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                Personal Information and Privacy Protection Policy

                Issuance Date: 28 October 2021

                Effective Date: 28 October 2021

                Hang Seng Bank (China) Limited ("Hang Seng", "the Bank", "we" or "us"), with the register office 34/F, 36/F, Unit 45-031 45F & 46F, Hang Seng Bank Tower, 1000 Lujiazui Ring Road, Free Trade Zone, Shanghai, China, take personal information confidentiality and security very seriously, and strive at all times to protect our customers’ and related parties’ personal information and privacy when we provide our good services with you. We therefore formulate this Personal Information and Privacy Protection Policy (this “Policy”) to comply with the laws, regulations, rules and regulatory requirements.

                Important Notice: Please read through this Policy or any other agreement between you and us carefully when you apply for or use any product, service or device of the Bank, handle any business at the Bank or make any transaction with the Bank, sign any agreement, visit, browse, use any website, electronic business platform or mobile device application of the Bank, participate in any marketing events and surveys of the Bank, apply for any position at the Bank, or communicate or liaise with the bank through other methods. If there is any discrepancy between this Policy and the other agreements entered into or other terms and conditions agreed between you and us, such other agreements or terms and conditions shall prevail. You agree and understand the Bank may collect, store, use, process, transfer, provide, disclose, delete or use other methods to process your personal information.

                If you have any query, comment or suggestion, please contact us. You may contact us through below contact detail or “contact us” which is stated in our official website (www.cujad.com)or mobile device application.

                Please refer to below detail of Personal Information Protection

                http://www.cujad.com/1/2/contact-us-chi/email-us

                Hotline:400 830 8008

                This Policy include below content:

                I. Personal Information and Privacy Protection Policy Overview – How We Protect Your Personal Information

                II. How we collect your personal information

                III. How We Use Cookies and Other Technologies

                IV. Circumstances of use, disposal, disclosure and transfer of Information

                V. Your Rights of Personal Information

                VI. How we store and cross border transfer your Personal Information

                VII. How We Handle Minors' Personal Information

                VIII. Update of this Policy

                IX. Millenuous

                I. Personal Information and Privacy Protection Policy Overview – How We Protect Your Personal Information

                1. Overview

                To preserve the confidentiality, security and privacy of all personal information you provide to us, we follow the principle of reasonableness, legitimacy rightfulness and honest, and adopt below principle of public and transparent to protect and process your personal information:

                (1) We only collect personal information that we believe to be relevant and required for us to comply with law, perform a statutory responsibility or statutory obligation, understand your or relevant client’s needs, build up, review, maintain and develop our relationship with you or relevant clients, provide you with materials of relevant products and services.

                (2) We may for specific purposes provide your personal information to other members of the HSBC Group, our agents or other third parties, as permitted by law. We will obtain your consent to comply with the laws.

                (3) We will not transfer or provide your personal information to any third party, unless it is made to comply with law, perform a statutory responsibility, statutory obligation or perform the agreement, or in accordance with this Policy or other agreement between you and the Bank.

                (4) We may be required from time to time to disclose your personal information to our regulators, other governmental or judicial bodies or agencies, but we will only do so following the requirement of law, performance of statutory responsibility, requirement of regulator and government, performance of statutory obligation or agreement to the extent that we deem necessary.

                (5) We will not publicly disclose your personal information and we will obtain your separate consent and inform you the purpose, style and method of the personal information which is publicly disclosed.

                (6) We aim to keep your personal information on our records accurate and up-to-date. You can contact us to modify or supplement as per the contact detail stated in this Policy.

                (7) We maintain strict security systems and perform necessary inspection and filing procedure to comply with laws to prevent unauthorised access to your personal information by anyone.

                (8) All members of the HSBC Group, all our staff and all third parties with permitted access to your personal information are specifically required to take necessary measures to ensure the process of personal data is equivalent to the standard of personal information protection as stipulated in this Policy.

                By maintaining our commitment to these policies, we will ensure that we respect the inherent trust that you place in us.

                2. Information Security

                (1) Information security is our top priority. We will endeavor at all times to safeguard your personal information against unauthorised or accidental access, processing or erasure. We maintain this commitment to information security by implementing appropriate physical, electronic and managerial measures to secure your personal information.

                (2) We will strictly comply with the requirements of "Measures for the Administration of Electronic Banking" to keep the personal information provided by the users and customers of the Bank's website and e-banking confidential and store such personal information securely. To enable you to use the Bank's website and e-banking safely, we will provide the bank level information protection. The Bank's website will be accessed to by using encryption mode (such as HTTPs and TLS) and the transfer and encryption of the relevant data should be conducted under the Bank's security standard so as to satisfy the bank level security requirements.

