Silver Bullion (Hong Kong) Limited

Privacy Policy

In this Privacy Policy, "Silver Bullion", "we", "us" or "our" means Silver Bullion (Hong Kong) Limited.

Silver Bullion is committed to protecting the privacy and confidentiality of our customers' personal data.

We collect and use personal data only for legitimate purposes connected with our relationship with you, the services you request from us, the protection and administration of your account and holdings, and our legal and regulatory obligations.

We do not sell, rent or trade your personal data. We do not provide your personal data to third parties for their own marketing or unrelated commercial purposes.

Where we need to disclose personal data to another person, we do so only where reasonably necessary to provide or support the services you have requested, administer or protect your account or holdings, comply with applicable legal or regulatory requirements, obtain necessary professional or operational support, or where you have authorised the relevant disclosure.

This Privacy Policy explains how Silver Bullion collects, uses, processes, stores, protects and, where necessary, discloses personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO").

This Privacy Policy applies to personal data held by or on behalf of Silver Bullion, including personal data collected through our website, account opening process, transactions, customer communications and other services.

Silver Bullion remains responsible for personal data under its control, including where such data is hosted, stored, accessed or processed on our behalf by an authorised entity within the Silver Bullion Group or an external service provider.

Personal Information Collection Statement

This Personal Information Collection Statement ("PICS") forms part of this Privacy Policy and applies where Silver Bullion collects personal data directly from you.

Where an account opening page, application form, identity verification process, Change Request, transaction instruction or other collection point refers or links to this Privacy Policy, this PICS explains why the relevant information is being collected and how it may be used.

Purpose of Collection

We collect personal data for purposes connected with establishing, administering and maintaining our relationship with you, including:

a)opening, maintaining and administering your account;

b)verifying your identity and conducting customer due diligence, sanctions screening, politically exposed person screening, fraud prevention, risk assessment and other compliance checks;

c)assessing and processing applications, orders, purchases, sellbacks, payments, withdrawals, storage arrangements and other instructions;

d)maintaining records of your precious metals purchases, sales, holdings, ownership, storage and transactions;

e)communicating with you regarding your account, transactions, services, security matters and changes affecting our relationship with you;

f)complying with applicable legal, regulatory, reporting, audit and record-keeping requirements;

g)operating, maintaining, protecting and securing our website, systems and services;

h)responding to enquiries, complaints, disputes, data access or correction requests and other communications;

i)facilitating audits, insurance, verification or reconciliation relating to customer holdings or storage records;

j)establishing, administering, monitoring, varying, releasing or, where applicable, enforcing a pledge, charge, lien, security interest or other security arrangement over your holdings where requested or agreed to by you and approved by us; and

k)sending newsletters or other marketing communications only where you have expressly consented to receive them.

Whether Provision of Personal Data Is Obligatory

The provision of some personal data is voluntary, while other information may be required for us to provide a particular product or service, comply with applicable legal or regulatory requirements, or properly administer your account.

Where particular personal data is required for account opening or maintenance, identity verification, due diligence, transaction processing, payment, storage, withdrawal, sellback or another requested service, failure to provide the required information may prevent us from opening or maintaining your account, processing the relevant instruction or providing the relevant service.

Providing personal data for marketing purposes is voluntary. You are not required to consent to marketing in order to open or maintain an account or use our services.

Persons to Whom Personal Data May Be Disclosed

Where reasonably necessary for the purposes described above, personal data may be disclosed to or processed by:

a)authorised entities within the Silver Bullion Group that provide technology, hosting, operational, compliance, customer service, accounting, cybersecurity or administrative support to Silver Bullion;

b)custodians, vault operators and storage service providers involved in the custody or administration of your holdings, including The Safe House SG Pte Ltd;

c)banks, payment service providers, settlement providers, logistics providers and other persons involved in completing a transaction or service requested by you;

d)identity verification, screening, technology, cloud infrastructure, cybersecurity and other service providers processing personal data on our behalf;

e)auditors, inspectors, insurers, insurance brokers, loss adjusters and their respective agents where reasonably required for audit, verification, reconciliation, insurance or claims purposes;

f)our legal advisers, accountants, auditors and other professional advisers;

g)regulatory authorities, governmental authorities, law enforcement agencies or courts where disclosure is required or permitted by applicable law; and

h)where you request or agree to an approved pledge, charge, lien, security interest or other security arrangement over your holdings, the relevant lender, secured party, security holder or other person involved in establishing, administering, monitoring, varying, releasing or enforcing that arrangement.

