Privacy Policy
Updated: September 22, 2026
Effective: March 28, 2022
Westock Securities International (Hong Kong) Limited (“Westock Securities”, “we”, “us” or “our”) is committed to providing customers with the best financial services.
Protecting the security and privacy of customer data is a matter we have always taken seriously. Westock Securities has therefore established the following principles and is committed to keeping customer data and information confidential.
We respect and protect your personal privacy. When you browse the Westock Securities app and its sub-pages (the “Platform”) or use related services, we will collect, use and share your personal information in accordance with this Privacy Policy (the “Policy”).
The following sections help you understand in detail how we collect, use, store, transmit, share, transfer (if applicable) and protect personal information, and how we provide services for you to access, update, control and protect your information. Because this Policy is closely related to your use of our services, we recommend that you read and understand it carefully and make the choices you consider appropriate. By starting to use Westock Securities, you fully understand and agree to all contents of this Privacy Policy.
This Policy helps you understand the following:
1. How we collect and use your personal information
2. How we use Cookies and similar technologies
3. Information storage and information security
4. How we share, transfer and publicly disclose your personal information
5. How we protect your personal information
6. Account cancellation by the personal information subject
7. Your rights
8. How this Policy is updated
9. Relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance
Westock Securities understands the importance of personal information to you and will make every effort to protect the security and reliability of your personal information. We adhere to the following principles: accountability, clear purpose, choice and consent, minimum necessity, security assurance, subject participation, openness and transparency. At the same time, Westock Securities undertakes to adopt appropriate security measures in accordance with mature industry security standards to protect your personal information.
Please read and understand this Privacy Policy carefully before using our products or services.
1. How we collect and use your personal information
1.1 Personal information refers to various information recorded electronically or otherwise that can identify a specific natural person, either alone or in combination with other information, or reflect the activities of a specific natural person. Sources of such information include: information you provide to us through the Platform or other lawful channels; information you voluntarily make public; information disclosed through lawful public channels (such as lawful news reports or government information disclosure) or lawfully retained by third parties.
After you authorize us, we collect a unique device identifier. If you grant the corresponding permission, the app will first attempt to obtain the Android ID; if unavailable, it will combine hardware parameters such as motherboard, brand, CPU architecture, device name, manufacturer, device model and product name to generate a derived device identifier; if none of the above hardware information can be read, a unique device identifier will be generated locally. All identifiers are encrypted before being uploaded to the server. After you uninstall the app or clear local app data, the derived identifier and locally generated identifier will be reset.
We will use your personal information in the following scenarios:
(1) To use your personal information for the purposes of collection and use described in this Policy.
(2) To send you commercial electronic information and provide you with product information relevant to you. You may manage such information by clicking “Message Center” in the Westock Securities app. If you wish to receive notification services from Westock Securities, you need to authorize notifications in your phone settings. If you do not wish to receive push notifications, you may turn off notifications in your device system settings. After you turn them off, your phone’s system notification bar will not receive message reminders provided by the Platform. For example, we may push messages about specific products, activities or services based on your information. If you do not wish to receive push information, you may turn off push functions through device system permission settings or contact us to cancel the push service.
(3) If we need to use your personal information for other purposes not specified in this Policy, we will seek your consent again through confirmation agreements, on-screen confirmation in specific scenarios, or other means.
(4) Device identifiers are only used for account login management, device identification, account security risk control, anti-fraud, ensuring the security of securities business transactions, and product function optimization. Such information will not be used for marketing push without permission and will not be shared with unrelated third parties.
1.2 Westock Securities will collect and use your personal information only for the following purposes described in this Policy:
1.2.1 To fulfill anti-money laundering obligations, conduct real-name management, and comply with securities supervision, securities registration and settlement, exchange rules, investor protection, cybersecurity and other requirements under laws, regulations and regulatory provisions.
(1) When you open an account through Westock Securities or use the Platform’s services, you need to provide your identity information, contact details, address and linked third-party depository account information. If you fail to provide such information, you may not be able to open an account or enjoy related services. To verify the accuracy and completeness of such information, we will verify and check the information you provide against information lawfully retained by relevant institutions (including government agencies, public institutions and commercial institutions).