                (3) We have a dedicated team for business management, technology support and security protection to operate and manage the Bank's website and e-banking services. The team has clear and specific responsibilities for information security and the team leader will ensure these responsibilities to be performed. In addition, the Bank also sets up a series of management mechanism for system access, data privacy and security safeguard.

                (4) The servers of the Bank's website and e-banking services are deployed in the unified data center of our Group. We effectively prevent network attacks by properly setting up and using the firewall and antivirus applications within a highly secured environment. In addition, we catch all abnormal status through real-time monitoring system, such as low disk space, IP attack etc., which will trigger system alerts to administer and security team by SMS and emails to ensure the fast response.

                (5) We exercise strict management over our staff members who may have access to your personal information, including but not limited to access control applied to different positions, contractual obligation of confidentiality agreed with relevant staff members, formulation and implementation of information security related policies and procedures, and related training offered to staff. When we use services provided by external service providers (entities or individuals), we also impose strict confidentiality obligations on them and request them to abide by our security standards when processing personal information.

                (6) For the security of your personal information, you take on the same responsibility as us. You shall keep your personal information secret and confidential, such as your account information, identity verification information (e.g. user name, password, dynamic password, verification code, etc.), and all the documents, materials, devices or other media that may contain or record or otherwise relate to such information, and shall ensure your personal information and relevant documents, materials, devices or other media are used only in a secured environment. You shall not, at any time, disclose to any other person or allow any other person to use such information and relevant documents, materials, devices or other media. Once you think your personal information and/or relevant documents, materials, devices or other media have been disclosed, lost or stolen and may so endanger the relation between you and the Bank or cause your bank account being used for any unauthorised transaction, you shall notify us immediately so that we may take appropriate measures to prevent further loss from occurring.

                (7) If unfortunately, personal information security incident occurs, we will adopt emergency plan and take relevant actions and remediation measures to mitigate the severity and losses in connection therewith. Meanwhile, we will report such personal information security incident and our actions in accordance with law and regulatory requirement.

                II. How we collect your personal information

                1.Personal information refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized. Personal information include name, birth date, ID certificate information (ID card, passport and etc.,), personal biometrics recognition, information, contact information, address, account information, property status, location and etc., Sensitive personal information refers to personal or property information that, once leaked or illegally provided or misused, may harm personal or property safety and will easily lead to infringement of the personal reputation, human dignity, physical or psychological health, or discriminatory treatment. Such information mainly includes ID certificate information (ID card, passport and etc.,), personal biometrics recognition, bank account, credit information, property information, transaction information, location, medical and health, biometrics recognition, specific identity, financial account, as well as any personal information of a minor under the age of 14.

                For the purpose of providing various products and services to you and related customers, contacting and communicating with you, establishing, reviewing, maintaining and developing business relationship with you or related customers in a fully informed manner, or complying with applicable laws and fulfilling statutory duties or purpose, we receive and store the personal information provided by you or voluntarily by a related party with your authorization during the process when you visit, browse or use any of our website, electronic business platform, mobile device application, apply or use any or our product, facility or service, perform any business or transact with us, participate in any of our marketing activity or respond to our questionnaire, apply for any our position, or otherwise contact or liaise with us by whatever means. We will inform you of the necessity for processing the sensitive personal information, its impact to the individual rights and interests, and separately obtain your consent in accordance with applicable laws and regulations before colleting your sensitive information.

                The personal information we collect may be recorded in paper, electronic means (for example, including but without limitation to the information we collect by way of automated machine, website, online banking, mobile banking or other mobile device application, email, text message, telephone banking or other channels) or any other means.

                2. In order for us to provide you with e-Banking services, you need to provide us or allow us to collect from you the following information necessary for the following purposes or functions. If you fail or refuse to provide the following personal information, we may not provide certain function of e-Banking services:

                (1)Registering e-Banking account:
                Your name, mobile phone number, ID type, ID number, bank card number and password, phone banking number, phone banking PIN;
                If you hold CAT II settlement account with us, you need to provide facial biometrics information to register your e-Banking account.
                (2)Logging on e-Banking account, retrieving logon username or password:
                Your ID type, ID number, e-Banking username, any logon password, second password, security password, code, dynamic password, verification code pre-set by you or created or sent via security device, mobile phone or other equipment or methods (collectively “password”), security questions and answers.
                (3)Maintaining proper and secure operation of e-Banking, preventing and controlling e-Banking related risks:

                De identification information such as your device type, operating system, unique device identifier, software version, International Mobile Equipment Identity (IMEI), logon IP/MAC address, internet service provider (ISP), device accelerators (such as gravity sensing devices). If the de identification information can not be used to identify your identity or retrieved to personal information, we will not treat it as your personal information. If the information alone or in combination with other information may be used to identify your identity, we will treat it as your personal information and have it properly protected.

