PortfoPlus Limited (“we”, “us”, “our” or the “Company”) is committed to protecting and respecting your privacy.


This policy sets out the basis on which we process, collect, transfer, store and use personal data we collect from you. This privacy policy specifically addresses our obligations in respect of personal data privacy under the Personal Data (Privacy) Ordinance of Hong Kong SAR, Chapter 486 of the Laws of Hong Kong SAR (the “Ordinance”).The term “personal data” shall have the meaning ascribed to it by the Ordinance.

BY USING THE PORTFOPLUS WEBSITE OR MOBILE APPLICATION (collectively, “PortfoPlus") OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. Do not use PortfoPlus or give us your personal data if you do not agree to the terms of this privacy policy. However, we will not be able to render certain services to you if you do not provide such personal data to us.


1 Collection of Personal Data

1.1 Types of personal data collected by the Company may include:-

(a) Information that identifies you, such as your name, gender, date of birth, contact details, mailing and billing address;

(b) Information you provide to the Company through PortfoPlus, telephone conversations with the Company’s representatives, and in response to customer surveys;

(c) IP address, real-time geographic location data, browser settings, browsing records, and/or other internet log information of your computer or mobile device via the use of cookies on our website;


1.2 The Company may collect personal data from you in the following circumstances:-

(a) when you fill in forms on our website (“our site”) or in our mobile application PortfoPlus. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information at other times, for example in connection with a promotion or when you report a problem with our site;

(b) If you contact us, we may keep a record of that correspondence;

(c) When you choose to complete surveys that we use for research purposes;

(d) When you make orders and/or carry out transactions through our site;

(e) When you visit our site and access its resources.


The above list is not exhaustive as there may be other situations or circumstances in which we may be required to collect personal data from you. We will not collect any personal data from you except in circumstances where you have knowingly provided that information to us or you have authorised a third party to provide that information to us.


1.3 We only retain personal data for so long as it is necessary to fulfil the purposes for which the personal data were to be used, as specified in this Privacy Policy.  


2 Purpose of Collection and Uses of Personal Data

2.1 The purposes for which personal data may be collected by us include:


(a) developing and improving the quality of the Company’s products and services (“Services”), our site and mobile application;

(b) providing you with information, products or services that you request from us or which we feel may interest you (subject to your consent, please see section 2.2 below);

(c) carrying out our obligations arising from any contracts entered into between you and us and/or to provide the Services, including (but not limited to) providing relevant information or advice, processing your enquiries, and undertaking administration, planning and account management functions as well as other associated business processes;(d) allowing you to participate in interactive features of our service, when you choose to do so.

(e) complying with any applicable law, rule, regulation or guideline issued by regulatory or other authorities in or outside Hong Kong.

(f) handling any claim, action and/or legal proceedings for or against the Company or any party in relation to the Services, including collecting overdue amounts;

(g) notifying you about changes to our Services;

(h) to conduct research and statistical analysis, customer profiling and analysing market trends, and to generate reports for disclosure to the public using anonymised, pseudonymised or de-identified personal data.


2.2 From time to time, the Company may use your personal data to send you news, offers, promotions and joint marketing offers and the Company requires your consent for that purpose. Such consent will be sought from you at the time of collection of your personal data. We may contact you via email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials by informing us (see below for contact details), and we will cease to do so, without charge.


3 Disclosure of Personal Data

3.1 We will keep the personal data we hold confidential but where disclosure is necessary for the Company to comply with any statutory or legal obligations or requirements, or for the Company to provide the Services to you, or to complete any transactions you have requested, or to carry out any related purposes for which the persona data were collected, such personal data may be provided to the following parties (whether within or outside Hong Kong):


(a) personnel, agents, advisers, IT consultants, data processors, auditors, accountants, lawyers, contractors, banks and financial institutions, and service providers in connection with our operations or Services;

(b) our overseas offices, affiliates, business partners (including our agents and collaborators) and counterparts;

(c) persons to whom we are required to make disclosure under applicable laws in or outside Hong Kong, including any competent court of law, law enforcement agencies, or other governmental or statutory authorities, institutions or organisations where necessary;


4 Use of Cookies

4.1  We collect activity information on our site through the use of cookies. Cookies do not identify you; they simply allow us to track usage patterns and provide us with statistics to analyse and improve our site.

4.2 You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.


5 Security

5.1 All information you provide to us is stored on our secure servers. We use modern security methods including data encryption to safeguard the personal data provided by you. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.


5.2 We will take all reasonable steps to protect your personal data from loss, misuse, unauthorised access, modification or disclosure.


6 Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page.


7 Transfer of Personal Data Outside Hong Kong

Where necessary, the Company may transfer your personal data to third parties outside of Hong Kong for the purposes specified in this Privacy Policy. We will ensure that any international transfer of your personal data is made pursuant to appropriate safeguards in accordance with the Ordinance as well as applicable laws and regulations in Hong Kong.


8 Data Access and Correction

8.1  By providing your personal data to us, you are consenting to the terms of this Privacy Policy.

8.2 Under the Ordinance, you have the right:

(a) to check whether we hold personal data about you and to access such data;

(b) to correct your personal data;

(c) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us.


8.3 Please send requests to access or correct data, to cease communications, and/or your questions or complaints to Colin Wong (Director) at [email protected].

8.4 We reserve the right to charge a reasonable fee for processing any data access request.


9 Governing law and jurisdiction

This Privacy Policy Statement shall be governed by the laws of the Hong Kong Special Administrative Region. You agree to submit to the exclusive jurisdiction of the Hong Kong courts.

Last updated: 18-Jul-2021