Any disclosure will be limited to information reasonably necessary for the relevant purpose.

Access and Correction

You have the right to request access to and correction of your personal data in accordance with the PDPO.

Privacy enquiries and requests for access to or correction of personal data should be addressed to:

Data Protection Officer
Silver Bullion (Hong Kong) Limited
Unit B, 20/F, 228 Electric Road, North Point, Hong Kong
Email: dpo@silverbullion.com.hk

We may charge a fee for complying with a data access request where permitted by law, but any such fee will not be excessive.

Collection of Personal Data

"Personal data" means information relating to a living individual from which the identity of that individual can be directly or indirectly ascertained.

We may collect personal data directly from you or, where lawful and appropriate, from persons acting on your behalf, corporate representatives, public registers and databases, identity verification and screening providers, banks or payment service providers, regulatory or governmental authorities, authorised entities within the Silver Bullion Group, or other sources relevant to our services or compliance obligations.

The types of personal data we may collect include:

a)Personal Particulars: name, residential address, date of birth, nationality and other identifying information.

b)Identity Verification Information: copies or images of passports, Hong Kong Identity Cards, national identity cards or other government-issued identification documents, together with photographs, selfies, facial images, video recordings, liveness checks, facial verification results and other information generated or collected in connection with identity verification.

c)Contact Information: telephone numbers, mobile numbers and email addresses.

d)Employment and Financial Profile Information: occupation, employer or company name, position or title, nature of business or industry, income information and positions held in companies or other organisations.

e)Financial and Due Diligence Information: bank names and account information, source of funds, source of wealth, expected transaction activity, and supporting information or documents required for due diligence, risk assessment or ongoing review.

f)Holdings and Transaction Information: information relating to your precious metals purchases, sales, holdings, ownership records, storage arrangements, transaction history, payments, settlements and any pledge, charge, lien, security interest or other arrangement affecting your holdings.

g)Customer Communications and Feedback: enquiries, instructions, correspondence, feedback, complaints and other communications.

h)Appointment Information: information required to arrange and facilitate visits to our premises.

Data Minimisation and Accuracy

We collect only personal data that is necessary, adequate and not excessive for the purposes for which it is collected.

We take all practicable steps to ensure that personal data held by us is accurate having regard to the purposes for which it is used.

We may ask you to update or verify your information from time to time, particularly where information is required for account administration, identity verification, customer due diligence, transactions or regulatory compliance.

Where we have reasonable grounds to believe that personal data is inaccurate for the purpose for which it is to be used, we will take appropriate steps to correct, verify or cease using the information as required by applicable law.

Use of Personal Data

We use your personal data for the purposes set out in the Personal Information Collection Statement above and for purposes directly related to them.

We will not use your personal data for a new purpose that is not the purpose for which it was collected or a directly related purpose unless we obtain prescribed consent where required under the PDPO, or the use is otherwise permitted or exempted by law.

Marketing Communications

We will only use your personal data for direct marketing where you have expressly consented to receive marketing communications from us.

Where you select the newsletter option, you consent to Silver Bullion using your email address to send you newsletters and updates concerning gold, silver and platinum products and services.

We will not use your personal data for direct marketing unless we have received your consent.

We do not sell your personal data or provide it to any third party for that party's marketing purposes.

You may withdraw your consent at any time. We will stop using your personal data for direct marketing without charge, and withdrawing your consent will not affect your account or services.

Disclosure and Confidentiality of Personal Data

We treat customer personal data as confidential.

