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EFM Asset Management (“EFM”) recognizes the importance of protecting your personal and financial information when you visit our website located at [Company Name’s Website] (“Website”). The following information is designed to help you understand the information collection practices at this Website.

By visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use this Website. Please review the Terms and Conditions to learn of other terms and conditions applicable to your use of this Website.


Changes to this Privacy Policy


EFM reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. We suggest that you review this Privacy Policy periodically for changes. The current version of this Privacy Policy can be accessed from the link on our homepage, at the bottom of our Website pages. We will post a message on our Website home page whenever an amendment is made to this Privacy Policy so that you will know when to check. You acknowledge that by accessing our Website after we have posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.


With respect to any expansion of the purposes of using your personally identifiable information received by us from the purposes as stated in this Privacy Policy, prior notice will be given to you and you have the right to decline acceptance of such expansion however in such circumstances our provision of continuing services to you may be limited.


Information Collection and Use


Methods of Information Collection

We may receive personally identifiable information you submit to or we collect through our Website. Failure to provide such personally identifiable information may result in EFM being unable to provide you with the services or information requested. Separately we use “cookies” or other technology (collectively “cookies”) to collect and store information about your internet connection when you visit our Website. Cookies or other technology help us to provide customized services and information. “Cookies” are small files placed on your hard drive. Each website that you visit can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Website. In addition, a number of companies offer utilities designed to help you visit websites anonymously.


Information Collected and Purpose of Information Collection


The types of personally identifiable information that may be collected at our Website include information you provided to us through the “Contact Us” page (e.g. your name and email address). Separately the “cookies” may track and record information of your activities on our Website (including user’s preference and behaviour, navigation on the Website, logged-on identity, etc.). When you are navigating our Website, we also record your IP address.


Use of Personally Identifiable Information

The personally identifiable information you submit to or through our Website is used only for responding to your inquiry sent to us, for business administration, business reporting and statistical analysis purposes, for the provision of information on EFM products and services to you, for servicing your account, that set out at the section “Information Collected and Purpose of Information Collection” and for other directly related purposes. We will not sell, share, rent or otherwise disclose or transfer your personally identifiable information to others for monetary gains. Additionally, you may encounter cookies or other similar devices on our Website that are placed by third party website tracking companies. In such circumstances the purpose and means of collection and retention policy of your personal identifiable information is the same as stated in this Privacy Policy and such information will not be transferred to any third parties except as provided under this Privacy Policy. These third party website tracking companies are our data processors which only process personal information on our behalf and do not process the personal information for any of their own purposes.


Aggregate Information: We generally record certain usage information, such as the number and frequency of visitors to our Website. This information may include the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your IP address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.


We may also disclose details about the general use of our Website to third parties e.g. to demonstrate patterns of use to advertisers and other business partners. Information we pass on will not include any personal information by which you may be identified. Retention Period: We will take practicable steps to ensure your personally identifiable information will not be retained by us longer than is necessary for the fulfilment of the Purposes.


Affiliates and Service Providers: We may provide your personally identifiable information to our affiliates and other third party service providers (including information technology service providers) for the Purposes. The third party service provider only processes your personally identifiable information on our behalf and will not use your personally identifiable information for any of its own purposes or for any direct marketing purpose. By disclosing your personally identifiable information to us via our Website, you understand that we may transfer your personally identifiable information to our affiliates or such other third service providers outside of Hong Kong to the extent legally permissible. These persons may have access to the personally identifiable information you submit through our Website, but only for the purpose of performing their duties specified in this paragraph. These persons may not use your personally identifiable information for any purpose other than those stated above.


Compliance with Laws: Except as otherwise provided in this Privacy Policy, EFM does not automatically collect personally identifiable information from visitors to our Website, except to the extent we are required to do so pursuant to any law or regulation binding on us. We will (and you authorize us to) disclose your personally identifiable information if we are required to make such a disclosure under applicable law or regulation, or where requested to do so by the police or by regulatory bodies, or where we wish to do so in relation to any suspected misuse by you of our Website, or of any of our Website services.


EFM does not sell its customers’ e-mail addresses, nor will we provide your personally identifiable information to third parties or our affiliates for their marketing purposes or any of their other purposes without your consent. It is only voluntary for you to provide your personally identifiable information for marketing purposes. As a matter of policy, EFM generally does not transfer any of your personally identifiable information to any third parties or its affiliates for marketing purposes and even if it does, it will only do so with your prior written consent.


For personal identifiable information collected in Hong Kong –your rights under PDPO: Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) of Hong Kong and codes and guidelines issued pursuant thereto, any individual:


(i) may check whether EFM holds personally identifiable information about him/her and may request access to such information;
(ii) may request EFM to correct any personally identifiable information relating to him/her which is inaccurate;
(iii) may request EFM to specify its policies and practices in relation to personally identifiable information and to be informed of the kind of personally identifiable information held by EFM; and
(iv) may withdraw his/her consent for EFM  to use his/her personally identifiable information for marketing purposes; EFM will not use his/her personally identifiable information for these purposes if he/she communicates his/her withdrawal of consent to EFM. In accordance with the terms of PDPO, EFM has the right to charge a reasonable fee for the processing of any request to supply you with a copy of your personal identifiable information (ie. data access request) mentioned above.



EFM endeavours to prevent unauthorised disclosures of your personal information by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority.

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