This statement is made by The Motley Fool Hong Kong Limited (“TMF”, “we”, “us” or “our”).
We are committed to protecting and respecting your privacy. This Privacy Statement sets out how we may collect, use and disclose your Personal Data (as defined below). We are committed to protecting and respecting your privacy rights under the Personal Data (Privacy) Ordinance (Cap 486) of Hong Kong (the “PDPO”). We are equally committed to ensuring that all our staff with access to your Personal Data upholds the same obligations.
We may amend this Privacy Statement from time to time. If we make any substantive changes to this policy, we will announce it on our site.
In the event of any inconsistencies between the English and Chinese versions of this Privacy Statement, the English version will prevail.
A. Collection of Personal Data
“Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. We may collect the following Personal Data from you:
- Signing up for content delivered via email:When you sign up for a report or other content delivered by email, we will ask for your basic information that is relevant to the provision of services by us, such as your name, country of domicile and email address. We may also capture your IP address.
- Subscribing to any premium products and services: When subscribing to any of our premium products and services, we need to know, in addition to your basic information, the sort of information typically used for credit card transactions, such as your name, billing address, telephone number, credit card number, card verification code and expiration date. We encrypt all of this information using Secure Socket Layers (SSL) technology.
- Other services:We may also ask for more Personal Data in order to provide you with other services. For example, if we launch a text alert feature, we would need to ask for your mobile number in order to provide you with this service.
The provision of any Personal Data is entirely voluntary, but without certain Personal Data we will not be able to provide you with some of our services. When we ask for your Personal Data in respect of a product or service, we will specify the fields which are mandatory and without which we would not be able to provide you with the relevant product or service.
If you are aged 18 or under, please obtain your parent or guardian’s permission before providing us with any Personal Data. Users without this consent are not allowed to provide us with Personal Data.
Information we automatically track
B. Use of Personal Data
We will collect and use your Personal Data for the following purposes:
- To provide you with our services: We may use your Personal Data to contact you if you have subscribed to any of our products or services, in order to deliver our services to you. Your Personal Data will be used to facilitate the delivery and provision of our products and services to you.
- To provide you with a customised experience:We may analyse your Personal Data to provide you, the user, with the best and most personalised web experience possible and to provide our advertisers with an efficient means to reach the right audience. We may use your Personal Data in identifying and tailoring our contents for your use.
- To market our products: If you have given consent as described in the section titled “Direct marketing” below, we may use your Personal Data in marketing our various products and services.
- Legal or regulatory obligation: We may need to make disclosure to comply with requirements and obligations on us, our parent company and/or affiliates under any law, regulation or court order, or under and for the purposes of any guidelines issued by regulatory or other authorities.
- Other related purposes: We may use your Personal Data for any other purpose directly related to or incidental to the above-mentioned purposes.
C. Security, retention, transfer and storage of Personal Data
TMF is committed to protecting your Personal Data. We will take all reasonable steps to ensure the security of your Personal Data. In order to prevent unauthorised access or disclosure, we have implemented technical and organisational security measures to protect and secure your Personal Data and ensure that it is used only in accordance with this statement and the PDPO, including but not limited to the following:
a) all Personal Data that you provide to us is stored on our secure servers; and
b) access to paid-for areas of the site, such as our premium services is password-protected for your privacy and security.
Where Personal Data is stored, accessed or transmitted via the Internet, it is not completely secure. We will take all reasonable steps to protect your Personal Data, but we do not have any control over, and cannot guarantee the security of your Personal Data transmitted via the Internet. Therefore, any such storage, access or transmission is at your own risk.
You are responsible for maintaining the secrecy of your passwords and/or any account information. If you think your username or password has been disclosed to another person, is lost or stolen or has been used without your authorisation, you are responsible for informing us immediately and we shall not be responsible for any direct or indirect loss which you may suffer if you fail to notify us immediately.
Retaining your Personal Data
We will ensure that your Personal Data is retained by us only for so long as is necessary in accordance with applicable laws and regulatory requirements and procure our third party service providers to do the same. Once it is no longer necessary for us to retain your personal information, we may dispose of this information in a permanent and secure manner. Please note that any Personal Data collected directly from our website by any third parties will be stored and retained according to their own privacy policies.
Transfer and storage
We may from time to time transfer your Personal Data to a location outside Hong Kong. Your Personal Data may also be transferred to and/or processed by our suppliers, third party service providers, advertisers and business partners, which may be located outside Hong Kong. By using our site and providing us with your Personal Data, you agree to this transfer, storage or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this statement. However, any Personal Data transferred to our advertisers and business partners will be outside our control and will be subject to their own privacy policies.
The Personal Data we collect is currently processed by our parent company, The Motley Fool, LLC (“TMF US”), in the United States of America and some of this data is stored in the US.
D. Disclosure of Personal Data
We will not give, rent, lend or sell your Personal Data to any third party. Furthermore, we will not disclose any Personal Data of any individual users, except as described below (which may involve transfer of your Personal Data outside of Hong Kong).
- On the TMF website:You may be publicly identified by your user or screen name on our website. If you choose your full name as your username, you have voluntarily disclosed that information to our community. The same is true for any personal identifiable information (such as an email address) you include in any article comment.
