Privacy Policy

Effective Date: January 2, 2019

This Privacy Policy governs the online information collection practices of Acumen Group, which shall include its branches, its subsidiaries and its affiliated companies, from time to time (together, “Acumen Group”, “we”, “us” or “our”) (“Acumen Group” “we” or “us”). Specifically, it outlines the types of information that we gather about you while you are using our website (the “Site”), and the ways in which we use this information.

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy.


How We Collect Information

We may collect, store and process personal or other information that you supply to us through your use of the Site. For example, individuals who contacted us with their information may be contacted to answer their inquiries. We collect personally identifying information from our users through the Site’s pages, and from time to time there may be other pages where information may be sought which will seek similar information.

We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect information about your computer’s connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site. The Site may also automatically recognize and store information about the type of browser you are using; your Internet Protocol (“IP”) address; the time, date, and length of your visit; and the referring site. We may also use a standard browser software feature called a “cookie,” in order to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help identify how many unique users visit us, track user trends and patterns, and may help deliver advertisements or other notices. They also may prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before. Cookies may not expire unless you manually delete them or set your browser to reject them. If you do not accept cookies, you may have difficulty navigating the Website, or the performance may not be the same. The Site also may use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open HTML-formatted email messages.

We collect, store and process personal or other information that you supply to us directly when you communicate with us by telephone, fax, letter, email or other forms of electronic communication, or when you provide us the application or other forms when you engage our services.

We also collect information from other sources, including other affiliated companies of our group, other publicly available sources such as social media and from third parties who provide it to us (e.g., your company, your intermediaries, your agents, advisers, custodians of your assets and law enforcement authorities).

Categories of Personal Data We Collect

Generally, this information may include:

  • Personal details: names, gender, date of birth, age, marital status;
  • Contact information: phone numbers, addresses, e-mail addresses, social media profile details;
  • Biographical information which may confirm your identity: government issued number(s), passport number(s), nationality, driving licence number(s), tax identification number(s), other government issued number(s), photographs and images of passports, signatures;
  • Electronic Identifying Data: IP addresses, cookies, activity logs, online identifiers, unique device identifiers; and geolocation data;
  • Employment details: industry; role; business activities; names of current and former employers; work address; work telephone number; work email address; and work-related social media profile details;
  • Education details and qualifications;
  • Financial details: billing address; bank account numbers; credit card numbers; cardholder or account holder name and details; instruction records; transaction details; and counterparty details, income, expenditure, assets and liabilities, sources of wealth;
  • Information about your family or personal circumstances, and interests, where relevant;
  • Information to assess whether you may represent a politically exposed person or money laundering risk


How We Use Information

We may use the information we collect from you in a variety of ways, including:

  • to provide services, information, assistance that you request from us;
  • to comply with our legal obligations, including but not limited to conducting verifications, monitoring and reporting in accordance with the Anti‐Money Laundering and Counter‐Terrorist Financing Ordinance, compliance with other applicable legal requirements and our internal compliance policies;
  • to customize features and advertising that may appear on the Site, to improve the delivery of our web pages to you and to measure traffic on the Site;
  • for the purposes of marketing, promotional activities, training and quality assurance.
  • for the purposes of administration and management of our business.


Disclosure of Personal Data

Acumen Group may share your information with or provide your information to the following parties for the purposes mentioned above:

  • other affiliated companies of our group;
  • third parties such as data processors, data storage providers or other service providers or advertisers in order to improve your experience with us, the Site,
  • third parties whom we engage to assist in delivering the services to you or to provide you with information about related products and services;
  • our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
  • your family, associates, representatives, agents, advisers and intermediaries who you tell us about;

Additionally, Acumen Group may disclose your information to the extent that such disclosure is required by law or regulation, governmental authorities, accreditation bodies, or to such an extent as we reasonably believe such disclosure is necessary to protect our legal interests. We reserve the right to cooperate with the authorities and to release such information to comply with necessary process.

The Site may also include links to other websites or provide access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third party products or services, use of any information you provide is governed by the privacy policy of the site you are visiting who is providing such products or services or collecting your information.

Use of Google Analytics

We may also use Google Analytics Advertiser Features (or other similar services) to optimize our business.

Advertiser features include:
Remarketing with Google Analytics;
Google Display Network Impression Reporting;
DoubleClick Platform Integrations; and
Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.


Location of Your Information

Your personal data may be processed by us in accordance with applicable law in Hong Kong.


Storage of Your Information

Your information is stored on Acumen Group’s servers that deliver our content and messaging, and is kept as long as such information remains potentially useful for the purposes it was collected, and not any longer. Your information can only be accessed by us and our affiliated companies. Our affiliated companies may also store such information.

 

Email Marketing and Opt-Out

You can remove yourself at any time from our marketing mailing list by sending email to us: info@acumen-hk.com.

Please note that changes to your email marketing preferences may not be effective immediately, and Acumen Group may be unable to prevent all commercial email contact from us or our affiliated companies. When contacting us regarding marketing opt-outs, you must include sufficient detail for us; at a minimum, your name, email and postal address.


Your Privacy Rights

You have the right to access, transport, update, rectify, or erase your personal data, as well as the right to object to or restrict its processing, transform it into anonymous form, or withdraw from any consent-based uses. These rights may be exercised by emailing Acumen Group. You also have a right to complain to your local data protection authorities if you believe your privacy rights related to your personal information have not been properly observed.

When contacting us regarding your rights, you must include sufficient detail for us to locate your file; at a minimum, your name, email and postal address.

We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice.

 

Updates to Privacy Policy

Acumen Group reserves the right to update and revise this Privacy Policy at its discretion. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date at the top of this page. Your use of our Website constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

If you have questions concerning this privacy policy, please email info@acumen-hk.com.