Personal Information Collection Statement

In compliance with the Personal Data (Privacy) Ordinance ("the Ordinance"), this Personal Information Collection Statement serves as a notice to you, whether you are an individual client or a director, officer, employee, agent or other representative of a client ("Client") to whom services and products may be provided by GMO-Z.com Forex HK Limited and/or GMO-Z.com Bullion HK Limited (hereafter collectively known as "Z.com Trade ") so that you are informed of the purposes for which your personal data will be used and to whom your personal data may be transferred and other matters as prescribed in the Ordinance:

  1. From time to time, it is necessary for you to supply Z.com Trade with data for the Client to open or continue accounts with Z.com Trade, or to establish or continue financial accommodation or credit facilities or obtain other services and products from Z.com Trade.
  2. Failure to supply such data may result in Z.com Trade being unable to open or continue accounts or establish or continue financial accommodation or credit facilities for or provide other services and products to the Client.
  3. Your data are also collected in the ordinary course of continuation of the business relationship between the Client and Z.com Trade, for example, when the Client effects transactions.
  4. Z.com Trade may use your data for the following purposes:
    • 4.1. processing the Client's applications for opening accounts, financial accommodation or credit facilities or other services or products;
    • 4.2. daily administering and operation of the accounts, services and facilities provided to Client;
    • 4.3. conducting client identification and verification procedures and credit checks at the time of application and from time to time during the continuation of the business relationship between the Client and Z.com Trade whether at special or regular reviews;
    • 4.4. meeting the disclosure requirements under any law, regulations, guidelines, codes of practice or court orders binding on, or applicable to, Z.com Trade or any of its group companies, including but not limited to disclosure requirements relating to prevention of money laundering and terrorist financing;
    • 4.5. complying with the obligations, requirements or arrangements for disclosing and using data that apply to Z.com Trade or any of its group companies or that it is expected to comply according to:
      • a) any law binding or applying to it within or outside the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
      • b) any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future (e.g. guidelines, guidance or requests given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information) and any international guidance, internal policies or procedures;
      • c) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers (together the "Authorities" ) that is assumed by or imposed on Z.com Forex or its group company by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
      • d) any agreement or treaty between Authorities;
    • 4.6. assisting other financial institutions to conduct credit checks and collect debts;
    • 4.7. designing services and products for the Client's use;
    • 4.8. your name and contact details may be used for marketing Leveraged Foreign Exchange trading, Over-the- counter Gold Bullion/Silver trading ,financial or related services and products of Z.com Trade and/or its group companies;
    • 4.9. ensuring ongoing credit worthiness of the Client;
    • 4.10. determining amounts owed to or by the Client from time to time;
    • 4.11.collecting amounts outstanding from the Client and/or other persons providing security for the Client's obligations;
    • 4.12.provision of reference (status enquiries) relating to the Client;
    • 4.13.conducting matching procedures by comparing data for producing or verifying data that may be used for or against the Client;
    • 4.14.enabling an actual or proposed assignee of Z.com Trade or an actual or proposed participant, sub-participant or transferee of Z.com Trade's rights in respect of the Client to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer; and
    • 4.15.purposes relating to the above.
  5. Data held by Z.com Trade relating to you will be kept confidential but Z.com Trade may provide such data to the following parties for the purposes set out in paragraph 4 above:
    • 5.1. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to Z.com Trade in connection with the operation of its business;
    • 5.2. any other person under a duty of confidentiality to Z.com Trade including a group company of Z.com Trade which has undertaken to keep such data confidential;
    • 5.3. any financial institution with which the Client has or propose to have dealings;
    • 5.4. any actual or proposed assignee of Z.com Trade or any actual or proposed participant, sub-participant or transferee of Z.com Trade's rights in respect of the Client; and
    • 5.5. any person to whom Z.com Trade or any of its group companies is under an obligation or is expected to make disclosure under any law, regulations, guidelines, codes of practice or court orders binding on, or applicable to, Z.com Trade or any of their group companies.
  6. Z.com Trade may from time to time transfer your data outside Hong Kong for the above purposes and for the purposes of data processing and storage.
  7. Under and in accordance with the terms of the Ordinance and guidelines issued pursuant thereto, you have the right:
    • 7.1. to check whether Z.com Trade holds data about you and to access your data;
    • 7.2. to require Z.com Trade to correct any of your data which is inaccurate; and
    • 7.3. to be informed of Z.com Trade's policies and practices in relation to personal data and to be informed of the kind of personal data held by Z.com Trade and the main purposes for which data will be used.
  8. You may, at any time, request Z.com Trade to cease using your personal data for direct marketing purposes by writing to Z.com Trade's Compliance Officer as prescribed in paragraph 10 below.
  9. In accordance with the terms of the Ordinance, Z.com Trade has the right to charge a reasonable fee for the processing of any data access request.
  10. Please address your requests for access to data or correction of data or for information described in paragraph 7.3 above in writing to:

    Compliance Officer
    GMO-Z.com Forex HK Limited or
    GMO-Z.com Bullion HK Limited
    Suite 2501, Sino Plaza,
    255-257 Gloucester Road, Causeway Bay, Hong Kong

    E-mail: compliance.trade.hk@z.com

  11. Nothing in this Statement shall limit your rights under the Ordinance. Should there be any inconsistencies between the English version and the Chinese version of this Statement, the English version shall prevail.
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