Privacy Policy
PERSONAL INFORMATION COLLECTION STATEMENTS AND PRIVACY
POLICY STATEMENT

(1) Policy
SP Trader Pro HD ('Software') is licensed to the Brokers ('Brokers'), registered securities dealer with the Securities and Futures Commission ('SFC') in Hong Kong. Brokers provide brokerage services to their clients - dealing in securities and/ or futures, and Sharppoint ('SP') - the developer of the Software.
 
To facilitate the Service provided by the Brokers using the Software ("Service"), it may be necessary for the Users of the Software ('the Users') to provide the Brokers with personal data of the Users. Failure to supply such personal data may result in the Brokers being unable to provide the Service to the Users.

The Policy set out hereunder regarding the use of personal data ("Information") is
applicable to the Service provided and maintained by the Brokers.
The Users hereby agree that any Information supplied by the Users to the
Brokers is on a voluntary basis, and is accurate, true, current and complete. If this
is not the case or the Brokers have reasonable grounds to suspect as such, the
Brokers have the right to cancel and/or refuse the Service to the Users.

(2) Collection of Personal Data
The Brokers collects the Information during membership or subscription
registration.
Information supplied by the Users to the Brokers and/or collected by the
Brokers may include but is not limited to the following: -
(a) name;
(b) postal address, country or zip/postal code;
(c) telephone or mobile phone or fax number;
(d) e-mail address;
(e) payment details, including banking information; or
(f) other data in connection with the operations of the Service by the Brokers.
The Users have control of the disclosure of Information to the Brokers; of course, the
choice of the Users to refrain from disclosing, might limit the Service the Brokers can offer to the Users.
The Brokers will endeavor to maintain Information as accurately as possible only
upon the latest information provided by the Users.

Brokers can develop their own client portal, which is a webpage for Users to manage their accounts. There is a function for Users to provide updated information to Brokers. This function allows Users to submit the deposit notice and upload supporting documents such as bank slip or address proof to Brokers. 
 
SP helps Brokers to develop the application for internet trading on mobile device, Brokers request to embedded the client portal in the application, so that their Users can access the portal and conduct account related activities easily. Therefore, an upload function is built in the client portal and require the application to access to mobile camera or storage.

(3) Purposes
The Users understand that any and all Information the Users provide to
the Brokers will be collected and may be used for the purposes of: -
i. conducting surveys;
ii. marketing and promotions;
iii. collecting data for identity ratification and records;
iv. handling and following up service calls, enquiries and complaints;
v. maintaining contact lists for correspondence;
vi. meeting any legal, governmental or regulatory requirements in Hong Kong or
any other applicable jurisdiction, including disclosure or notification
requirements;
vii. providing information for internal use, including chat or bulletin boards,
editorial and feedback purposes; or
viii. carrying out the Users' instructions, responding to enquiries by that
Users or made on behalf and providing the Users with the Services.

Information submitted by the Users will be used for the Users to access to
different authorized areas of the Brokers' website and, when necessary, to enable
contact.

In some instances, the Users may also be requested to enter certain data which
may be used to better tailor the type of information presented to the Users. In
most cases, this type of data is optional although, where the requested service is a
highly personalized Service, failure to provide the requested data may prevent the
Brokers from providing such a service to the Users.

(4) Use of Information for Direct Marketing
If the Users does not wish the personal data to be used for direct marketing by
the Brokers, the Users may make such request to the Brokers in writing or by
e-mail.

(5) Transfer of Information
The Users are hereby aware, agree and authorize that all Information will be
retained by and stored in one or more databases of the Brokers and will be provided
to, disclosed to, accessed by and transferred to: -
i. any person or bodies corporate or division within the Brokers and/or the
Brokers' group of companies;
ii. any person or bodies corporate under a duty of confidentiality to the Brokers;
iii. employees of the Brokers;
iv. any contractors, agents, other persons or bodies corporate engaged by the
Brokers for or in relation to any of the purposes listed above or any third-party
service providers who provide administrative, telecommunications, computer,
payments, securities clearing, insurance, professional or other services to the
Brokers;
v. any person by whom the Brokers is required by applicable legal,
governmental or regulatory requirements to make disclosure; or
vi. any other person reasonably requiring the same in order for the Brokers to
provide the Service and to carry out the purposes set out herein.
The Users agrees that the Brokers may release the information when such
release is reasonably necessary to:
i. comply with applicable law;
ii. enforce or apply the terms of any agreements;
iii. protect the rights, property or interest of the Brokers or its Users; or
iv. comply with the Brokers' Privacy Policy Statement.

