Privacy and the Information Handling Practices of the Mitsubishi UFJ Financial Group, Inc. (MUFG Group)
First Sentier Investors (Hong Kong) Limited is a member of the Mitsubishi UFJ Financial Group, Inc. (MUFG), a global financial group.
How we handle your personal information
Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, contact details as well as your health and financial information. We are part of the MUFG Group. We will act to protect your personal information in accordance with local law and this policy statement.
For more information about First Sentier Investors, including its relationship with MUFG, please see the About us section.
We collect personal data to provide you with the financial products and services you request as well as information on other products and services offered by us. The law may also require us to collect personal information in certain circumstances. We will tell you who collects the personal information, advise you of their contact details, your right of access to that information, and what will happen if you choose not to provide this information.
Personal information may be used and disclosed within the MUFG Group to administer our products and services, as well as for prudential and risk management purposes and, depending on your choice, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We co-operate with police and other enforcement bodies as required or allowed by law.
We disclose relevant personal information to external organisations that help us provide services. These organisations are bound by confidentiality arrangements. They may include overseas organisations.
You can seek access to the personal information we hold about you. If the information we hold is inaccurate, incomplete or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why.
If you have any questions or would like further information on our privacy and information handling practices, please contact us.
At First Sentier Investors, the privacy of your personal data is important to us. We collect personal data to make and maintain investments on your behalf or on behalf of your clients in funds managed by us as well as to provide you with information about other products and services we offer. In some circumstances the law may also require us to collect personal data.
In Hong Kong, Personal Data is defined as any data
(a) relating directly or indirectly to a living individual;
(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
(c) in a form in which access to or processing of the data is practicable;) from those data
First Sentier Investors is bound to protect your personal data in accordance with applicable laws and/or guidelines, and the principles contained therein.
The following statement outlines our general information handling practices.
How is your personal data dealt with?
In the course of doing business and/or operating this website, we may use internal service providers or outsource certain tasks to third party administrators or agents. These internal providers or third parties will have access to your personal data submitted via the website; their use of your data would be restricted to authorized use(s) as stipulated in the confidentiality arrangements to which they are bound by. Your personal data may also be used by us to administer, monitor and evaluate products and services, inform you about promotional activities, gather, aggregate and report statistical information, assist you with any queries and take measures to detect and prevent fraud and other illegal activity. We may also be allowed or obliged to disclose information by law or by the rules of any applicable regulatory body or otherwise where you have given your consent. In some instances, your personal data may be transferred out of the jurisdiction.
We aim to ensure that the personal information we retain about you is accurate, complete and up to date. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking or the best of our products for your individual circumstances.
What personal data do we collect?
First Sentier Investors collects personal data on investors, clients, intermediaries and business contacts via application forms, other First Sentier Investors forms, investment management agreements, correspondence, business cards, phone, fax, e-mail and on-line. Personal data collected may include:
Date of birth
Bank account information
The main purpose for First Sentier Investors collecting your data is to make and maintain investments on your or your client's behalf in funds managed by us. If you would like to receive further information from us about other products or services offered by First Sentier Investors please ensure you tick the relevant box on the appropriate application form or contact us by e-mailing us at firstname.lastname@example.org
E-mail and Marketing
We do not intend to use your email addresses for direct marketing purposes, nor will we provide your personal data to third parties or our affiliates for their marketing purposes without your consent. As a matter of policy, we do not transfer your personal data to any third parties or its affiliates for marketing purposes, or we would only do so with your prior written consent. Also, we will not send you e-mail messages without first receiving your consent, unless it relates to servicing your account or unless you have consented to receiving electronic delivery of fund documents as part of our E-Delivery service. It is our policy to include instructions for unsubscribing from these services, or withdrawing any consent previously provided.
Personal Data Quality
We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date. Please contact us by e-mailing us at email@example.com if any of the details you have provided change. Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.
