SCIS data protection policy

This privacy policy describes the collection and use of your personal data made by Smart Capital International Solutions Limited as data controller, a limited liability company incorporated under Hong Kong law with Hong Kong company registration number 3326914 and registered office at Unit 1411, 14/Floor, Cosco Tower, 183 Queen’s Road Central, Sheung Wan, Hong Kong (hereinafter referred to as “SCIS”).

A. Which data does SCIS collect?

Personal data is any data which is provided to us or which we obtain that can be used to identify you (“you”) or that SCIS can link to you (“Personal Data”). SCIS will collect Personal Data about you, subject to applicable law, from a variety of sources as follows:

  • When you provide it to us (e.g. sending us emails, signing an agreement, filling forms, contacting us via telephone or visiting or making an enquiry through our websites, or by any other means).
  • In the ordinary course of our relationship with you (e.g. in the course of managing your transactions).
  • Where you apply for a job with us, we may collect from you and third parties (where relevant) additional Personal Data such as your CV and any references.
  • That you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
  • From third parties who provide it to us (e.g., your employer; our clients; credit reference agencies; law enforcement authorities; etc.).
  • When you visit any of our websites or use any features or resources available on or through a website.
  • When you visit a website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.

We believe that the responsible use of Personal Data collected is critical to our business objectives and reputation. As part of our commitment to privacy, we have adopted this Policy.

B. Use of personal data

We will process Personal Data in order to:

  • provide you with a personalised service;
  • provide you with information on market trends and opportunities;
  • to engage in marketing and business development activities and understand the effectiveness of our marketing;
  • verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage SCIS’s relationship with you;
  • to perform the contract with you: improve our services;
  • keep our site and systems safe and secure;
  • to carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management;
  • to comply with SCIS’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
  • understand our clients and their business objectives;
  • update and enhance client records;
  • defend against or exercise legal claims and investigate complaints; and inspection procedures.

C. Transfer of Data

As an international group we share information between our offices and your Personal Data is made available to them. Some of these offices are located outside the European Economic Area (EEA) and the laws in these countries may not provide the same level of protection as in countries within the EEA. However, all our offices at all times will ensure a level of data protection at least as protective as that required in the EEA. We may also instruct third party suppliers to perform services such as software support, e-marketing campaigns, hosting our website, etc. on our behalf. In such cases we take the necessary contractual steps to ensure the adequate protection of your Personal Data.

D. Your Rights

In accordance with the relevant provisions, you have the right to:

  • Confirm whether SCIS is processing Personal Data that concerns you, and access to the Personal Data SCIS holds about you.
  • Request the rectification of Personal Data.
  • Request the removal of Personal Data in certain circumstances (there may be cases where SCIS is legally entitled to retain it such as the defense against potential claims).
  • You can exercise your rights by contacting SCIS using the details set out in the “Our Contact Information” section below.

Your request will be analyzed and answered within one (1) month from receipt by us.

You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data.

E. Data Retentions

The Personal Data provided will be kept for the period determined by various criteria including: (i) legal obligation of conservation; (ii) term of the contractual relationship and service of any responsibilities derived from said relationship; and (iii) If and when applicable request of removal by the interested party.

F. Security

Keeping your Personal Data secure is of utmost importance to us. We take appropriate technical and organizational measures according to industry standards to keep your information secure and protect it from unauthorized use or damage, both online and offline. For security reasons we cannot disclose these measures in details.

G. Data Protection Officer Informations

For any doubts or queries about your personal data you may contact with the data protection officer of SCIS or by sending an email to SCIS’s data protection manager at the following address: dataprotection@scis.ltd