                3. You may decide, at your free choice, to provide us with your personal information for the following functions. If you fail or refuse to provide the following information, you are not able to use the relevant functions,but your use of other functions of our e-Banking will not be adversely affected.

                (1)Transfer and Remittance
                To provide you with transfer and remittance service, we need to collect from you the name of payee, beneficiary bank account number and information of beneficiary bank.
                If you receive money by using “mobile phone number payment” function, you need to set mobile phone number receiving function, and we need to collect your registering mobile phone number, information of beneficiary bank, and to complete identity verification by SMS OTP.
                To provide you with overseas transfer and remittance service, we need to collect from you the payee’s name, information of beneficiary bank, beneficiary account number, country/region where beneficiary bank is located or transfer purpose.
                You need to provide passwords pre-set by you or created or sent via security device, mobile phone or other equipment or methods for the purpose of identity verification, approving and processing transaction requests or instructions. We will also collect the records of these transactions for your check or enquiry.
                We will collect your account information and payment and receiving details for the purpose of notifying you with your account balance update via SMS or APP Push Notification function.

                (2)Risk Profiling Questionnaire:
                Your age, financial status, income information, investment experience, investment preference and risk tolerance, planned investment products and tenor.
                (3)Purchasing and selling foreign currencies, foreign currencies exchanging, purchase of financial products such as deposit and mutual fund:
                Your name, mobile phone number, ID type, ID number, purpose of purchasing or selling foreign currencies, tax residence, taxpayer identification number.
                We will collect passwords pre-set by you or created or sent via security device, mobile phone or other equipment or methods for the purpose of identity verification, approving and processing requests or instructions for transactions. We will also collect the records of these transactions for your check or enquiry.

                (4)Financial Planning Questionnaire:
                Relevant information will be collected according to the family structure of your choice, such as year of birth, annual income (family or individual), total loan amount (family or individual), retirement age, post-retirement expenditure (family or individual), estimated education funds for children.
                (5)Insurance application:
                Your Name, Date of Birth, Gender, ID type, ID number, Tax Resident Identity and Account Information. According to different insurance products, further information will be collected including the information of the insured and policy holder, insured amount and ID Image.
                We will collect passwords pre-set by you or created or sent via security device, mobile phone or other equipment or methods for the purpose of identity verification, approving and processing requests or instructions for insurance transactions. We will also collect the electronic policies for your future enquiry.

                (6)Fingerprint or facial biometrics recognition functions:
                Your fingerprint and/or facial biometrics information. These information is used only for the purpose of verification of identity, logon or transaction instruction.
                (7)CAT II RMB settlement account:
                Photo of front side and back side of your ID certificate, ID information including your name, ID number, date of birth, beginning date of your ID, former name, country/region of birth. And your facial biometrics information would be used for verification of identity. Tax Resident Identity, place of birth, residential address, and the starting date of residence, mailing address, email address, binding CAT I account, the bank’s name of CAT I account, mobile phone number and phone banking PIN for verification of identity.
                Income, education, marital status, occupation, belonged industry, the name and scale of your company, your department, starting date in the current company, total work experience, phone number of the company. Urgent contact person’ information includes his name, relationship with the applicant and his mobile phone number. Your real estate, domicile, domicile address and the minor children.
                We may inquire your credit information and/or credit report with Basic Financial Credit Information Database and/or other credit reference agencies legally incorporated.

