PortfoPlus is committed to protecting and respecting your privacy.

This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 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”).

BY USING 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 any of your information 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 information about you to us.


1 Information collection

1.1 In order to provide a better service to you, we may collect and process the following data about you:

(a) Information that you provide by filling in forms on our site (our site). 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) We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

(d) Details of transactions you carry out through our site and of the fulfilment of your orders.

(e) Details of your visits to our site and the resources that you access.


1.2 We only retain personal data for so long as it is necessary. However, a copy may be archived indefinitely.


2 Uses made of the information


2.1 The purposes for which information may be used by us in and outside Hong Kong include:

(a) ensuring that content from our site is presented in the most effective manner for you and for your computer.

(b) providing you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

(c) carrying out our obligations arising from any contracts entered into between you and us.

(d) allowing you to participate in interactive features of our service, when you choose to do so.

(e) complying with laws in or outside Hong Kong.

(f) legal proceedings, including collecting overdue amounts.

(g) notifying you about changes to our service.


2.2 We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive

promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.


3 Disclosure of your information


3.1 We will keep the personal data we hold confidential but may provide information to:

(a) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services

 (b) our overseas offices, affiliates, business partners and counterparts

 (c) persons under a duty of confidentiality to us

 (d) persons to whom we are required to make disclosure under applicable laws in or outside Hong Kong

 (e) actual or proposed transferees or participants of our services


3.2 We cannot control how third parties use information.


4 Cookies


4.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows

us to improve our site. [By continuing to browse the site, you are agreeing to our use of cookies.]

4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to

your computer's hard drive.


4.3 We use the following cookies:

(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.


(b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Google Analytics is used on our website to help analyze how users use the site. Google Analytics is a web analysis service provided by Google Inc. Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google’s ability to use and share information collected by Google Analytics regarding your visits to this site is restricted by the Google Analytics

MIXPANEL is used on our website to help analyze how users use the site. MIXPANEL is a web analysis service provided by Mixpanel. Mixpanel utilizes the data collected to track and examine the use of our website, to prepare reports on its activities. Mixpanel’s ability to use and share information collected by Mixpanel regarding your visits to this site is restricted by the Mixpanel

AMPLIDTUDE is used on our website to help analyze how users use the site. AMPLIDTUDE is a web analysis service provided by AMPLIDTUDE. AMPLIDTUDE utilizes the data collected to track and examine the use of our website, to prepare reports on its activities. AMPLIDTUDE’s ability to use and share information collected by AMPLIDTUDE regarding your visits to this site is restricted by the AMPLIDTUDE


(c) Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).


4.4 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which

we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies


4.5 You 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. 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 a password with anyone.

5.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the

security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to

try to prevent unauthorized access.


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 Data transfers


We will generally hold your data on our servers in Hong Kong. However, we may transfer it to our overseas offices elsewhere in the world or to any people listed at paragraph 3

above, who may be located elsewhere.


8 Your consent and rights


8.1 By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this Statement.


8.2 Under the Hong Kong Personal Data (Privacy) Ordinance, individuals have the right:

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

(b) to require us to correct inaccurate 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 questions or complaints to:

[email protected]

8.4 We may charge a reasonable fee for processing a 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: 30-Mar-2018