In accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (the “Ordinance”), this document sets out the Privacy Policy Statement and the Personal Information Collection Statement of GAM Hong Kong Limited. They govern the arrangements under which you provide personal data to GAM Hong Kong Limited, its affiliates and any other companies in the group of companies headed by GAM Holding AG (together, “GAM”).

GAM is committed to protecting and safeguarding the personal data of current, prospective and former clients in accordance with the provisions of the Ordinance.

Within GAM your personal data will be transmitted and stored in a protected environment. We will take all reasonable steps to ensure that your personal data will not be seen by any third parties other than those which GAM has engaged in order to provide services to you or to GAM. We will only disclose your data to other third parties if compelled to do so for legal or regulatory purposes. We will not supply any information about you to anyone unless we believe it is lawful to do so.

If you register with us on the GAM website (the “Site”) your registration data will be used to determine which funds and services are available to you in accordance with your professional status and place of residence. GAM does not collect personal data relating to you from the Site except when provided voluntarily by you.

GAM has various security provisions in place to ensure the privacy of your personal information. However, GAM accepts no responsibility or liability for the security of your data whilst in transit from you via the internet to us. If you prefer, you may choose another means to communicate with us, where you consider it appropriate.

The Site may include hyperlinks to other third party websites that are not operated or controlled by GAM. Once you leave our Site, GAM is not responsible for the content or the privacy practices of third party websites.

A cookie is a small text file that is sent to your computer, or other device, by the websites that you visit. They are widely used to monitor traffic to sites, and to enable certain functionality such as personalising websites to your interests or preferences.

To understand how GAM uses cookies and how you can alter your cookie settings please refer to the separate Cookies Notice.

Any personal data provided by you through the Site is provided voluntarily by you.

GAM may use the personal data which you provide for any one or more of the following purposes:

1. carrying out its everyday business activities and dealings with you;
2. subject to your right to exercise your opt-out, providing information on GAM products and services to you;
3. compiling statistical analysis of the pages of the Site visited;
4. monitoring and analysing its business;
5. developing other products and services; and
6. preventing crime, and any other legal and regulatory purposes to the extent required by any applicable law or regulation.

GAM will not request disclosure of sensitive personal data through this Site (such as data relating to your ethnic origin or religion) but if you choose to provide such data, GAM will assume that such data are provided by you voluntarily and can be used for the above purposes.

GAM will not transfer any personal data it collects about you to third parties except:

1. to the extent that it is required to do so by any applicable law or regulation;
2. to parties who provide services to GAM or to you or act as GAM's agents;
3. to any person to whom GAM transfers or proposes to transfer any of its rights or obligations under the Site terms of use;
4. to licensed credit reference agencies or other organisations that help GAM and others make credit decisions and reduce the incidence of fraud or in the course of carrying out identity, fraud prevention or credit control checks; or
5. at your request or otherwise with your consent.

Such data may be transferred to a place outside Hong Kong, and by accepting the terms of use of the Site, you consent to such transfer.

GAM will not sell, share, rent or otherwise disclose or transfer your personal information to others for monetary gains.

GAM may use your personal data in direct marketing and GAM requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

1. the name, contact details, products and services information, transaction pattern and behaviour, financial background and demographic data of a customer held by GAM from time to time may be used in direct marketing;
2. the following classes of services, products and subjects may be marketed to you: financial, investment, wealth management, and related products and services; and
3. GAM may send you investor education materials, investment alerts and invitations to events, tailored according to your personal data.

If you do not want GAM to use your data or transfer them to a third party for use in direct marketing, you may exercise your opt-out right by notifying the Data Protection Officer of GAM Hong Kong Limited.

In addition to one-to-one email messages from client managers or other contacts you have at GAM, you may also be subscribed to our centralised mailing lists. This will only happen upon receiving your written consent. You can unsubscribe from our mailings at any point. Every email has several options to unsubscribe at the end of the message. Alternatively, you can ask your GAM contact to remove you from specific mailings. If you are a client of GAM or invested in a GAM fund, you may receive fund reporting mailings (e.g. fund fact sheets, holding reports, risk reports, performance updates).

GAM may record or monitor telephone conversations and email correspondence between you and GAM to monitor the effectiveness of security arrangements, to enable compliance with applicable laws and regulations, and to maintain and improve the quality of GAM services.

GAM will only retain your personal information for as long as is needed to comply with any applicable laws and regulations.

In accordance with the terms of the Ordinance, you have the right to:

1. check whether GAM holds data about you, and access any such data;
2. require GAM to correct any data relating to you which are inaccurate;
3. ascertain GAM’s policies and practices in relation to data and to be informed of the kind of personal data held by GAM;
4. object to GAM’s use of your personal data for direct marketing purposes.

In accordance with the terms of the Ordinance, GAM has the right to charge a reasonable fee for the processing of any data access request.

If you do not wish your personal data to be used for direct marketing purposes, you may exercise your opt-out right at any time by writing to the Data Protection Officer. The Data Protection Officer is also the individual to whom requests for access to data, correction of inaccurate data, or for information about policies and practices and kinds of data held, should be addressed. Communication to the Data Protection Officer should be addressed to:

The Data Protection Officer
c/o Head of Legal & Compliance 
GAM Hong Kong Limited
Suite 2302
23/F, Lee Garden One
33 Hysan Avenue
Causeway Bay
Hong Kong

Please note that GAM reserves the right to amend this Privacy Policy at any time. Your continued use of this Site shall signify your agreement with and understanding of any additional or modified terms or conditions.