                (8)personal unsecured loan:
                Photo of front side and back side of your ID certificate, ID information including your name, ID number, date of birth, effective date and tenor of the certificate, and your facial biometrics information to verify the identity. Your former name, birth country/region, Tax Resident Identity, birthplace, residential address and starting date of residence, mailing address, email address, binded CAT I account number, bank’s name of CAT I account, occupation, belonged industry, the belonged company, income, education and marital status.
                (9)Update the certificate information:
                Photo of front side and back side of your ID certificate, ID information including your name, ID number, date of birth, effective date and tenor of the certificate, and your facial biometrics information to verify the identity. Mobile phone number and SMS OTP to verify your identity.
                (10)Update personal information
                Upon the updated information you provided, we will collect your residential information including residential country/region, residential address, beginning date of your residence, home phone number; mailing information including mailing country/region, address and postcode, job information including your profession, occupation, industry, company’s name and address, country/region you live in, income; and other information including marital status, education, and email address. We will also use your facial biometrics information, password sent by the security device or SMS OTP to verify your identity.
                (11)Update the information of CAT I account binded with CAT II account:
                Your name, CAT I account number, bank’s name of CAT I account, mobile phone number, you need to provide SMS OTP to verify your identity.
                (12)Finding branches nearby:
                Your geographic location information.
                (13)Account opening appointment:
                Your name, title, contact number, city you are living in.
                (14)Contact us:
                Your name, title, contact number, email address, city you are living in, details about what you enquire.

                4. In addition, our mobile banking applications may also invite your permissions for the following system functions relating to personal information and will collect and use the information for the permitted functions based on your permission:


                Items

                Permitted Functions

                Fingerprint logon

                Identity recognition, logon, and verification using fingerprint(s)

                Face ID

                Logon mobile banking via facial recognition on some types of Apple device

                Camera

                Facial recognition, ID identification, QR code payment and recognize other transaction instructions

                Photos

                Upload ID certificate photos and other pictures

                Location

                Improve the location accuracy of nearby branches, recognize and control transaction risk.


                For those functions that need your permission, you may, at your free choice, decide whether to additionally grant the permission for the said functions on mobile banking applications. If you refuse to grant permission for a specific function, you are not able to use that specific function,but your use of other functions in our mobile banking will not be adversely affected.
                For example, APP may support to cancel your previous function permission. You may choose to turn off relevant system permissions, setting path as below:
                For Android: Setting-Application-Permissions
                For Apple IOS: Setting-Privacy-Permissions-Application
                If you cancel the system permissions, we will no longer process relevant personal information. However, the above cancellation would not impact the processing of your personal information based on your previous system permissions.

                5. When you use our Mobile Banking Service, under certain particular scenarios, we will use the software service toolkit provided by third party (“SDK”). To provide the service to you, SDK will collect your information:

                Third Party SDK

                Scope and purpose of collection

                Gaode SDK

                To provide the location-based service, we use your access permission, IMEI number, latitude and longitude information, MAC address, running program.

                CibFintech SDK

                To quickly verify your identity by obtaining and recognizing your face feature and action to.

                Wechat SDK

                For sharing to wechat, but wechat will not collect your personal information

                AppDynamics SDK

                To analyze the performance of e-Banking, we will use AppDynamics SDK to obtain your mobile IP, mobile manufacturer, mobile type, network type,visit length information.

                Tealium SDK

                To do visit statistics survey and client behavior analysis, we use Tealium SDK to access to your mobile IP, mobile manufacturer, network type, browser type.


                If you refuse the listed SDK(s) to collect your information, you may not be able to access these services, but you or relevant party can still access to other functions or services on e-Banking.

                6.Subject to the scope allowed by applicable laws, we may collect and use your personal information without your consent under any of the following circumstances:
                (1) Where it is necessary for performing a statutory responsibility or statutory obligation;
                (2) Where it is directly required for cooperating with authorities to carry out public health activities,
                (3) Where it is necessary for protecting the life, health, property safety and other import legitimate rights and interests of you or other natural person(s) and it is difficult to acquire your personal consent ;
                (4) Where the personal information, which has already been disclosed to the social public by yourself;
                (5) Where the personal information is collected from the information which has been legally disclosed to the public, like news reporting, government published information and other legitimate channels;
                (6) Where it is necessary for the conclusion or performance of a contract to which the you are the contracting party;
                (7) Any other circumstance as provided by laws.

