Synergy (“we”, “us” and “our”) is committed to protecting the privacy, confidentiality and security of the personal data collected in compliance with the data protection principles and all relevant provisions under the Personal Data (Privacy) Ordinance (Cap. 486) (“Ordinance”). Synergy owes a strict duty of confidentiality to its investors and we are committed to protecting the security of your personal data. We are equally committed to ensuring that all our staff comply with strict internal standards of security and confidentiality to protect your personal data from unauthorised access, unlawful processing and against accidental loss, destruction or damage.
Personal Data collected from You
“Personal Data” has the meaning given to it under the Ordinance that applies to our processing of your personal information, which means any data relating directly or indirectly to a living individual; from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and in a form in which access to processing of the data is practicable. Personal Data may be collected from you through direct interactions with you (e.g. when you send us email or mail, or when you speak to members of Synergy) which may include contact information, such as name, e- mail and postal address. We may also collect Personal Data from you directly or indirectly from information or documents you provide to us in relation to your investments.
Synergy may use the Personal Data for the following purposes:
- to fulfil our contractual obligations (e.g. to open, manage or administer your account);
- to comply with legal and regulatory obligations (e.g. to perform KYC checks to comply with applicable anti-money laundering laws, or to prevent and detect financial crime); and
- to operate our business in a prudent manner in accordance with applicable laws and regulations, which may include responding to inquiries and requests, determining your eligibility for any of our products or services, etc.
Synergy will not provide your Personal Data to third parties for direct marketing or other unrelated purposes without your prior consent.
Use of Personal Data
Synergy is prohibited from disclosing to any third party the particulars of your identity, financial, business or personal affairs of, or any other information relating to you, a prospective investor, an investor or client, or any information that an individual passes on to Synergy in respect of its prospective investors, investors or its clients unless:
- you, a prospective investor, an investor, a client or the individual (as the case may be) has given prior written consent to the disclosure of the Personal Data;
- disclosure is necessary for the purpose of, or in connection with, any legal proceedings, for the purpose of obtaining legal advice, or is otherwise necessary for the purposes of establishing, exercising or defending our rights;
- disclosure is compelled by law enforcement authorities, regulators or other government agencies, for example to comply with anti-money laundering laws, or by regulatory requirement; or
- there is a public duty to disclose such information; or
- disclosure is to our affiliates and/or service providers who have been contracted to perform services.
We will retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, such as providing our services, or as required by applicable laws or regulations. This period may extend beyond the termination of our relationship with you.
Data Access and Correction
You are entitled under the Ordinance to seek access to, or seek to correct Personal Data which Synergy holds about you. Synergy may require that any persons requesting access or correction provide suitable identification to access any data. Requests for access and/or correction of Personal Data should be addressed to the following address: