Privacy Policy

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 (e.g., contact information, account numbers, or details such as age, marital status, and financial information). Leadtone is accountable for all Personal Data in our possession.

This Policy has been designed to comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and 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; and
• 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 registration page. You authorize the collection of Personal Data from these sources, and where applicable, you authorize these sources to provide us your Personal Data.

Under the Personal Data (Privacy) Ordinance, we collect and use your Personal Data for the purposes specified in our data collection statements and in accordance with the Data Protection Principles. 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, provide a guarantee in respect of, or use any product or service, and while you are our current or former client, or act on behalf of one, we may collect and confirm Personal Data about you such as:

• Information establishing your identity (such as your name, address, email address, mobile telephone number, occupation, date of birth, Hong Kong Identity Card number and other identification documents required by law).
• Information to authenticate your identity such as knowledge-based information (i.e. username, password and account information), biometric information (i.e. signature, fingerprint and voiceprint), device information (i.e. device model, browser type and activity, IP address, security cookie and approximate physical location of device);
• Information about your Financial status including your employment history, annual income, assets, liabilities, and credit history.
• Information reflecting your business dealings with us.
• Information about your balances and transactions, including bank/investment/mortgage account activity and payment history.
• Information about beneficial owners, intermediaries, and other parties, which is required by law.
• Other information with your consent, or as permitted or required by law.

Using Your Personal Data

We may use this 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 to authenticate you when you contact us, or we contact you.
• 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.
• Understand your product and service requirements.
• Market a product or service, either directly or through a service provider, partner or third party.
• Determine your eligibility for some of our products and services and offer them to you.
• 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.

If for any reason your information is required to fulfil a different purpose than that of your original intent, we will seek your consent before we proceed, unless such use is permitted under the Personal Data (Privacy) Ordinance.

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 (collectively, 'service providers'). You acknowledge that some of our service providers may be located outside of Hong Kong and as such your Personal Data may be accessible to governmental, national security and regulatory authorities in accordance with the laws of these jurisdictions.
• With other organizations or agents with whom you have arrangements and to whom you have provided consent directly.
• 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 that supports the products, services, or accounts you may have with us.
• To meet requests for information from the Privacy Commissioner for Personal Data, Hong Kong Monetary Authority, Securities and Futures Commission, or other regulators.
• To satisfy legal, audit, insurance, self-regulatory and regulatory requirements applicable to us under Hong Kong law.
• In any negotiations for the sale or assignment or proposed sale or assignment of all or part of our business or assets (including the sale of mortgages) and to our successors and assigns who may use the information for similar purposes as those described in this Policy.
• To other parties connected with your account, as applicable (e.g., guarantors, powers of attorney and other people named on the application).
• To a joint account holder, including limited information about the account prior to it becoming a joint account.
• Where permitted or required by law.

We do not sell the names or other Personal Data of our customers. We do not disclose the names or other Personal Data of our customers to other companies outside of Leadtone without consent, unless required or permitted by law. We may use affiliates or other companies to provide services on our behalf such as data processing, account administration, analytics and marketing. Such companies will be given only the Personal Data needed to perform those services and we do not authorize them to use or disclose Personal Data for their own marketing or other purposes. We have or will have contracts in place holding these companies to the same standards of confidentiality by which we are governed.

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 organizational, technological and physical safeguards to protect the security of your Personal Data under our control in a manner that is appropriate to the sensitivity of the Personal Data. These safeguards are intended to protect the security of Personal Data, regardless of the format in which it is held, against loss or theft, and against unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and representatives will have access to your Personal Data to perform their job functions. The importance of protecting the confidentiality of your information is specified in our employment agreements and regularly confirmed in writing. We audit our procedures and security measures regularly to help ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the information.

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 (such as a change of address, telephone numbers, current address, marital status, etc.). If any of your Personal Data changes or you discover inaccuracies in our data, you are required to advise us so we can update our records. 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

Cookies are text files that are placed on websites on the internet. Each cookie includes the name of the website and a unique ID. We use cookies on our website. They do not delete data from your computer, or damage files or programs. We make use of cookies in order for the internet site to function properly.

Cookies are a small bit of record-keeping information that we store in your computer/other equipment to associate and identify activity with you. Cookies collect this information and share it with us, the website owner.

Any use of the internet site means that you are acquainted, and you agree with this storage of cookies policy and unconditionally accept all terms. In the privacy and security settings of your browser you can choose to delete or disable all cookies from your computer. Keep in mind that certain features of the website may no longer work properly when disabling cookies.

To find out more about our Cookies Policy and processes used to collect and use cookies, please email us at

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, to ask questions about our privacy policies or to refuse or withdraw your consent to our use of your Personal Data for purposes outlined in this Policy, you may send in a written request or contact us at:

If you have any complaints or concerns about this Policy or our privacy practices, please email us at or contact the Office of the Privacy Commissioner for Personal Data:

If you choose to send us an email, do not include sensitive information.

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. If we intend to use or disclose your Personal Data for purposes materially different from what is described in this Policy, we will take reasonable steps to notify you. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices, as your continued use of our services or provision of Personal Data after changes have been made to this Policy constitutes your acceptance of those changes.