                7. In the case you are a connected person (which means any person with whom our entity customer has a relationship, including but not limited to, a director, supervisor or employee of a company, partners or members of a partnership, any shareholder, substantial owner, controlling person, or beneficial owner, trustee, settler or protector of a trust, account holder of a designated account, payee of a designated payment, representative, agent or nominee of the security provider for the relevant customer or applicant of our entity customer, or in the case you provide or propose to provide security (“Security”) for liabilities owed to use by our entity customer or relevant business applicant, we may collect following personal information from our entity customer or business applicant, for the purpose of providing banking products, services, and performing banking business to the relevant customer or business applicant, maintaining proper and secure operation of banking business and services, preventing and controlling related risks and provision of security. But we shall ensure such indirect collection of information is limited to the minimum level which is necessary for the related business. We will require the entity customer or business applicant to clarify the source of your personal information they provided, and assure the legitimacy of the information source. Meanwhile, we will learn from the entity customer or business applicant about the scope and purpose of your authorization to them. In the case that the processing of personal information required for our performance of business exceeds the scope of authorization that the entity customer or business applicant acquired from you, we will obtain your further consent for such procession.
                (1) Personal identity information, including name, gender, nationality, type/number/validity period of ID certificate, occupation, job position, relationship with relevant customers (such as employment/shareholding/investment relationship), telephone number, e-mail, contact information, birth date, place of birth, place of residence, work address, photo, any relationship with politically exposed person and relevant information etc.;
                (2) Personal property information, including personal income, real property, movable property (e.g. vehicle, financial assets, etc.), indebtedness, investment, tax-paid amount, tax residence, taxpayer identification number, amount paid for the provident fund, etc.;
                (3) Personal biometrics information, such as signature, handwriting, portrait, fingerprint, voice, face recognition information, etc.;
                (4) Personal account information, including account number, time of account opening, institution with which the account is opened, account balance, account transaction information, etc.;
                (5) Personal credit information, including credit card, loan and other credit transaction information, litigation and investigation information, penalty and any other information about personal credit status;
                (6) Personal information arising from customer investigation, e.g. personal information collected during customer due diligence, sanctions or anti-money laundering checks etc.;
                (7) Any other personal information acquired during the establishment or maintenance of business relationship for the performance of contracts or for compliance with laws and regulatory requirements, e.g. person information included in the customer documentation, personal information arising from any suspicious and unusual activity investigation, correspondence or other communication records(including video or audio records, call log and correspondence records and contents), device identifier and code, hardware type and serial number, operating system version, software version, IP address, network service provider etc.
                The aforementioned information is required for the Security, providing products or services to the relevant customer, fulfilling the agreement between you or relevant customer and us, and enabling us to perform our obligation under laws and regulations. If you refuse to provide such information (or the information you provided is incomplete, inaccurate or not real), we may not be able to provide the corresponding product, or service or perform the business for your or any relevant customer.
                8. Kindly understand that the services we provide will be continuously updated and developed. If you choose to use the service not covered by this Policy, and we need to collect your information based on the business, we will separately inform you of the matters in relation to the information collection on a real, accurate and complete basis and by means of reminder on the page, communication process or other means prescribed in the agreement, and acquire your consent for the information collection. We will also process your personal information in accordance with this Policy and applicable agreement (if any). If you choose not provide the information, you may unable to use certain or certain part of the services, but without prejudice to your rights to use other services we provided to you.

                III. How We Use Cookies and Other Technologies

                1.Your visit, browse, use of any website, electronic business platform or mobile device application of the Bank may be recorded for analysis on the number of visitors to the site and general usage patterns, helping you reduce the number and frequency of information entry or assisting determine the security status of your account. Some of this information will be gathered through the use of "Cookies". Cookies can enable us to provide safer and more useful features for website or application users. The information collected by "Cookies" is unidentified aggregated research data, and contains no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. Most browsers and/or applications are initially set to accept Cookies. You can manage or delete Cookies as per your preference. Should you wish to disable Cookies, you may do so by changing the setting on your browser and/or application. However, by disabling them, you may not be able to take full advantage of our website and/or application.

                2.The website and/or application may also work with third parties to research certain usage and other activities on the website and/or application. These third parties include without limitation to Adobe, etc. They use technologies such as "Cookies" etc. to collect information for such research. They use the information collected through such technologies (i) to find out more about users, including user demographics and behavior and usage patterns, (ii) for more accurate reporting and (iii) to improve the effectiveness of our marketing. They aggregate the information collected and then share it with us. No personally identifiable information about you is collected or shared by Adobe with us as a result of this research. Should you wish to disable the Cookies associated with these technologies, you may do so by changing the setting on your browser and/or application. However, after changing the setting you may not be able to enter certain part(s) of our website and/or application.

