Asian Private Banker – Published and owned by Key Positioning Limited

A Notice to Customers regarding the Personal Data (Privacy) Ordinance (“the Ordinance”)


Data Protection Principles – according to The Office of The Privacy Commissioner for Personal Data (Hong Kong), headed by the Privacy Commissioner of Personal Data

Principle 1 — Purpose and manner of collection. This provides for the lawful and fair collection of personal data and sets out the information a data user must give to a data subject when collecting personal data from that subject.

Principle 2 — Accuracy and duration of retention. This provides that personal data should be accurate, up-to-date and kept no longer than necessary.

Principle 3 — Use of personal data. This provides that unless the data subject gives consent otherwise personal data should be used for the purposes for which they were collected or a directly related purpose.

Principle 4 — Security of personal data. This requires appropriate security measures to be applied to personal data (including data in a form in which access to or processing of the data is not practicable).

Principle 5 — Information to be generally available. This provides for openness by data users about the kinds of personal data they hold and the main purposes for which personal data are used.

Principle 6 — Access to personal data. This provides for data subjects to have rights of access to and correction of their personal data.

1. You are in no way obliged to provide Asian Private Banker (owned by Key Positioning Limited) with your personal data. However, such provision may be necessary so as to allow Key Positioning Limited to deliver news products or other services which you have requested.

2. The purposes which we may use your personal data are as follows:

  • the daily operation of the content, services and products provided to you;
  • meeting the requirements to make disclosure under the requirements of any law binding on Key Positioning Limited;
  • informing you of any products or services (including products and services of Key Positioning’s business partners) which Key Positioning Limited deems to be of interest to customers;
  • making services or products for customers’ use;
  • marketing and/or cross-marketing services or products;
  • conducting surveys, polls and/or other such market research; and
  • purposes relating to the above.

3. Your personal data held by Key Positioning Limited will be kept confidential but Key Positioning Limited may disclose and move such information to the following parties, whether within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), for the purpose as set out in clause 2 as mentioned above:

  • any agent, contractor or third party service provider who provides administrative, telecommunications, market research, cross-marketing, survey computer and technical support, printing, payment or other services to Key Positioning Limited in connection with the operation of its business;
  • business partners or certain third parties in order for customers to be kept informed of products or services which Key Positioning Limited believes may be of interest to customers (including products and services of those business partners and third parties);
  • any other person or organization under a duty of confidentiality to Key Positioning Limited which has undertaken to keep such information confidential; and
  • any party to whom Key Positioning Limited is required or permitted by law or any regulatory authority to make disclosure.

4. Where the party as stated in Clause 3 above is situated outside Hong Kong in a place that does not have data protection laws in Hong Kong. In any case, Key Positioning Limited will remain responsible for ensuring the confidentiality of your personal data which will be subject to appropriate security measures.

5. You have the right to:
(a)access to personal data held by Key Positioning Limited about you or your account and update or correct such data;
(b)request for information on items of personal data about you which Key Positioning Limited may routinely disclose to its business partners of cross marketing and administrative purposes;
(c)access to personal data about you so held by those service providers and/or business partners and update and correct such data;
(d)request Key Positioning Limited to stop sending marketing information to you; and
(e)ascertain Key Positioning’s policies and practices in relation to personal data and be informed of the kind of personal data held by Key Positioning Limited.

6. Key Positioning Limited reserves the right to charge a reasonable fee for the processing of any request(s) made under Clauses (5)(a) and (5)(b).

7. Your personal data will only be retained by Key Positioning Limited for as long as necessary for the needs of its business or is permitted by local legislation.

8. You shall promptly notify and contact Key Positioning Limited as set out below of any change in your personal data or other information supplied to Key Positioning Limited.

9. The person requesting access to personal data or correction of such data or for information regarding Key Positioning Limited’s policies and practices and kinds of personal data held or regarding receipt of marketing materials or otherwise is to be addressed as follows:

Key Positioning Limited

13B Greatmany Centre
111 Queen’s Road East
Hong Kong
Tel: +852 2529 5977 Fax: +852 3013 9984