This also applies - and in particular - to cooperation with partners and third parties which we use for the processing of contracts. Your data will neither be passed on to third parties nor sold, unless you expressly agree.
OLZ guarantees the confidentiality of all stored personal data of registered users.
As part of this privacy notice, we would like to inform you about how we ensure the protection of the information you provide: The personal data is collected, processed and used only in accordance with the provisions of applicable data protection law. Our data protection practice is therefore consistent with the Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
In summary, OLZ asserts that no personal data will be collected beyond this website without your consent. You alone decide to what extent you wish to disclose this data or not, such as with a registration or similar.
2. Accountable authority / EU-Representative
In cases referred to in Article 3, paragraph 2 of the Regulation (EU) 2016/679 (General Data Protection Regulation; GDPR) and in accordance with Article 27 of GDPR as representative in the EU is designated:
OLZ Wealth Management AG
Principality of Liechtenstein
You may reach our EU representative at: info(at)olz.li
2b. Accountable authority
Responsibility for the processing of personal data is with:
OLZ (Hong Kong) Limited
Suite A1, 19/F, Two Chinachem Plaza
68 Connaught Road, Central, Hong Kong
Tel.: +852 3619 4178
For any request related to the protection of your personal information, please contact our privacy officer
+852 9098 0372
3. Personal Data
Personal data is any information relating to an identified or identifiable natural person; a natural person is considered as being identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics expressing the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person. This includes, for example, your name, your telephone number, your address, as well as all inventory data that you provide us with when registering and creating your client account. Statistical data or anonymised data, which we collect, for example, when you visit our web shop and which cannot be directly linked to your person, is not covered here.
4. Purposes of Data Collection
a) The collection and processing of this data is carried out for the purpose of contract compliance, for the purpose of enabling the use of our website (connection establishment), to ensure system security and stability on a permanent basis, to optimise our web presence, and for internal statistical purposes. We collect, store and process personal data solely in accordance with the applicable statutory regulations and insofar as this is both necessary and required to fulfil and improve the contractual performance obligations between us and the user / client. This also includes the storage of data for any warranty claims after the end of the contract.
b) In addition, we use your data within the scope of applicable law for our own marketing purposes in order to optimise our web presence and to draw your attention to services that might be of particular interest to you.
c) In addition, collection, processing and use of personal data only takes place if you have given your consent.
OLZ likes to inform you regularly about current topics and projects around our field of activity via the newsletter. You will receive a newsletter from us only upon express request. We use the opt-in process to send the newsletter, which means that you will receive our newsletter by email provided that you have previously explicitly registered for newsletter delivery. When you have registered for the newsletter, your email address will be used together with your consent for our own promotional purposes until you unsubscribe from the newsletter. You can unsubscribe at any time. We are entitled to commission third parties for the technical handling of promotional activities and are entitled to pass on your data for this purpose.
The data provided by you when registering for the newsletter (name and email address) will be stored and used only to send the newsletter.
6. Legal basis for processing
7. Legitimate interests for processing
In addition to the aforementioned legal basis for data processing, we also process data based on our legitimate interests. This applies in particular, but is not limited to, processing for marketing and promotional purposes. We pursue, in particular, the following interests:
ensuring potential use of the website
ensuring the security and stability of IT systems
our own marketing purposes
internal statistical purposes
OLZ is entitled to pass your personal data on to third parties abroad if this is required for the execution of the contract. These third parties are bound to the same level of data protection as the provider. If the level of data protection in one country does not correspond to the Swiss level, we contractually ensure that the protection of your personal data corresponds at all times to that in Switzerland.
9. Automatic data processing method
We collect personal information for the purpose of creating an investment profile. This data is evaluated via an automated method. The logic of the programme is relatively simple: it evaluates your answers to specific questions and assigns them to different categories which correspond to levels moving from defensive to dynamic.
This method enables us to manage you according to your requirements and to offer you suitable products; the evaluation thus forms the basis for the selection of products offered to you.
At your request, we can also have this baseline evaluation performed ‘by hand’, ie by a person rather than an automated method. In most cases, the result will be the same.
10. Duration of retention
We retain your personal data for as long as is necessary to comply with applicable laws, or as we deem appropriate, or as long as it is required for the purposes for which it was collected. We will block or delete your personal data as soon as it is no longer needed and definitely on expiry of the statutory maximum retention period.
You can request your personal data to be deleted at any time by sending us a corresponding request to padraig.seif(at)olz.com.hk. We will comply with your request promptly provided we are not required to retain it for other reasons or need it, for example for the enforcement of claims.
11. Further data sources
In addition to the data that we collect directly from you, we also obtain data from public registers (such as the Commercial Register) and from third-party providers.
Since data sources vary according to the client, no general information can be given regarding said sources. If desired, we are of course willing to disclose our sources of data to you in detail.
12. User rights
12.1. Right of Revocation
Insofar as you have given us consent to collect, store and use personal data in regard to the website or our services, you can revoke this consent at any time. The revocation can be sent by email or in writing to the contact above in section 2: Accountable Authority. The effects of the revocation are limited to the storage and use of personal data, which may not be stored and used without your prior consent based on statutory permission. The revocation also has no effect on previous processing procedures made on the basis of the consent.
12.2. Further rights
On written request, we will give you information at any time about your stored personal data. The request for information must be made in writing and with proof of identity (copy of ID, passport or other official identification document). Exercising this right is free of charge once a year; for any further request, we reserve the right to charge for cost incurred.
b) Correction, deletion, restriction of processing
In addition, you have the option of having your personal data corrected, blocked or deleted by us at any time. Please contact the authority, details of which can be found in section 2. Excluded from deletion is solely the data which we need for the completion of outstanding tasks or for the enforcement of existing rights and claims, also data which we are obliged to keep due to statutory regulations. Such data will be blocked.
c) Right of appeal
We attach great importance to safeguarding the rights of our clients and therefore also to the protection of your personal data. Nevertheless, should you be of the opinion that we process your data unlawfully, you can contact us at any time on +852 3619 4178 or by email padraig.seif(at)olz.com.hk with details of your concern. We will address your concerns to the best of our ability. If, contrary to expectation, our client service cannot provide you with satisfactory assistance, you can submit your concern to the Federal Data Protection Supervisor at any time as a formal complaint, which will then be investigated.
d) Data portability
Upon written request, you also have the right to receive personal data relating to you in a structured, current, machine-readable format (pdf file) for transmission to a third party. We reserve the right to charge for costs incurred.
13. Children's data
To the best of our knowledge, we collect, process and use children’s personal data only with the consent of their legal representative. Persons under the age of 16 must obtain the permission of their legal representative before they provide us with personal data.
Accordingly, the use of our website for persons under the age of 16 who do not have the consent of their parents is generally inadmissible.
We use session-based, temporary cookies: these do not remain on your computer. When you leave our pages, the temporary cookie will also be discarded. With the help of the information gathered, we can analyse the usage patterns and structures of our website and optimise it by improving content or personalisation and simplifying use.
In addition, we use persistent cookies: these remain on your computer to simplify shopping, personalisation and registration services on your next visit. For example, these cookies may record what you have chosen to buy while you continue to shop. Also, you only need to enter your password once on web pages that require login. Persistent cookies can be manually removed by the user. They delete themselves after a certain time has elapsed.
Cookies are also used by some of our advertising partners (third-party cookies). These cookies help us tailor our site to the specific needs of our clients, for example, by showing advertisements that might actually interest you. Using these cookies enables us to gather information about which products you have viewed or searched for or which pages you have previously visited. These cookies are stored on your hard drive and delete themselves after a certain time. There is also no personal information stored in the cookies used by our advertising partners. Use is pseudonymised so that no conclusion is drawn on your identity.