                IV. Circumstances of use, disposal, disclosure and transfer of Information

                1.How we use your personal information

                The information and data we collect might be used for one or multiple of the following purposes, as determined by the relationship between you and us: to realize the purposes and functions mentioned in above Article II of this Policy “How We Collect Your Personal Information”;
                (1)to contact you; and, to review and approve, process, and operate the business requests and transactional orders from you and other customer as related to you;
                (2)to comply with applicable laws and regulations (including any and all local and exterritorial legislation, law, regulation, act, rules, court decision, arbitration judgment, self-discipline rules, order, sanction, court order applicable to HSBC group member and any covenant between HSBC group member and authority, and agreement between authorities that is applicable to us or HSBC group member), or orders and requirements of any authority;
                (3)to perform our statutory duty or obligation, and perform related policy and procedures set up to perform such duty and obligation;
                (4)to maintain and improve E-banking business function, and develop new features (if any new feature will use your personal information for any other purpose and scope than you have agreed, we will seek your further consent before launching any of such use);
                (5)to investigate and prevent, as regulated by applicable laws, any current, potential or sceptical financial crime activities (including money laundering, terrorist financing, bribery and corruption, tax evasion, fraud, sanction evasion and/or any action or attempt to breach or evade applicable laws and regulations as related), and manage financial crime risk;
                (6)debit collection;
                (7)to obtain, verify and provide asset information and credit information for the purpose of assets review and credit review;
                (8)to exert or retain the right, and perform the obligation of ours and HSBC group members’, by agreement or by law, including without limitation, the performance of any contract between us and any current or potential assignee, partner, or dealer in any business or assets transaction.
                (9)to facilitate the internal operation of us or HSBC group (for purposes including credit and risk management, statistics, data analysis and process, system, service, product development and improvement, planning, insurance, audit and management governance);
                (10)communication with you to understand your needs, to create, review, maintain and develop the business relationship with you and with related customers based on sufficient mutual understanding, and review and process your job application to us;
                (11)to obtain and use third party goods and services such as management service, consulting, telecom service, payment service, data retention/processing and outsourcing services;
                (12)to introduce and demonstrate our services and products that might interest you, and improve our understanding on your interest in related services and products, to provide you with business massage and marking information that you may have interest in, market research and satisfaction feedback. If you would like not to receive any of such information or be involved in any of such activities, we provide instructions to help you refuse them. 。

                2.Entrusted Processing and Sharing

                (1) Unless otherwise agreed by you in express, we will not share with, publish or disclose any of your personal information to any third party other than HSBC group member. Only for legislative, reasonable, necessary and specific purpose will we provide related personal information of yours to a third party that we engage for delegated information disposal, in which case we will have binding contract with the third party on the purpose, term, methodology, information type, information security measures, etc., and monitor the third party activities as related to information disposal to make our personal information protection standards met. Further delegation will not be allowed by us before we have your prior consent.
                (2) For the purposes set out above in this Policy, we may provide or disclose all or part of your personal information to the following recipients provided that we or the recipients inform you of the name of recipient, contact information, purpose of disposal, the type of information that will be disposed and you grant specific consent to do so, and in case any of your personal information is to be disposed in any other methodology or for any other purpose, we will seek your further consent in advance (unless any of such specific consent is exempted by law):
                (a) a member of the HSBC Group (for instance, we may engage another HSBC group member to dispose your personal information so as to extend the availability of our service to you);
                (b) any contractor, subcontractor, agent, third party product or service provider, licensor, professional consultant, business partner, or associated person of the HSBC Group (including their employees, directors and officers) (for instance, we may provider telecom service provider with your mobile phone number, related marketing information or transactional information so that the telecom service provider could inform you of such information);
                (c) anyone acting on your behalf according to your authorisation or according to law, payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks (e.g. for CHAPS, BACS, SWIFT, CIPS and CNAPS), clearing houses, clearing or settlement systems, market counterparts, upstream withholding agents, swap or trade repositories, stock exchanges, companies in which you have an interest in securities (where such securities are held by us for you), or anyone making any payment to you;
                (d) any person or related party who has the right or obligation, acquires an interest or assumes risk, in or in connection with any product or service you receive from the Bank, or any business you handle at the Bank or any transaction you make with the Bank (for example, the person who provides or intends to provide any mortgage or other security for any of your debt to the Bank, or the beneficiary of the insurance product that the Bank distributes to you);
                (e) other financial institutions, industrial associations, bank card organizations, credit rating agencies, credit reference agencies (including without limitation, the People’s Bank of China’s credit information database) or information service providers (for instance, we may provide credit reference agencies with such information as related to your application for loans and performance of repayment, to facilitate objective reflection of your credit status);
                (f) any third party fund manager providing you with asset management services or insurance companies providing you with insurance services (for instance, we will provide your account information to finance institutes from which you have obtained assets management service or insurance service so as for the institutes to identify your payment);
                (g) any third party that provides us with referral, agency or intermediary service, or to whom we provide referral, agency or intermediary service;

                3.Transfer

                We will not transfer your personal information to any other company, organization or individual, except for the following,

                1) Where in compliance with applicable law, upon your request we will transfer in such manner that is available by us, to the recipient you designate;

                2) in the case of business/asset transfer, restructure, disposal (including securitization), merger, spin-off, acquisition transactions, dismissal or bankruptcy of us where the transfer of your personal information is necessary. Where any personal information is transferred, we will inform you of the name of recipient and request the recipient to comply with this Policy. Otherwise, they shall require the recipient to obtain separate consent from you.

