High-Flyer Capital Management (Hong Kong) Limited and its affiliates ("High-Flyer") values the security and privacy of your personal information. This Privacy Policy sets forth High-Flyer’s policies with respect to the collection, sharing, using, processing and disclosure of personal information in connection with this website. By visiting our website, you consent to these policies. If you do not consent to the terms below, please do not continue to use the website.
Personal Information We May Collect About You
When you access this website, we collect your IP address.
We may collect certain personal data about you if you contact us through an e-mail address listed on our website and submit such information. For example, we may collect your name, company name, address, city, state, country, postal code, e-mail address, phone number, fax number, and any other information you choose to provide to us in your subject line and message.
Certain users may access sections of our website that require entry of a username and password. We collect that username and password when you register and when you enter this information to access the non-publicly available section of our website.
We collect basic technical information from all visitors to our website, such as whether you have accessed the page before and the time of your last visit. This information may include cookies and other commonly used technologies (e.g. web beacons). Please see the section on Cookies below for further information.
How High-Flyer Uses Your Personal Information
High-Flyer considers your personal information to be confidential. If you submit your personal information to us via our website, we will use this information only to the extent necessary to respond to you and as discussed below.
It may be necessary for you to provide personal information where High-Flyer has a legitimate interest in carrying out various actions which may include the following:
- to contact you and respond to your inquiry or provide you access to specific information or offers;
- to support our relationship with you;
- to understand how we can improve our products and services;
- to personalize your visit to the website and to assist you while you use the website;
- to send marketing communications to you;
- to improve the website by helping us understand who uses the website; and
- to comply with applicable laws, regulations or codes of practice.
- Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing. This right to object is not absolute in all cases.
Sharing Your Personal Information
High-Flyer may, to the extent relevant to the purposes for which we collect your information, share your information with third parties including:
our affiliates or other entities that are part of our group or with our funds; any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with courts of law, governmental, regulatory or law enforcement agencies; our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators; service providers and trading counterparties to our funds or our affiliates, including placement agents or distributors, asset managers, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools; credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence; any person, as directed by you; or any person to whom we may or do transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets or assets of the funds we manage, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee. We may also use or disclose your information as permitted by law to collect debts, detect and prevent fraudulent activity, or protect the rights or property of High-Flyer, our clients and investors, our website, its users, or third parties, or when we otherwise believe in good faith that it is required by law.
Data Transfers
Given the global nature of High-Flyer’s activities, personal information collected from you, including via the website, may be transferred to, and processed by, recipients located outside the European Union (“EU”), including the U.S., which are not considered by the European Commission to provide an adequate level of data protection.
You hereby expressly consent to the transfer of your personal information to recipients (including High-Flyer), as described in this Privacy Policy, which are located outside of the EU. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
E-Mail Communications and Marketing
Occasionally, High-Flyer may send you e-mail communications with information that may be useful to you, including information about the products and services of High-Flyer. If you wish to stop receiving marketing or market research communications from High-Flyer, or would like to stop processing your personal information in any other way, you can contact High-Flyer as described below. However, if you are a customer or have a commercial relationship with High-Flyer, to ensure that you receive important information, you agree that High-Flyer may send you non-marketing related information when necessary. High-Flyer does not disclose, sell or otherwise market your personal information to third parties, unless it is required to do so by law.
Your Rights
If you are a resident of the EU, you have certain data subject rights in respect of the personal data we hold about you. These rights include:
- the right to request access to and rectification or erasure of your personal information;
- the right to obtain restriction of processing or to object to processing of their personal information;
- the right to withdraw consent where you have given consent to the processing of your data, to withdraw consent;
- the right to lodge a complaint about the processing of their personal information with their local data protection authority; and
- the right to portability of your information.
If you are based in the EU and would like to exercise one of the aforementioned rights, please send a request via email to: compliance@highflyercapital.com.
Links to Other Websites
High-Flyer’s website contains links to other websites. High-Flyer is not responsible for the privacy practices or the content of other websites. This Privacy Policy applies only to the information High-Flyer collects through its website. High-Flyer encourages you to read the privacy statements of all of the destination websites which you visit.
Security
High-Flyer uses various methods to protect your personal information against accidental or unlawful destruction, loss or alteration and unauthorized disclosure or access. Although High-Flyer exercises reasonable care and security, High-Flyer does not guarantee the protection of your personal information as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You use High-Flyer’s website and provide all such personal information at your own risk.
High-Flyer generally keeps personal information for as long as necessary to fulfil the purposes for which such personal information was collected, or for a longer period as required by law or where necessary for the purposes of its other legitimate interests. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether High-Flyer is subject to a legal, contractual or similar obligation to retain the data.
Cookies
Cookies are small text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org .
When you visit High-Flyer’s website, High-Flyer may place a cookie or other online tracking device in order to improve your experience by recognising you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies High-Flyer places may also collect information about your IP address, or click stream data within the website. This information helps High-Flyer improve the functionality of its website.
High-Flyer may also use cookies provided by Google Analytics to help measure how visitors use the website. The information collected is used for a variety of purposes, including, but not limited to, site traffic reporting, unique visitor counts, and content optimization. Although Google Analytics logs the information coming from the website on our behalf, High-Flyer controls how the data may and may not be used. If you do not want to help High-Flyer learn how to improve the website, you can opt-out of this website analysis tool by clicking: https://tools.google.com/dlpage/gaoptout .
Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.
Revisions to Our Privacy Policy
High-Flyer reserves the right to modify, alter or otherwise update this policy at any time. We will notify you of material changes to this privacy policy by posting the revised policy with the date it was revised on our website. We encourage you to periodically review this privacy statement to stay informed about how we are protecting the data we collect. In some cases we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you.
Questions and Comments
If you have any questions or comments about our Privacy Policy please contact us by email at compliance@highflyercapital.com or by writing to us at High-Flyer Capital Management (Hong Kong) Limited, 1-3 Pedder Street, Suite 1027, Central, Hong Kong.