“Personal data” means data relating directly or indirectly to an individual from which it is practicable for the identify of the individual to be directly or indirectly ascertained.
Our Commitment to Privacy
What Information Do We Collect?
When you visit the Sapien Asset Management Web Site, we may collect two types of information from you: personal data you knowingly choose to disclose that is collected on an individual basis and the Sapien Asset Management Web Site use information collected on an aggregate basis as you and others browse the Sapien Asset Management Web Site.
1. Personal Information You Choose to Provide
In addition to providing the foregoing personal data to us, if you choose to correspond further with us through e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses. We provide the same protection for these electronic communications that we employ in the maintenance of information received by mail and telephone.
2. Sapien Asset Management Web Site Use Information
The Sapien Asset Management Web Site utilises Web server logs and will use a standard technology called “cookies” (see explanation below, “What Are Cookies?”) to recognize you and your access privileges on the Sapien Asset Management Web Site as well as to collect information about how the Sapien Asset Management Web Site is used. Information gathered by using cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at the Sapien Asset Management Web Site, and the Web Sites you visited immediately before and after the Sapien Asset Management Web Site. This information is collected on an aggregate basis. None of this information is associated with you as an individual.
We also log IP addresses, or the location of your computer on the Internet, for systems administration and troubleshooting purposes. We do not use IP address logs to track your session or your behaviour on the Sapien Asset Management Web Site.
How Do We Use the Information That You Provide to Us?
Broadly speaking, we use personal data for purposes of administering our business activities, providing customer service and making available other products and services to our customers and prospective customers. Occasionally, we may also use the personal data we collect to notify you about important changes to the Sapien Asset Management Web Site, new services and special offers we think you will find valuable. The lists used to send you product and service offers are developed and managed under our traditional corporate standards designed to safeguard the security and privacy of our customers’ personal data. You will be given the opportunity to notify us of your desire not to receive these offers.
The main purposes for which personal data may be used by us are:
Processing your application or registration for our services, enquiry or feedback
Incorporation into our user database
Provision of contacts and business details in response to enquiries and complaints
Processing billing and payment
Meeting requirements to make disclosure under any law applicable in or outside Hong Kong
Other related purposes
We may use your personal data both in and outside Hong Kong.
Disclosure to Third Parties
Personal data held by us will be kept confidential but we may provide such data to:
Banks and other financial institutions in connection with the collection of payments;
Any personnel, agent, adviser, auditor, contractor or service provider who provides services or advice to us in connection with our operations;
Any person under a duty of confidentiality to us;
Any person to whom we are required to make disclosure under any law applicable
Any actual or proposed transferee of our business or the Sapien Asset Management Web Site or any part of our business or Sapien Asset Management Web Site or participant in our operations.
Sharing Information with Sapien Asset Management Limited and the Group
Your personal data may be disclosed to and used by us or other companies controlled by, or under common control with, Sapien Asset Management Limited (the “Group”), for the purposes of direct marketing or the provision of customized information regarding the Group’s network of Internet and other products and services.
What Do We Do with the Information We Gather?
Statistical Analysis and Banner Advertising
We may perform statistical analyses of user behaviour in order to measure interest in the various areas of the Sapien Asset Management Web Site (for product development purposes) and to inform advertisers as to how many consumers have seen or “clicked” their advertising banners. We also use demographic and preference information to allow advertising banners on the Sapien Asset Management Web Site to be targeted, in aggregate, to the readers for whom they are most relevant. This means that readers see advertising that is most likely to interest them, and advertisers send their messages to people who are most likely to be receptive, improving both the viewer’s experience and the effectiveness of the advertisement. For these purposes, we will disclose information to third parties only in aggregate form.
What Are Cookies?
Cookies are a feature of Web browser software that allows Web servers to recognise the computer used to access a Web Site. They are small pieces of data that are stored by a user’s Web browser on the user’s hard drive. Cookies can remember what information a user accesses on one Web page to simplify subsequent interactions with that Web Site by the same user or to use the information to streamline the user’s transactions on related Web pages. This makes it easier for a user to move from Web page to Web page and to complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalised.
How Do We Use Information We Collect from Cookies?
We use Web Site browser software tools such as cookies and Web server logs to gather information about the Sapien Asset Management Web Site users’ browsing activities in order to constantly improve the Sapien Asset Management Web Site and better serve our customers. This information assists us to design and arrange our Web pages in the most user-friendly manner and to continually improve the Sapien Asset Management Web Site to better meet the needs of our customers and prospective customers.
Cookies help us collect important business and technical statistics. The information in the cookies lets us trace the paths followed by users of our Website as they move from one page to another. Web server logs allow us to count how many people visit the Sapien Asset Management Web Site and evaluate the Sapien Asset Management Web Site’s visitor capacity. We do not use these technologies to capture your individual e-mail address or any personally identifying data about you although they do permit us to send focused online banner advertisements and other such responses to you.
From time to time you may notice offers from outside companies advertised on the Sapien Asset Management Web Site. We endeavour to take measures to select product or service providers that are responsible and afford privacy protections to their customers. However, we do not make any representations about the practices and policies of these companies. You may opt-out of sharing your personal data with such affiliates by choosing not to use their service or content.
How Do We Share Information with Strategic Partners?
We may enter into strategic marketing alliances or partnerships with third parties who may be given access to personal information including your name, address, telephone number and e-mail for the purpose of providing you information regarding products and services that we think will be of interest to you. In connection with strategic marketing alliances or partnerships, we will retain all ownership rights to your personal data.
Notice of New Services and Changes
Occasionally, we may also use the information we collect to notify you about important changes to the Sapien Asset Management Web Site, and new services and special offers we think you will find valuable. As our client, you will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an offer or by sending us an e-mail request at info.
Personal data or e-mail that you send to us may not be secure unless we advise you that security measures will be in place prior to your transmitting the information.
How Do We Protect Your Personal Data?
We utilise encryption/security software to safeguard the confidentiality of personal data we collect from unauthorized access or disclosure and accidental loss, alteration or destruction.
Evaluation of Information Protection Practices
Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality and quality of our information. This policy may be updated from time to time so please check this statement periodically as it is your responsibility to make sure you are aware of our latest policies.
We may charge a reasonable fee for processing any data access request.
How Can You Access and Correct Your Information?
You may address data access or correction requests, and questions or complaints to:
Personal Data Privacy Officer
Sapien Asset Management Pty Ltd
Level 1, 23-25 O'Connell Street,
Sydney NSW 2000
Use of Personal Data in Legal Procedures
If it becomes necessary that we take legal action against you for any reason whatsoever including copyright infringement, you expressly agree that the personal data provided by you can be relied upon in identifying and taking action against you.
What About Legally Compelled Disclosure of Information?
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.
We retain personal data so long as the data is still required for the purposes mentioned above.
We reserve the right to retain copies indefinitely for our archives.
What About Other Web Sites Linked to the Sapien Asset Management Web Site?