(2) If you are an individual user, in specific circumstances stipulated by anti-money laundering laws, regulations and regulatory provisions, you may need to provide us with color scans of valid identity documents for verification and retention. If you fail to provide such documents or materials, we may not be able to open an account for you or provide other services on the Platform.
1.2.2 Risk prevention
To prevent your funds, personal information and other important information or materials from being obtained by criminals, we need to collect the following information to assess the risk of your account. When you visit the Platform, we may record the service categories and methods you use and operation information during use, including the following permission-related information:
(1) Camera permission
1) Take photos of the front and back of your identity documents and upload them on the account opening page.
2) Take photos of bank account documents and upload them on the add bank card page.
3) Take photos of remittance vouchers and upload them on the deposit funds page.
(2) Photo album permission
1) Select and upload photos of the front and back of your identity documents from your phone album on the account opening page.
2) Select and upload bank account photos from your phone album on the add bank card page.
3) Select and upload remittance voucher photos from your phone album on the deposit funds page.
(3) Microphone permission: used to contact customer service on the online customer service page.
(4) SMS sending permission: Westock Securities needs to send SMS messages to verify user identity during registration and business handling.
(5) SMS receiving permission: when registering with a Westock Securities mobile number, we need to read the user’s verification code to facilitate user operations.
(6) Phone call permission: some pages displaying customer service phone numbers need phone call permission so users can dial directly.
(7) Storage permission: when handling business in Westock Securities, you may need to upload images or files containing personal identity information, which requires read storage permission. In addition, downloading necessary resource files, caching images and self-selected market data also require read storage permission.
(8) App self-update permission description
To ensure the security of the version you use, this app needs to apply for the following permission during self-update:
Permission name: Install unknown apps permission (REQUEST_INSTALL_PACKAGES)
Purpose: only used to complete overwrite installation after downloading a new version installation package; it will not be used to install other apps or for unrelated operations.
Data association: this process does not collect your device information or identity data; it only verifies the integrity of the installation package (such as SHA256 signature matching).
User control: you may turn off this permission at any time in system settings, but you will not be able to automatically update to the latest version.
(9) WiFi address: when you place a trade order on Westock Securities, the WiFi address will be used as evidence of your operation.
(10) App media file access permission description
10.1 Data use boundary description
1) We will only access the single file you explicitly select when you actively trigger a specific function.
2) We will not scan, read or collect other media files on your device.
3) We will not use obtained media files for any purpose not clearly disclosed.
4) We will not share your original media file data with any third party.
10.2 Photo permission (READ_MEDIA_IMAGES) description
We will apply for read photo permission when you use the following functions:
1) Profile settings: select photos from the album to set avatar and background.
2) Account security verification: upload identity document photos for account opening and identity verification.
3) Content creation: perform photo operations during dynamic publishing and editing, including saving and draft management.
4) Social sharing: generate share images, save content to the album, or share images.
5) App feedback: upload screenshots or photos to assist troubleshooting.
10.3 Video permission (READ_MEDIA_VIDEO) description
We will apply for read video permission when you use the following functions:
1) Security verification: upload short videos for liveness verification in advanced account verification to improve security and prevent fraud.
2) Problem feedback: attach screen recording videos when submitting technical issues to help the technical team accurately locate problems.
3) Media selection optimization: in content editing scenarios such as trade comments, to distinguish videos from images and improve selection experience, the app uses a custom media selector to access video files.
10.4 User rights protection
We solemnly promise:
1) All permission requests are triggered based on specific functions and follow the principle of minimum necessity.
2) We only access media files you explicitly select and never scan your entire media library; all media files will be deleted promptly after the specific purpose is completed.
3) You may manage or revoke permission authorization at any time through device settings; we will not refuse to provide core trading services because you refuse authorization.
4) All data processing activities comply with Google Play developer policy requirements and applicable data protection laws and regulations.
10.5 Supervision and responsibility
We promise:
We will never use media data for user profiling or personalized recommendations.
We will never use media data to train AI models.
If a data breach occurs, we will promptly notify you in accordance with the law and bear corresponding responsibilities.
(11) Notification permission is used to provide you with timely market news, announcements and transaction notification messages through third-party SDKs, as detailed below:
[Permissions and information required by TalkingData SDK]
We need to share your relevant personal information with this SDK for the following purposes, methods and scope:
1. READ_PHONE_STATE: allows the app to access mobile device information in read-only mode; the information obtained is used to uniquely identify users for app statistical analysis and cheat prevention.