Most browsers (such as Firefox, Chrome, Internet Explorer, Safari, etc.) accept cookies by default. You can allow or block temporary and persistent cookies in the security settings - independently of each other. However, we should point out that certain features are not available on our website and some websites may not display properly if you disable cookies.
The data stored in our cookies will not be linked to your personal data (name, address etc.) without your express consent.
15. Liability for links
OLZ expressly states hereby that at the time of setting links no illegal content was identifiable on the pages so linked. We have no influence on the current and future design, content or authorship of linked pages. Therefore, we hereby expressly dissociate ourselves from all content on and of all linked pages which are changed after establishing the link. This statement applies to all links and references on our web presence. Regarding illegal, incorrect or incomplete content and in particular, for damages resulting from the use or non-use of such information, only the provider of the page to which reference was made is liable and not whoever simply sets the link to the respective publication.
16. Web analysis
16.1. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. (Google) for needs-based design of websites. We only receive data evaluations with no personal references.
You can prevent cookies being installed by setting your browser software accordingly. However, we should point out that in this case you may not be able to use all functions of this website to the full extent. By using this website, you consent to the processing of data collected on you by Google in the manner and for the purposes set out above.
16.2. Google AdWords
This website uses Google AdWords, an analytics service provided by Google Inc. (Google). Google Adwords sets a cookie on your computer (conversion cookie) if you have reached our website via a Google advertisement. These cookies expire after 30 days and are not used for personal identification. If you visit certain of our pages and the cookie has not expired, we and Google can see that someone clicked on the advertisement and was redirected to our site. Each AdWords client receives a different cookie. Cookies cannot be tracked via the AdWords clients' websites. The information gathered with the conversion cookie is used to generate conversion statistics for AdWords clients who have opted for conversion tracking. We do not receive any information with which users can be personally identified.
If you do not want to participate in the tracking process, you can also reject the required setting of a cookie - for example, via a browser setting that generally disables the automatic setting of cookies.
17. Security measures
We apply technical and organisational security measures to appropriately protect your personal information from unauthorised access, abuse, accidental or intentional manipulation, loss or destruction. To protect your privacy, we use a secure connection for our website, which you can see from the ‘https’ (https stands for Hypertext Transfer Protocol Secure) at the very beginning of the address bar in your browser. In this way, the connection is encrypted via SSL/TSL and your data cannot be intercepted by third parties. Technical security measures to protect your personal data are regularly checked and, if necessary, updated. These principles also apply to companies which process and use personal data on our behalf and in accordance with our instructions.
Hong Kong, 19. December 2019
This is the website of the following company: OLZ (Hong Kong) Limited, a company formed under the laws of Hong Kong, with its principal activities in Hong Kong and registered with the Companies’ Register under registration number 2719143.
We understand that our customers and website visitors are concerned about the privacy of information. We have established policies and procedures concerning the collection, use and security of your information that will help protect your privacy. This privacy statement provides information on the obligations and policies of OLZ (Hong Kong) Limited under the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance").
OUR COMPANY POLICY
OLZ (Hong Kong) Limited recognizes the importance of personal data to our business and the importance of respecting the privacy rights of our clients. Therefore, we are committed to ensuring compliance with the requirements of the Ordinance. Each employee of OLZ (Hong Kong) Limited must abide by our commitment to privacy in the handling of personal information. To further enhance confidentiality and security of all personal data, only authorized staff will be allowed to have access to the personal information collected. It is restricted to those persons who have a business need to access personal information in order to perform their job duties.
The purpose of this privacy statement is to establish the policies and practices of OLZ (Hong Kong) Limited's commitment to protect the privacy of personal data and to inform you about our responsibilities and your rights under the Ordinance.
Types of Personal Data Held
There are two broad categories of personal data held by us. They are personal data relating to clients and employees of OLZ (Hong Kong) Limited.