Personal information security
We are committed to keeping secure the personal data you provide to us. We take all reasonable precautions to protect the personal data we hold about you from misuse and loss and from unauthorised access, modification or disclosure. We have a range of physical and technological policies and procedures in place to provide a robust security environment. We seek to ensure the on-going adequacy of these measures by regularly reviewing them. Our security measures include, but are not limited to: restricting access to our computer systems and physical records to authorised persons and preventing users from accessing information they have no need to access; and requiring employees to use unique passwords to gain access to systems. These passwords are changed regularly and their use is independently monitored; employing firewalls, intrusion detection systems and virus scanning tools to prevent unauthorised persons and viruses from entering our systems; using dedicated secure networks or encryption on sensitive customer information transmitted via email when we transmit electronic data for purposes of outsourcing; providing secure storage for physical records; and detecting and preventing unauthorised access to buildings by employing physical and electronic means such as alarms and cameras. Where information we hold is identified as no longer needed for any purpose we take reasonable steps to effectively and securely destroy it.
Online services - collection of information via web site activity
For statistical purposes we may collect information on web site activity (such as the number of users who visit our web site, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our web site from another web site, the address of that web site) through the use of 'cookies'. Unless the web site is a secure web site this information on its own does not identify an individual but it does provide us with statistics that can be used to analyze and improve our web site.
We may also collect your personal data via your use of our web site. Generally, the information that we collect is what you give us when you complete a Form or otherwise make an enquiry via the web site.
A 'cookie' is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer. When you use our public web site, we send you a temporary cookie (known as a session cookie) that gives you a unique identification number. A different identification number is sent each time you use our web site. Session cookies do not identify individual users, although they do identify a user's browser type and your Internet Service Provider (ISP). At the end of your interaction with our public web site, the session cookie "crumbles". This means it no longer exists on your computer and therefore it cannot be used for further identification or access to your computer. We also use persistent cookies in certain parts of our sites. A persistent cookie is stored on your hard drive and is read by your browser each time you visit the secure web site. The persistent cookie can be used to track your browsing habits and present more appropriate or personalised content. A persistent cookie has an expiry date and is stored on your hard drive until that date. To evaluate the effectiveness of our web sites, we may use third parties to collect statistical data. No personal data is collected on these occasions. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use parts of our web sites as intended.
Links to other web sites
Our web site may contain links to non-First Sentier Investors web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
We monitor and record telephone calls for training and security purposes.
Your rights relating to Personal Data under the Personal Data (Privacy) Ordinance of Hong Kong (“Ordinance”)
(i) Right to confirm with us whether your personal data is being held;
(ii) Right to access and obtain a copy of such data;
(iii) Right to have your personal data corrected; and
(iv) Right to object to use of your personal data for marketing purposes
If you have any questions or would like further information on our privacy and information handling practices or would like to exercise any of these rights, please address them to:
Data Protection Officer
First Sentier Investors (Hong Kong) Limited
One Exchange Square
8 Connaught Place
Central, Hong Kong
First Sentier Investors will respond promptly, and in any event within 7days, to a request by you in relation to any of the above. If we deny access to your personal information, we will let you know why.
First Sentier Investors (FSI) is committed to maintaining high standards of corporate governance, ethics and behaviour in all of its activities, as part of which FSI requires that its employees display the highest levels of professionalism in all aspects of their work to facilitate compliance with its code of conduct and all applicable laws.
FSI is also committed to providing a culture where all staff are encouraged to raise concerns about unacceptable practice and misconduct. This extends to others with a connection to FSI such as directors, contractors, consultants, suppliers and service providers or a relative or dependent of these individuals or their spouse.
Individuals as noted above with information in relation to serious wrongdoing (including unethical, illegal, corrupt or other inappropriate conduct) are encouraged to contact the FSI Whistleblowing Protection Officer via:
- The First Sentier Investors EthicsPoint website click here.
The global direct access telephone hotline on +1-844-319-1607, or a local toll free number in the following locations:
- Australia: 1-800-515-184
- Hong Kong: 800-93-3975
- United Kingdom: 0808-234-5817
- United States: (844) 319-1607
- Singapore: (StarHub) 800-001-0001 OR (SingTel) 800-011-1111 then 844-319-1607
This Website is produced by First Sentier Investors (Hong Kong) Limited and has not been reviewed by the Securities and Futures Commission of Hong Kong.