Privacy Policy | SGSL 

Privacy Policy



As a Client of Sun Growth Securities Limited and its associated companies (“Sun Growth Financial”), it is necessary from time to time for the Client to supply his/her personal data (“Personal Data”), within the meaning ascribed in the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Privacy Ordinance”), to Sun Growth Financial or Affiliates when opening or administering accounts, or in the establishment, continuation or provision of investment, dealing or related services.


Failure to supply Personal Data may result in Sun Growth Financial being unable to open or administer accounts or establish, continue or provide investment, dealing or related services.


Personal Data may also be collected in the ordinary course of continuation of the business relationship with Sun Growth Financial and/or Affiliates.

  1. Subject to the provisions of the Privacy Ordinance, you hereby consent to any Personal Data being used for any of the following purposes:
    1. the daily operation of the services provided to the Client;

    2. conducting credit checks;

    3. assisting other institutions to conduct credit checks;

    4. maintain credit history of the Client for present and future reference;

    5. ensuring ongoing credit worthiness of the Client;

    6. designing investment, dealing or related services or products for Client’s use;

    7. marketing investment, dealing or related services or products to Client (please see further details in Clause (10) below);

    8. supporting any statements made in any documents in connection with the services of Sun Growth Financial;

    9. determining the amount of indebtedness owed to or by the Client;

    10. collecting of amount outstanding from Client and those providing security for Client’s obligations;

    11. assisting other relevant parties, professionals, institutions or relevant regulatory authorities to verify certain facts in connection with the services of the Sun Growth Financial;

    12. meeting requirements to make disclosures under the requirements of any laws and/or regulations binding on Sun Growth Financial; and

    13. any other purposes relating to or incidental to any of the above.

Sun Growth Financial shall keep Personal Data confidential but Sun Growth Financial may be required to provide Personal Data to the following persons in furtherance of the purposes set out in Clause (4) above, to which you hereby consent:
  1. any officer, employee, agent or third-party service provider who provides services to Sun Growth Financial in connection with the operation of its business;

  2. an appropriate person under a duty of confidentiality to Sun Growth Financial including any Affiliate which has undertaken to keep such information confidential;

  3. any person or institution with which the Client has or proposes to have dealings;

  4. credit reference agencies and debt collection agencies (in the event of default payment);

  5. any regulatory authorities or exchanges which relate to or govern any business of Sun Growth Financial and any Affiliate;

  6. any assignee, transferee, delegate, successor or person to whom the account of the Client is transferred and the authorized person of the Client; and

  7. any of Sun Growth Financial’s actual or proposed assignees, participants, sub-participants or transferees.


Personal Data may be transferred to any place outside of Hong Kong, whether for the processing, holding or use of such data outside Hong Kong, and also to service providers which offer services to any Affiliate in connection with the operation of its business.


To the extent permitted by law, Personal Data collected by Sun Growth Financial from time to time may be used and disclosed in accordance with this Data Privacy Policy.


In accordance with the terms of the Privacy Ordinance, any individual has the right to:

  1. check whether Sun Growth Financial holds data about him/her and access to such data;

  2. require Sun Growth Financial to correct any data relating to him/her which is inaccurate;

  3. ascertain Sun Growth Financial’s policies and practices in relation to data and be informed of the kind of personal data held by Sun Growth Financial; and

  4. in relation to customer credit, request to be informed which items of Personal Data are routinely disclosed to credit reference agencies or debt collection agencies, and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency.


In accordance with the Privacy Ordinance, Sun Growth Financial reserves the right to charge a reasonable fee for the processing of any data access request. All requests for access to data or correction of data (when the Client considers that his/her Personal Data, supplied by Sun Growth Financial following a data access request, is inaccurate) or for information regarding policies and practices and kinds of data held should be addressed as follows:

Data Protection Officer

Sun Growth Financial

Units 2901-05, 29/F, Infinitus Plaza,

199 Des Voeux Road Central, Sheung Wan, Hong Kong


    We intend to use your Personal Data in direct marketing and we require your consent (which includes an indication of no objection) before we can use your Personal Data for this purpose. Your provision for this purpose is voluntary. The specific requirement regarding your consent (which includes an indication of no objection) is introduced in Part VIA of the Personal Data (Privacy) Amendment Ordinance 2012. In this connection, please note that:

    1. your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by Sun Growth Financial from time to time (“Marketing Personal Data”) may be used by Sun Growth Financial in direct marketing.

    2. the following classes of services, products and subjects may be marketed:

      1. financial, insurance, securities, commodities, investment and related services and products and facilities;

      2. reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to in Clause (10)(b)(i) above;

      3. services and products offered by Sun Growth Financial’s co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be) in relation to the class of marketing subjects as referred to in Clause (10)(b)(i) above; and

      4. donations and contributions for charitable and/or non-profit marking purposes;

    3. the above services, products and subjects may be provided or (in the case of donations and contributions) solicited by Sun Growth Financial and/or:

      1. any Affiliate of Sun Growth Financial;

      2. third party financial institutions, insurers, securities, commodities and investment services providers;

      3. third party reward, loyalty, co-branding or privileges programme providers;

      4. co-branding partners of Sun Growth Financial (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be); and

      5. charitable or non-profit making organization;

    4. In addition to marketing the above services, products and subjects itself, Sun Growth Financial also intends to provide the Personal Data described in Clause (10)(a) above, whether such provision is for gain or not, to all or any of the persons described in Clause (10)(c) above for use by them in marketing those services, products and subjects described in Clause (10)(b) above (in respect of which Sun Growth Financial may or may not be remunerated), and Sun Growth Financial requires your written consent (which includes an indication of no objection) for those purposes;

    We may not use your Marketing Personal Data for direct marketing without your consent. Please indicate your consent when signing relevant customer documents.

    If you give your consent but subsequently change your mind and no longer wish Sun Growth Financial to use or provide to other persons your Marketing Personal Data for use in direct marketing as described above, you may exercise your opt-out right by notifying Sun Growth Financial in writing addressed to the Data Protection Officer in Clause (9) of this policy.

    Please note however that the right to make such a request is not applicable to you if the direct marketing is addressed to you in your capacity as a representative of a company or business and is not sent to you in your individual or personal capacity.