                IV. Your Rights of Personal Information

                1.You have the right to request us to protect and secure your personal information in accordance with the provisions of the applicable laws and this Policy.

                2.When you use mobile device, you have the right to check with the Bank through the following method whether the Bank holds your personal information and to check, correct and update the personal information you have provided to the Bank, except as otherwise provided by applicable law:

                Please refer to below detail of Personal Information Protection

                http://www.cujad.com/1/2/contact-us-chi/email-us

                Hotline: 400 830 8008

                3.You have the right to check with the Bank for the Bank's policies on personal information and privacy protection. When you have any query about this Policy, you have the right to seek explanation/interpretation from the Bank to help you understand our practices regarding personal information and privacy protection and their possible consequence, and understand your rights and interests under this Policy in relation to personal information and privacy.
                4.You have the right and obligation to update your personal information at the Bank to ensure all information be accurate and up-to-date. You have the right to require the Bank to provide convenience for you to update your personal information at the Bank and to correct any of your information that is inaccurate.
                5.In relation to personal credit or guarantee, you have the right to request to be informed of your personal information that is disclosed to credit reference agencies by us, so as to enable your request to the relevant credit reference agencies for access to and correction of your information.
                6. We will only retain your personal information within the time limit necessary to achieve the purpose of our bank’s services and within the time limit allowed by applicable laws, regulations or separately agreed between our bank and you, unless otherwise required or allowed by the applicable laws. If one of the following occurs, we will delete your personal information on our own initiative or at your request, unless to comply with the requirements of applicable laws, archives, accounting, auditing and reporting, or to perform the other agreement between you and us, or to clean up the credit and debt relationship between you and us, or to provide information inquiry to you, regulators or other organs, or technically infeasible to delete your personal information:
                (1) the service purpose of the bank has been realized, cannot be achieved or no longer necessary;
                (2) the bank ceases to provide services, or the storage period has expired or exceed;
                (3) you withdraw your consent to us in accordance with the contact information stipulated in the Policy;
                (4) we violate laws or regulations or this Policy to deal with your personal information.
                7. When you use the mobile device applications provided by us, you have the right to uninstall the mobile device applications or stop using the mobile device applications to refuse us to further obtain your personal information. Please note that to uninstall the mobile device applications will not close your digital banking account. You have the right to close your digital banking account (by closing your bank account or disabling the digital banking functions of your bank account, for the sake of account safety you should visit our branches or sub-branches in person for such closure) and request for deletion of your personal information in accordance with the applicable law and regulation, this Policy, and other agreement between you and us. After you close your digital banking account, we will no longer collect your information through relevant channel, and will delete relevant personal information in accordance with the applicable law and regulation, this Policy, and other agreement between you and us, except for those we keep according to the applicable laws and regulations, regulatory, archival, accounting, auditing and reporting requirements, agreement between you and us, or for settlement of any indebtedness between you and us, or for record check or enquiry from you, regulators or other authorities, or those which are deleted difficultly subject to technology limitation.
                8.If you have any query, complaint, feedback, suggestion on this Policy or requests for access to, correction, deletion or withdrawal of personal information, please call 24-hour customer service hotline at 4008-30-8008 or visiting our official website www.cujad.com,“Contact US” on the HANG SENG China APP , our branches or sub-branches to raise your requests. Upon the receipt of your request, we will reply to you within 15 days but no more than 30 days at most or shorter period as prescribed by law and regulation (if any). Normally the Bank will not charge fees for the processing of your above-mentioned reasonable requests related to personal information. Nevertheless, for the frequently repeated and unreasonable requests, the Bank will charge certain fees as the case may be to the extent allowed by the law and regulation.
                Due to the requirements of law and regulation, we may not to be able to respond your requests under any of the following circumstances:
                (1) Where the request is in direct relation to personal information controller’s obligations under the law and regulations;
                (2) where the request is in direct relation to state security or national defense security;
                (3) where the request is in direct relation to public security, public sanitation, or major public benefits;
                (4) where the request is in direct relation to investigations into compliance, regulatory requirements, crimes, prosecutions, court trials, execution of rulings, etc.;
                (5) where there is sufficient evidence that you are intentionally malicious or abuses your rights;
                (6) where the purpose is to protect you or other individual’s life, property and other substantial legal interests but difficult to acquire your consent;
                (7) where responses to your request will give rise to serious damage to your or any other individual or organization’s legal rights and interests; and
                (8) where the request involves any trade secret.

