Personal Information Collection Statement

For clients (and prospective clients)

1. It is often necessary for clients (and prospective clients) to supply us with personal data about themselves in connection with the provision of our services to those clients.

2. Failure to supply such personal data may result in us being unable to provide clients (and prospective clients) with the relevant services.

3. The purposes for which personal data relating to a client may be used are as follows:

3.1 the provision of services to the client in accordance with the instructions of the client and as we may otherwise deem appropriate or necessary;

3.2 designing services or related products for clients’ use;

3.3 collection of outstanding fees from clients;

3.4 meeting the requirements to conduct client identification and verification and to make disclosure under the requirements of any law, guideline, code of practice or practice direction binding on, or applicable to us including, but not limited to, any such law, guideline, code or practice direction relating to anti-money laundering and anti-terrorism;

3.5 purposes specifically provided for in any particular service offered by us; and

3.6 purposes directly related to any of the above;

3.7 the client’s name and contact details (including but not limited to an office address, telephone number, and email address) provided by the client to us will be used for marketing our services and/or related products.

If a client does not want us to use his personal data for the purposes mentioned in paragraph 3.7 above, he may email info@bluepenadvisory.com, indicating his decision.

4. Personal data held by us relating to a client (and prospective clients) will generally be kept confidential but we may provide such information for the above purposes to:

4.1 our branch or associated firm or office;

4.2 a government agency such as the Hong Kong Police, the Hong Kong Customs and Excise Service, the Hong Kong Immigration Service, and the Independent Commission Against Corruption, if we know or suspect that any person is engaged in drug trafficking, terrorism or any other serious crime or handling the proceeds of crime or that any property constitutes terrorist property; in this case, the obligation to report to the authorities may override our confidentiality obligations;

4.3 any other legal practitioner (including, without limitation, solicitors, barristers, and foreign lawyers), accountant, or other financial or professional adviser representing the client in connection with those services and advice being provided to the client us;

4.4 any financial institution, business or professional firm with which the client has or proposes to have dealings related to the services or advice being provided to the client by us;

4.5 any actual or proposed assignee of us or transferee of our rights in respect of the client or any firm which takes over, or is negotiating the take-over of, our business or into which we are merged;

4.6 if a client is ever in default of payment of our fees or otherwise, debt collection agencies; and

4.7 to third-party service providers which provide administrative, technology, marketing, or other services to us in relation to our business operations.

5. We will retain clients’ personal data only for so long as is necessary to fulfil the purpose for which they were collected. After that time, their personal data will be erased.

6. Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) and guidelines issued pursuant thereto, any individual may:

6.1 check whether we hold personal data about him/her and may request access to such data;

6.2 request us to correct any data relating to him/her which are inaccurate;

6.3 request us to specify its policies and practices in relation to personal data and to be informed of the kind of personal data held by us; and

6.4 request us to cease using his/her personal data for marketing purposes.

7. In accordance with the terms of the PDPO, we have the right to charge a reasonable fee for the processing of any data access request.

8. Requests for access to personal data or correction of personal data; for information regarding policies and practices and kinds of data held are to be addressed in writing to:

Privacy Officer

Blue Pen Advisory

Email: info@bluepenadvisory.com

9. Nothing in this Statement shall limit the rights of clients under the PDPO.

For Staff and persons applying to us for employment

If you are enquiring about a position with us, we will ask for your CV and any information relevant to your application. We will use personal information about you in connection with recruiting you, processing your application for the position, and if applicable, extending an offer to you. Any personal information submitted as part of a job application will only be used in connection with such application.

Get in touch

info@bluepenadvisory.com

Address: 2/F, Dah Sing Life Building,
99-105 Des Voeux Road Central, Hong Kong