(1) Personal data held by us relating to clients may include the following:-
(a) name and address, occupation, contact details, date of birth, their identity card or passport numbers;
(b) current employer, nature of position, relevant income of clients;
(c) details of financial status of clients; and
(d) information obtained by us in the ordinary course of the business relationship.
(2) Personal data held by us relating to employees may include the following:-
(a) name and address, contact details, date of birth and nationality of employees and their spouses and their identity card or passport numbers and place and date of issue thereof;
(b) additional information compiled about employees which may include records of remuneration and benefits paid to the employees, records of job postings, transfer and training, records of medical checks, sick leave and other medical claims and performance appraisal reports of the employees; and
(c) relevant personal data pertaining to former employees may be required by us to fulfill obligations to the former employees and legal obligations under certain ordinances.
Main Purposes of Keeping Personal Data
(1) The purposes for which personal data relating to clients may be used are as follows:-
(a) facilitating the daily operations of the services provided to the clients;
(b) marketing investment products or services by OLZ (Hong Kong) Limited ;
(c) providing investment products or services;
(d) maintaining statistical data and providing a database for product and market research;
(e) marketing financial or investment products or services (other than investment products or services provided by OLZ (Hong Kong) Limited ) by any company/companies other than OLZ (Hong Kong) Limited, subject to client's express prior written consent;
(f) compliance with applicable laws and regulations; and
(g) any other purposes relating or incidental thereto.
(2) The purposes for which personal data relating to employees may be used are as follows:-
(a) determining and reviewing salaries, bonuses and other benefits;
(b) consideration for promotion, training, secondment or transfer;
(c) providing employee references;
(d) registering employees as intermediaries or licensees with statutory authorities/institutions for purposes directly related or associated to the employment; and
(e) any other purposes relating or incidental thereto.
Transfer of Personal Data
Personal data held by OLZ (Hong Kong) Limited relating to clients will be kept confidential but may be transferred to the following parties (whether within or outside the Hong Kong Special Administrative Region) for any of the purposes stated above:-
(a) any agent, contractor, third party service provider or any company(ies within the same group of companies to which OLZ (Hong Kong) Limited belong ("the member company(ies)") which provides administrative, telecommunications, computer, marketing, professional or other services to OLZ (Hong Kong) Limited in connection with their business operations;
(b) any person to whom OLZ (Hong Kong) Limited is under an obligation to make disclosure under the requirements of any law binding on OLZ (Hong Kong) Limited or any of the member companies or under and for the purposes of any guidelines issued by regulatory or other authorities with which OLZ (Hong Kong) Limited or the member companies are expected to comply;
(c) any actual or proposed assignee of OLZ (Hong Kong) Limited or participant or sub-participant or transferee of OLZ (Hong Kong) Limited 's rights in respect of the client; and
(d) any persons or bodies corporate under a duty of confidentiality to OLZ (Hong Kong) Limited.
Accuracy of Personal Data
OLZ (Hong Kong) Limited strives at all times to ensure accuracy of all personal data collected and processed by us. In order to assist us to deliver on this pledge, please inform us immediately in the event that your personal information has been changed or you discovered that your personal information held by us is incorrect.
It is not a statutory requirement for you to provide personal data to us. However, we will not be able to provide you with the services and products you may wish to subscribe to from OLZ (Hong Kong) Ltd. unless you provide us with the necessary personal data or information.
You have a right
(i) to be informed whether we hold any of your personal data;
(ii) to be supplied with a copy of your personal data we hold; and
(iii) to request correction of your personal data we hold. If you wish to access to and/or to correct any of your personal data held by us, please send your written request to the address set out below. We may, subject to the Ordinance, impose a reasonable fee for complying with a data access request.
Data Protection Officer
OLZ (Hong Kong) Limited
Suite 1A, 19/F, Two Chinachem Plaza
68 Connaught Road