us, including to:

• Verify your identity and authenticate you when you contact us.
• Evaluate and process your application, account, transaction, and reports.
• Set up your accounts and provide ongoing service.
• Provide you with products and services you have requested.
• Communicate with you, including to respond to your inquiries.
• Market a product or service, either directly or through a service provider, partner or third party.
• Help manage and assess our risks, operations, and relationship with you.
• Comply with legal, regulatory, governmental and contractual requirements under Hong Kong law.

We may also use your Personal Data for other purposes with your consent or as permitted or required by law.

Sharing Your Personal Data

We may share your Personal Data:

• With Leadtone partnering companies.
• With our employees, agents, service providers and any other entities that perform services on our behalf. Some service providers may be located outside of Hong Kong.
• With other financial institutions to process payments or to verify information such as your identity and income.
• With payment card networks to operate or administer the payment card system.
• To meet requests from the Privacy Commissioner for Personal Data, Hong Kong Monetary Authority, or other regulators.
• To satisfy legal, audit, insurance, self-regulatory and regulatory requirements applicable to us under Hong Kong law.
• Where permitted or required by law.

We do not sell the names or other Personal Data of our customers. We do not disclose Personal Data to other companies outside of Leadtone without consent, unless required or permitted by law.

Cross-Border Data Transfers

When we transfer your Personal Data outside of Hong Kong, we ensure appropriate safeguards are in place to protect your Personal Data in accordance with the Personal Data (Privacy) Ordinance and any applicable regulations.

Protecting Your Personal Data

We have implemented organisational, technological and physical safeguards to protect the security of your Personal Data. These safeguards are intended to protect Personal Data against loss or theft, and against unauthorised access, disclosure, copying, use or modification. We audit our procedures and security measures regularly to ensure they remain effective and appropriate.

Accessing and Updating Your Personal Data

Under the Personal Data (Privacy) Ordinance, you have the right to request access to and correction of your Personal Data held by us. You are responsible for advising Leadtone of any inaccuracies or changes to your Personal Data. Please be prepared to verify your identity when updating or changing your Personal Data.

Data Retention

We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law or regulation.

Use of Cookies on Our Website

We use cookies on our website to ensure it functions properly. Cookies are small text files placed on your computer that associate and identify activity with you. They do not delete data from your computer or damage files or programs.

Any use of our website means that you agree to our cookies policy. In the privacy and security settings of your browser you can choose to delete or disable all cookies. Note that certain features of the website may no longer work properly when disabling cookies.

Your Rights

Under the Personal Data (Privacy) Ordinance, you have the right to:

• Request access to your Personal Data.
• Request correction of your Personal Data.
• Object to the use of your Personal Data for direct marketing purposes.
• Withdraw consent where processing is based on consent.

Contacting Us

To request access to or correction of your Personal Data, or to ask questions about our privacy practices, please contact us at:

If you have complaints about this Policy, you may also contact the Office of the Privacy Commissioner for Personal Data:

Changing this Policy

We may amend this Policy from time to time to take into consideration changes in legislation or other issues that may arise. If we make changes, we will post the revised Policy on our website. Your continued use of our services after changes have been made constitutes your acceptance of those changes.