                9.You may supervise or make suggestions for our practices regarding personal information and privacy protection, and lodge complaints or demand compensation according to law against us or our staff for any infringement of your rights and interests in your personal information and privacy.

                10.This Policy will not restrain your right to exercise other rights you are granted by laws and regulations as the subject of information.

                VI. How we store and cross border transfer your Personal Information

                1. In principle the personal information collected and produced within the territory of People's Bank of China (the “PRC”) will be stored in the unified data center of our Group.
                2. For cross border transaction purpose, subject to applicable laws and regulations, we will seek your separate consent and notify you of the data sharing/transferring, including the data receiver’s identity, contact information, purpose of processing, method of processing and the type of personal information (if cross-border transfer involved, we will also notify you the manner and method of exercise your right).
                3. We will take necessary measures to your personal information provided to offshore and request offshore recipient to abide by our personal information protection standard stipulated to comply with laws, regulations and this Policy.

                VII. How We Handle Minors' Personal Information

                1. Using our products and services by minors must be carried out under the supervision of their parents or guardians. We will abide by laws and regulations, this Policy and Provisions on the Cyber Protection of Personal Information of Children to give special protection to minor’s personal information. If you are a parent or guardian of a minor, when you have any questions about the information processing of the minor under your guardianship, please contact us through the contact method stipulated in this Policy.
                2. We understand the importance of protecting the minors' personal information with extra caution. If you are under 18 years old, it is suggested that your parents or guardians shall carefully read this Policy and you shall submit your personal information only after seeking consent from them. Meanwhile, it is suggested that your use of our product and service is conducted under the guidance of your parents or guardians. If they do not agree you to submit your personal information or to use any product or service of the Bank, you shall immediately stop submitting your information or using the product and service of the Bank. In addition, please notify such event to us as soon as possible, so as to allow us to take effective measures.
                3. If you are under 14 years old, you should and only obtain the consent of your parents or guardians to use any product or services of the bank or provide your personal information to the bank. We will process with personal information of minors in accordance with Provisions on the Cyber Protection of Personal Information of Children and with the permission of laws and regulations and the explicit consent of your parents or guardians. If we find ourselves are processing personal information of minors without the consent of verifiable parents or guardians, we will try to delete such personal information as soon as possible.

                VIII. Update of this Policy

                This Policy may be amended or updated from time to time. We will publish such changes at our website and/or relevant applications. You should keep an eye on relevant releases from time to time. We also will inform you of the contents of the publication by means of information push, short message and telephone notification as appropriate. And such amendments and updates will take effect from the expiration of the publication period and replace previous relevant contents. If you don’t agree to modify and update the content of this Policy, you should immediately stop using relevant products and services of the bank. If you continue to use relevant products and services, it will be deemed that you agree to accept the modification. Change of this Policy should not unreasonably reduce or restrict your rights as the personal information subject according to the applicable laws.

                IX. Millenuous

                1.If you provide the personal information of other third parties to our bank, we have the right to know the legitimacy of the source of the information and the scope and purpose of authorization of the third party to deal with personal information. If we need to process the personal information of the third party to carry out business beyond the scope of authorization of the third party, we will obtain the separate consent of the third party again. You should ensure that the third party is aware of this Policy and should specifically inform the third party how the Bank will process its personal information in accordance with this Policy. You may remind the person to read this Policy beforehand, or you may provide a copy of this Policy to the person.
                2.We may use indirect collection to obtain your personal information from third parties, but we will ensure that such indirect collection follows the principle of minimum quantity. We will ask the third party to explain the source of your personal information provided, and confirm the legitimacy of the source of your personal information, and we will check with the third party the scope and purpose it has obtained of your authorization for processing personal information. If the personal information processing activities we need to carry out for business are beyond the scope of your authorization to the third party, we will obtain your consent again.
                3. When you accept specific products or services provided by a third party through the products or services of our bank, you confirm that the products or services provided by the third party are operated independently by the third party. The third party shall independently assume full responsibility for the disputes arising from the handing of your personal information by the third party, and we will do our best to assist you in business. If a third party processes your personal information when providing you with products or services, you and the third party shall reach a separate agreement in according with applicable laws.
                4.The policy is subject to the Chinese version, and the English translation (if any) is for reference only.

                 
                 
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