- TMF US:As previously mentioned, all Personal Data we collect from our users is processed and stored by TMF US. Also, since TMF US handles the distribution of some of our emails for us, we may provide our users’ email addresses to TMF US for the purpose of delivering these publications. Unless you have registered with TMF US or have otherwise provided them with your email address, they will not be contacting you or otherwise using your email address for any TMF US-related purposes.
- Third party service providers:We may engage third party service providers to aid us in certain aspects of our operations, such as the distribution of our email products, conducting a survey for us, or processing of credit card transactions. Depending on the services performed, it may be necessary to provide these services providers certain Personal Data of our users. These service providers would be subject to confidentiality agreements which limit their use and disclosure of all information they obtain through their relationship with TMF to TMF-related business only, consistent with this statement.
- Legal or regulatory obligation:We may disclose your Personal Data to any legal, regulatory, governmental, tax, law enforcement or other authorities as well as self-regulatory and industry bodies to comply with requirements and obligations on us, TMF US and/or associated company under any law, regulation or court order, or under and for the purposes of complying with any guidelines issued by regulatory or other authorities.
Cookies contain bits of data that websites such as ours place on your web browser or device for record keeping purposes. Cookies can make the web more useful by storing information about your preferences on a particular site and help websites operate more efficiently.
We log certain information (which may include Personal Data) using cookies when you use our website. We also have several partners who set cookies on our pages. These partners include companies that help us better understand how to serve you, companies that serve our house ads, power the tools on our site, and companies that require cookies for their social applications to work.
We (and our partners) use the following cookies (adopting the categories and definitions set by the International Chamber of Commerce) and for the following purposes:
a) Strictly Necessary cookies: cookies that help us to temporarily identify your device after you have logged in so that you can access certain contents on our website, and to allow you to carry information between pages of our website without having to re-enter that information. These cookies enable us to provide you with the services that you have ordered or paid for;
b) Performance cookies: cookies that collect information on how visitors use our site including the pages visited and most frequented as well as the sources of our traffic. These cookies are used to help us improve how the site works, to estimate our audience size and determine usage patterns;
c) Functionality cookies: cookies that help us remember the choices you have made when using our website (e.g. layout, font size, colours etc.) so we can provide you with a more personalised experience; and
d) Advertising cookies: cookies that may be used to deliver more relevant ads, to limit the number times a user sees a particular ad on a website and to measure the effectiveness of a particular campaign.
Most browsers are initially set to accept cookies, but you have the option of disabling cookies by changing the setting on your browser. If you reject our cookies, you may not be able to use most features on our site, including all of our subscription-based services.
Other usage data
While on our website, your usage data may also be tracked using other tracking technologies similar to cookies.
We may place a pixel on pages on our site, or those of our advertisers and partners. This enables us to record in our server logs that a specific user id has visited a particular page. This data allows us to analyse and determine our audience’s behavioural characteristics, which helps us to optimise our site, advertisement placement, and marketing focus.
Tracking technologies used by third parties
We may also allow certain third parties (listed below) to collect certain information when you visit our site. They may utilise cookies (see above), pixels, beacons, or other technologies to collect and use information (e.g. hashed data, click stream information, browser type, operating system, date and time, subject of advertisements scrolled over) during your visit to this and other websites in order to help us analyse the use of our website or to provide advertisements they feel you would like. Where cookies and similar tracking technologies are used by third parties to deliver and monitor their own ads, please note we neither control nor have access to those cookies or data so collected, and their uses, processing and retention of any such information are subject to their own privacy policies and not that of TMF.
- Google Analytics: Google Analytics is a web analysis service provided by Google to help us analyse the use of our website. Google Analytics sets cookies on our site. Only non-personally identifiable data will be transferred to Google Analytics, and the IP addresses transferred will be anonymized. If you would like to opt out of the collection of data by Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
F. Direct marketing
We would like to use your Personal Data for direct marketing of our products and services but we cannot so use your Personal Data without your consent (which includes an indication of no objection).
In this regard, if you consent by ticking the relevant box similar to the one below or otherwise by notifying us in writing, we may use from time to time such of your Personal Data (for example, your address, telephone number, email address and/or account usage) as agreed by you to promote and market the following services:
- Financial advisory, investment research and other related products and services.
After you have given us your consent, if you would like us to stop sending direct marketing to you, you may do so free of charge (i) by clicking on the unsubscribe link found at the bottom of our email messages, (ii) by email to firstname.lastname@example.org, or (iii) by post to our Personal Data Privacy Officer at 13th Floor, One Pacific Place, 88 Queensway, Hong Kong. We will then remove your name from our lists as soon as we can.
G. Links to third party websites
Our website may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
H. Your data privacy rights
Subject to PDPO, you may:
a) check whether we hold Personal Data about you and may request access to that information and to information about the ways in which we have used and disclosed that information;
b) require us to correct any inaccuracy in any of your Personal Data held by us;
c) request us to stop processing your Personal Data held by us; and/or
d) ascertain our policies and practices in relation to your Personal Data.
If you request access to or correction of Personal Data, we have the right under the PDPO to:
a) charge a reasonable fee for processing a data access request, in which case we will inform you of the fee amount and accepted payment methods; or
b) reject a request if there is a valid reason for such rejection, which we will tell you.
Requests for access or correction of Personal Data, request for us to stop processing your Personal Data, or for information regarding our data protection policies and practices, may be addressed to us as follows:
Personal Data Privacy Officer
The Motley Fool Hong Kong Limited
One Pacific Place
Last updated 18 July 2018