Data Privacy Policy Statement
Our Governance and Privacy Commitment
Union Registrars Limited ("Union Registrars," "we," or "us") recognizes that the responsible handling of personal data is a critical component of corporate governance and sustainability. We process the personal data of numerous individuals and take our stewardship role seriously. We are strictly committed to protecting your data against loss or misuse and complying with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong). This policy details how we collect, use, and safeguard your information, ensuring transparency in our operations.
Scope of Data Collection and Sources
"Personal data" refers to any information that identifies you or can be used to verify your identity. We collect this data through various channels to facilitate our share registration services. You may provide data directly when you contact us via email, phone, or submit forms online. Additionally, we may receive your data from third parties (such as the listed companies in which you invest) or public sources.
Important Note on Third-Party Data: If you provide us with personal data regarding other individuals—such as joint account holders, family members, or beneficiaries—you must confirm that you have obtained their express consent to share their details with us and that they are aware their data will be handled in accordance with this policy.
Purpose and Legal Basis for Processing
We process your personal data only where we have a valid legal basis, such as the necessity to perform a contract, compliance with legal obligations, or legitimate business interests. Specifically, we use your data to:
Service Provision: Maintain your shareholding account, process instructions (e.g., transfers, dividend payments), and validate your identity to prevent financial crime.
Communication: Respond to your queries, provide updates on policy changes, and distribute corporate communications from issuers.
Operational Improvement: Analyze website usage (via cookies) and service trends to enhance our efficiency and user experience.
Risk Management: Conduct due diligence, monitor IT security, and manage internal resources.
Information we collect for use in site management and security purposes includes:
- he internet domain from which you access our website
- The Internet Protocol (IP) address
- The type of browser
- The operating system
- The date and time you access our website
- The Universal Resource Locators (URLs) or addresses, of the pages your visit
- The URL of the referral site
- Your username, if it was used to log in to the website
We will never use your data for a new purpose unrelated to the original collection reason without your express consent. Furthermore, we strictly prohibit the sale of your personal data to any third party for unsolicited marketing purposes.
Disclosure and Data Sharing
To fulfill our service obligations, Union Registrars may need to share your data with trusted third parties. These include the listed companies (Issuers) you are invested in, and service providers who assist our operations (such as printing houses, postage vendors, IT support, and payment processors). We may also share data with third-party screening services to perform "Know Your Customer" (KYC) and anti-money laundering checks. In all cases, we ensure adequate safeguards are in place. We may also be required to disclose data to regulators, auditors, law enforcement, or the courts to comply with legal requirements.
Data Retention and Cross-Border Transfer
We adhere to a strict retention policy, keeping your personal data only for as long as necessary to fulfill the purposes for which it was collected, or to satisfy legal, regulatory, or accounting requirements (e.g., maintaining statutory registers). Given the global nature of financial services and technology, your data may occasionally be processed or stored outside Hong Kong (e.g., for cloud backup or system maintenance). In such instances, Union Registrars takes all reasonable steps to ensure the data is protected by standards comparable to those of the Hong Kong Personal Data (Privacy) Ordinance, regardless of where it is processed.
Your Rights and Control
Under the Ordinance, you retain specific rights regarding your personal data:
Access and Correction: You may request a copy of the data we hold about you and require us to correct any inaccuracies.
Withdrawal of Consent: You may withdraw consent for specific processing activities by providing written notice. However, please note that withdrawing consent may impact our ability to provide certain services to you (e.g., electronic notifications).
Erasure and Restriction: You may request that we erase or restrict the use of your data. We will comply unless there is a compelling legal reason to retain it (for example, statutory requirements under the Companies Ordinance to maintain shareholder records for a fixed period).
Contact and Complaints
If you have questions about this policy, wish to exercise your rights, or have a complaint regarding our handling of your data, please contact our Data Protection Officer. We are committed to resolving any issues promptly.
Address: Union Registrars Limited
- Suites 3301-04, 33/F., Two Chinachem Exchange Square,
- 338 King’s Road, North Point, Hong Kong
Telephone: (852) 2849 3399
Email: info@unionregistrars.com.hk
You also have the right to lodge a complaint directly with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.