We do not sell, rent or trade customer personal data. We do not share customer lists or provide personal data to other persons for their own marketing, advertising, profiling or unrelated commercial purposes.

We may disclose personal data only where reasonably necessary for one or more of the purposes set out in the Personal Information Collection Statement above.

Where disclosure is necessary, we limit the personal data disclosed to what is reasonably required for the relevant purpose.

Where another person acts as a service provider or processor for Silver Bullion, that person is not permitted to use Silver Bullion customer personal data for its own unrelated purposes.

Where another person processes personal data on our behalf, we adopt contractual or other appropriate means to require that the information is:

a)used only for authorised purposes;

b)protected by appropriate confidentiality and security safeguards;

c)accessible only to authorised persons;

d)not retained longer than necessary for the relevant processing; and

e)subject to appropriate controls over any permitted subcontracting or onward processing.

Personal data is only shared within the Silver Bullion Group where necessary for the purposes described in this Privacy Policy, and access is limited to authorised persons who need the information for those purposes.

Security of Personal Data

We take all practicable steps to protect personal data in our possession or control against unauthorised or accidental access, processing, erasure, loss or use.

We maintain administrative, technical and physical safeguards appropriate to the nature and sensitivity of the personal data concerned.

These measures include appropriate access controls, confidentiality restrictions, system security measures and controls over persons permitted to access customer information.

Access to customer personal data is limited to authorised persons who require access for legitimate operational, compliance, security, legal or customer service purposes.

Where another person processes personal data on our behalf, we adopt contractual or other appropriate measures requiring appropriate confidentiality and security safeguards.

Processing and Storage Outside Hong Kong

Silver Bullion uses technology and operational infrastructure located in Singapore to support its customer accounts and services.

Personal data relating to your Silver Bullion account may therefore be hosted, stored, backed up, processed or accessed in Singapore.

This includes information relating to your account, identity verification, customer due diligence, transactions, holdings, communications and other services.

Processing in Singapore may be carried out by authorised entities within the Silver Bullion Group and service providers acting on behalf of Silver Bullion.

Personal data may also be accessed or processed in Singapore where necessary in connection with customer holdings stored through The Safe House SG Pte Ltd, operational support, compliance reviews, audits, insurance, cybersecurity, incident response, record keeping or an approved security arrangement.

Silver Bullion remains responsible for personal data under its control notwithstanding that the data is stored, processed or accessed outside Hong Kong.

Where personal data is processed on our behalf outside Hong Kong, we use contractual or other appropriate means to require that it is:

a)used only for authorised purposes;

b)protected by appropriate confidentiality and security safeguards;

c)accessible only to authorised persons;

d)not retained longer than necessary; and

e)subject to appropriate controls over subcontractors and onward processing.

Retention of Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected or as required for legal, regulatory, audit, investigation, dispute resolution or record-keeping purposes.

When personal data is no longer required, we take all practicable steps to erase or anonymise it, subject to applicable legal, regulatory, audit, investigation, dispute resolution or record-keeping requirements.

Where personal data is processed on our behalf by an authorised entity within the Silver Bullion Group or another service provider, we adopt contractual or other appropriate means to require that the information is not retained longer than necessary for the relevant processing.

Cookies and Related Technologies

Our website uses cookies and similar technologies to support the operation and security of the website and to understand how the website is used.

Essential cookies may be used for functions such as login, session management, security, fraud prevention and site preferences.

Analytics cookies may be used to understand general website usage and improve our website and services.

Links to External Websites

Our website may contain links to external websites not operated or controlled by Silver Bullion.

Once you leave our website, the privacy practices of the relevant third party will apply.

We are not responsible for the privacy practices, security or content of external websites and encourage you to review their applicable privacy notices.

Amendments to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, our services, technology infrastructure, storage arrangements or data processing practices.

The latest version will be made available on our website.

An amendment to this Privacy Policy will not, by itself, permit us to use previously collected personal data for a new purpose where prescribed consent is required under the PDPO.