Privacy Policy

This privacy policy sets out the manner in which Bennet Investment Limited (“Bennet Investment” or “we “or “us” or “our”) collects, uses and protects personal information and provides information about your privacy rights and the protections provided to you by law.

Personal Data means any information that identifies, or could reasonably be used to identify, a natural person, either on its own or together with other information.

Controller

Bennet Investment is the controller and is legally responsible for your Personal Data. We have appointed a data privacy manager who is responsible for monitoring issues relating to this privacy notice. If you have any queries regarding this privacy notice, including any requests to exercise your legal rights, please contact:

Head Office:
Far East Finance Centre,
16 Harcourt Road, Hong Kong
info@bennetinvestment.com

Data Security

Bennet Investment is committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information through the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk and we cannot accept any liability for the loss, theft or misuse of the personal information which you have registered on our website if there is a security breach.

Data collected by us

If you have had contact with us, for example through email, business cards or meeting one of our representatives, we may store limited amounts of personal information relating to you, such as your name, job title, employer organization and contact details.

We may also collect the following information:

• name and job title
• contact information including email address
• technical data and usage data
• demographic information such as postcode, preferences and interests
• marketing and communications data
• other information relevant to customer requirements

Purposes for which we gather information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

We mostly process Personal Data on the lawful basis of our legitimate interest (as described below) but in doing so we may not override your interests or fundamental rights and freedoms. We may also however process Personal Data where we have your consent to do so or where we need the personal information to perform a contract with you.

We require this information to operate and promote our business and understand your needs as well as to provide you with a better service, and in particular for the following reasons:

• for internal record keeping.
• for maintaining and recording of contacts
• for improving our products and services.
• for compliance with applicable laws and regulations

We may periodically send marketing and promotional emails about new products and services, recent transactions, business developments, market conditions or other information which we think you may find interesting using the email address which you have provided.

From time to time, we may also use your information to contact you for market research or to conduct surveys to improve or promote our services. We may contact you by email, phone, fax or mail.

We may also use the information to customize the website according to your interests.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Sharing of Data

We may transfer your data to group companies and affiliates, business partners, service providers who provide IT and system administration services and professional advisors including lawyers, bankers, financial advisors, auditors and insurers.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, as well as applicable legal requirements. For example, if you provide us with your information in connection with the FCA mandatory client onboarding, we must keep your information for up to five (5) years from the date of our last contact with you.

In any situation we will generally not keep your Personal Data for longer than 10 years.

Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

ou will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Cookie Policy

A cookie is a small file which asks permission to be placed on your computer’s hard drive. If you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may however prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to and from other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement but have their own privacy policies and we do not accept any responsibility or liability for these policies. You should exercise caution and look at the privacy statement applicable to the website in question.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Changes to this Privacy Policy

Bennet Investment may change this policy from time to time by updating this page. Please check this page from time to time to see any updates or any changes to our privacy policy. This policy is effective from 28th May 2022. By visiting www.bennetinvestment.com you are accepting and consenting to the practices described in this policy.