(6) Security of personal data
Given the nature of the Internet, the Brokers cannot guarantee that the transmission
of data is 100% secure. However, the Brokers shall take all practicable steps to
ensure that any Information collected by the Brokers through the website is safe and
secure from third party interference.
Physical records containing personal data are securely stored in locked areas and/or
containers when not in use.
Computer data are stored on computer systems and storage media to which access is
strictly controlled and/or are located within restricted areas.
Access to records and data without appropriate management authorization are strictly
prohibited. Authorizations are granted only on a "need to know" basis that is
commensurate with an individual's Broker responsibilities and their training.
Records of the Brokers are under the control of assigned information officers who
are responsible to ensure the transfer of or access to information is legitimate and
complies with the Ordinance.
Audit records may be produced to validate data modifications in order to verify the
data's integrity.
There may be violations logging processes for investigation of any unauthorized
attempt to access information.
Encryption technology may be employed for the certain data collected.

(7) Cookies
Cookies are items of information that a website transfers to an individual's hard drive
for record-keeping purposes while at the site. Cookies make Web-surfing easier by,
among other things, saving the passwords, purchases, and preferences for the
Users. The use of cookies is an industry standard, and the Users will find
cookies at most major web sites.
Cookies help make the Brokers better, by showing how and when the Users
uses the site. Many content improvements and updates are based on data such as
total number of visitors and pages viewed. This information is most easily tracked
with cookies.
Here are some examples of how the Brokers use cookies:
A cookie lets the Service remember that the Users has registered, which allows
the Brokers to speed up the Users' future activities at the Brokers' sites.
Similarly, if there are any stores within the Service, a temporary cookie tracks which
products the Users has selected while shopping. The cookie expires once the
Users has finished shopping. Letting it do the record-keeping saves the
Users the trouble of entering information over and over again during a single
visit. If the Users don't use this cookie, the Users may have difficulty
ordering the selections.
The cookie itself does not contain any personally identifying information although it
may enable the Broker to relate the Users' use of the Service to personally
identifying information that has previously been submitted by the Users, if any.
The Users may occasionally get cookies from the Brokers' advertisers.
These cookies are sent from third-party computers and are subject to such third
parties' policies.
Most browsers are initially set to accept cookies. If the Users do not want the
above information to be disclosed, the Users should set the Users'
mobile device to refuse cookies. However, it is likely that most areas of the site will not
function properly if the Users does so.

(8) Personal Data (Privacy) Ordinance
The Brokers will apply and follow the laws and principles of the Personal Data
(Privacy) Ordinance, Cap. 486 of the Laws of Hong Kong Special Administrative
Region ("the Ordinance"). The Brokers' staff and any relevant person under a
duty of confidentiality to the Brokers shall maintain a strict confidentiality policy on
all Information collected from the Service.
Under the Ordinance, the Users have the right to: -
i. check whether the Brokers holds any Information about the Users;
ii. have access to Information about the Users held by the Brokers;
iii. request correction of such Information;
iv. ascertain our policies and practices (from time to time) in relation to the
Information and the types of Information held by the Brokers;
v. disallow access to or use of Information about the User by the Brokers;
or
vi. be informed of action taken in response to the request of the Users for
correction of the Information held by the Brokers.
In accordance with the terms of the Ordinance, the Brokers have the right to charge a
reasonable fee in relation to the time and attendance involved in complying the
request of the Users in this regard.

(9) Access and Correction of Information
Any request for access or correction can be made by the Users on the website
(subject to prior confirmation of identity) or by sending the request  to the Brokers

THE BROKERS RESERVE THE RIGHT TO CHANGE THIS POLICY AT ANY
TIME
BY NOTIFYING THE USERS, THROUGH A NOTICE POSTED ON THE
SERVICE OR BY EMAIL, OF THE EXISTENCE OF A NEW PRIVACY POLICY
OR ANY UPDATES.
N.B.
ATTENTION KIDS: IF THE USERS ARE 16 OR UNDER, THE
USERS MUST GET PERMISSION FROM A RESPONSIBLE ADULT
BEFORE THE USERS DO ANY OF THE FOLLOWING ON OR
THROUGH THE SERVICE.
i. SEND ANY INFORMATION ABOUT THE USERS OR OTHERS
ii. ENTER ANY CONTEST, GAME OR SWEEPSTAKES
IF THE USERS GET PERMISSION FROM A RESPONSIBLE ADULT TO
SUBMIT THE USER'S NAME TO BE PUBLICLY POSTED ON THE
SERVICE, THE USERS SHOULD NEVER USE THE USER'S FULL
NAME. JUST SUBMIT THE USER'S FIRST NAME OR INITIALS.