Privacy Policy

This Privacy Policy (the “this Policy”) sets out how we and member(s) of Frontier Financial Group (together “FFG”) collect, use and handle your personal data provided to us, or which we have obtained from your visits to or use our websites, mobile applications(“APP”), social media platforms or our online services (collectively “Platforms”) or purchase or use any products, services, facilities (including loyalty or membership program) and/or other subjects of any member(s) of Emperor Group (collectively “Services”).

You shall read this Policy carefully before provision of your personal data or placing order for or using our Services or visiting our Platforms.

By using FFG Services, providing your personal data or accessing, browsing, using, subscribing or logging in our Platforms, you acknowledge that you have read this Policy and accept the terms herein.

Scope

FFG is dedicated to protecting your personal data and privacy in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong SAR) (the “Ordinance”) and all applicable laws and regulations.

Purposes of collection and use of personal data

FFG will only use your personal data for the specific purposes mentioned to you on or before collection and purposes directly related to such specific purposes. Most commonly, FFG may use your personal data for the following purposes or uses (without limitation):

for processing your order for FFG Services and delivery or provision of FFG Services to you;
for processing your payment for your order;
for improvement to FFG Services, Platforms and marketing;
for research and statistical analysis;
for sending you direct marketing if you have consented to it;
for compliance with laws, regulations and requirements, in or outside Hong Kong SAR;
for handling your enquiries/compliant;
for communicating with you; and
for such other purposes mentioned at the time of collection and/or specified in the applicable Personal Information Collection Statement (“PICS”) which is provided to you on or before collection of your personal data.

If FFG is wish to use your personal data for any new purposes, FFG will seek your prior consent before use.

The Platforms are not intended for minors and FFG does not knowingly collect any personal data from minors, except as part of dealings to provide minors with FFG Services, in such event, a parental/guardian’s consent may be required before submission of personal data under the applicable laws and regulations. The definition of minors shall be according to the law in the minor’s jurisdiction of residence (e.g. under the relevant privacy laws of PRC, a minor is under the age of 14 and under the Interpretation and General Clauses Ordinance (Cap.1) of HKSAR of PRC, children are under the age of 18).

Collection of Personal Data

When you interact with FFG, whether by using FFG Platforms, purchase or use of FFG Services or communicating with FFG, FFG may collect your personal data for the specific purposes as mentioned to you or specified in the PICS on or before our collection of your personal data.

FFG will not collect, process or use your sensitive personal data unless with your prior consent or otherwise permitted or required by applicable laws and regulations and the sensitive personal data are used for legitimate and necessary business purposes in accordance with the applicable law. Sensitive personal data includes religious beliefs, specific identities, healthcare, financial account and person’s race.

The provision of your personal data (including sensitive personal data) is voluntary and FFG will not collect or process your personal data (including sensitive personal information) without your consent unless permitted by applicable laws. However, if you do not consent to provide your personal data, FFG may not be able to provide Services as requested by you or fulfill your request in full or respond to your enquiries.

You should read the applicable PICS provided to you together with this Policy before provision of your personal data.

Retention of Personal Data

FFG will take all reasonably practicable steps to ensure that your personal data is not kept for a period longer than necessary for the fulfillment of the purposes for which FFG collected it, or for compliance with any legal, regulatory or reporting obligations or for assertion or defending against legal claims.

Disclosure and Transfer of Personal Data

FFG may disclose, transfer or share your personal data to third parties (whether locally or overseas) in the following circumstances:

service provider(s) and organisation(s) under a duty of confidentiality to FFG who provide administrative, data processing, data storage, collection of payment, IT supports, telecommunications, professional or other similar services to FFG;

third parties (including but not limited to co-branding partners that we partner with in connection with FFG Services and members of FFG) to whom the disclosure, transfer or sharing of your personal data is to fulfill or facilitate the fulfillment of the purpose(s) for which your personal data is collected;

those third parties as set out in the relevant PICS; and

governmental bodies or authorities (such as regulatory bodies, law enforcement bodies, government and tax authorities, etc.) as required or authorized by law.

Direct marketing

Subject to your prior consent, FFG may use or transfer your personal data for direct marketing purposes and sending you updates on latest news, offers and promotions in relation to FFG Services of any member(s) of FFG (whether partnering with co-branding partners and provider(s) or not) via the channel(s) as previously consented by you.

If you do not wish us to use your personal data for direct marketing, you may exercise your opt-out right by notifying our Data Protection Officer via the channels as set out in “How to contact us” section below.

Security of Data

FFG is committed to protect your personal data against unauthorized access, use, disclosure, processing, erasure or loss by taking all practicable measures. However, despite our effort to protect your Personal Data, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal data is limited to our relevant employees and contractors who have a need to know and are required to maintain the confidentiality of your personal data.

Third-party links

FFG Platforms may contain links to other websites, webpages, mobile applications or media platforms operated by other third parties (collectively the “Third Party Links”) which have their own privacy policies. FFG does not own and have no control over the content on these Third Party Links and shall not be deemed to endorse or recommend the content on these Third Party Links. FFG shall not be responsible for the content of these Third Party Links and your use of these Third Party Links shall be at your own risk. Before your visit these Third Party Links, you should read their privacy policy to understand the ways in which your personal data may be used by those third parties.

Your rights regarding your personal data

You have the right to ascertain whether we hold your personal data and access, update, correct and object to FFG use of your personal data held by FFG.

If you wish to exercise any of your rights above, please contact Data Protection Officer via the channels as set out in “How to contact us” section below.

To the extent permitted under applicable laws and regulations, FFG may charge a reasonable fee for the administrative costs incurred by us in processing and complying with your request above. FFG may refuse to handle or comply with any unreasonable requests as permitted by the applicable laws.

How to contact us

For all issues and enquiries regarding our privacy policy or use of your personal data, please contact our Data Protection Officer in writing by any of the following means:

Address: Units 3201-3203, 32/F, Bank of America Tower, 12 Harcourt Road, Central, Hong Kong

Email: cs@ffgwm.com

To enable us to handle your requests, we may ask you to provide your identity proof or any other necessary information for the verification of your identity. We reserve our right to amend and supplement this Policy from time to time without notice.