2. ACCESS_WIFI_STATE: obtains the device MAC address, also used to identify unique users for app statistical analysis and cheat prevention.
3. WRITE_EXTERNAL_STORAGE: used to save device information and record logs.
To protect your information security, we have signed strict data security and confidentiality agreements with third-party SDK service providers, and these companies strictly comply with our data privacy and security requirements. To help you better understand the types and purposes of data collected by TalkingData and how it protects personal information, you may visit https://www.talkingdata.com/privacy.jsp to learn more about TalkingData’s personal information protection policy. We understand and respect your right to choose. If you do not wish to participate in TalkingData’s big data calculation, you may exercise your opt-out right at https://www.talkingdata.com/optout.jsp. You understand and agree that TalkingData has the right to de-identify and aggregate collected data to build databases for providing data services. If the purpose, method or scope of personal information collection and use by the TalkingData SDK changes, we will notify and remind end users to read it in an appropriate manner.
[Permissions and information required by Xiaomi SDK]
1. Message push service
To provide push services, send notifications about software updates or new product releases (including marketing information), evaluate advertising effects and for other purposes, you agree that we may temporarily store message content obtained from third-party applications.
We will also collect your device identifier information, including IMEI/OAID (applicable to Android Q and above), IMEI MD5/MEID MD5, Android ID, VAID, AAID, and your MID (applicable to MIUI). Your device model, network type, device storage, device running process information, app version, SDK version, and your country or region settings also help us provide better push services and experience. We will also use your settings information, including whether to block the notification bar and whether to set lock-screen pop-up messages, to provide services. We will also collect app information using the push service (package name, version number, app name, first installation time, last update completion time) to ensure that you no longer receive notifications related to the app after uninstalling it.
If you set up app cloning, we will also collect your Space ID to distinguish different apps. If you use a non-Xiaomi phone, we will also collect your carrier name to measure access quality and optimize push services.
Among the above user data, your IMEI, network type, carrier name and device running process information will only be read locally and will not be uploaded.
2. We may associate information collected from your various devices so that we can provide consistent services across these devices. We will use this information to analyze and develop statistics related to the use of our products or services, so as to better improve our products or services.
[Permissions and information required by Alibaba Cloud SDK]
Permission business purposes:
ACCESS_NETWORK_STATE, ACCESS_WIFI_STATE, ACCESS_FINE_LOCATION, READ_PHONE_STATE: used to determine network status, enable and disable push functions, distinguish different networks, cache push connection parameters, and use different push connections.
INTERNET: used to connect to push services and provide push functions.
WAKE_LOCK: used to maintain the stability of push channels on low-end phones and improve the timeliness of push messages.
RECEIVE_BOOT_COMPLETED: used to maintain the stability of push channels after phone restart and improve the timeliness of push messages.
READ_EXTERNAL_STORAGE, WRITE_EXTERNAL_STORAGE: used to store the unique identifier of the push channel and improve push accuracy.
GET_TASKS, REORDER_TASKS: used for push opening method—open app function, to avoid opening the app multiple times.
[Permissions and information required by Huawei SDK]
Huawei Push Service will collect the following information:
Your ID, app ID, app package name, and server public IP address. In addition, if you enable receipt rights, receipt certificate and receipt address URL information will be collected; if you enable iOS rights, iOS certificate information will be collected; if you enable WebPush rights, key pair information corresponding to WebPush will be collected; the above information will be stored simultaneously on servers in Singapore, Russia and China.
If you create message push tasks on the AppGallery Connect website, information such as the usage frequency of Huawei Push functions, task names, message content and push scope (app Token, topic name, or audience group name) will be collected and processed according to the data processing location you select; however, if you do not select a data processing location, you will not be able to create message push tasks on the AppGallery Connect website.
In addition, Huawei Push will collect the following information from your end users:
AAID (anonymous application identifier), app Token, and Topic subscription relationship. If you select a data processing location, the data will be processed according to your selected location; otherwise the above information will not be processed.
Message delivery records, Token application records, and display/click/close tracking report records require you to enable Huawei Analytics and select a data processing location before data processing; otherwise no data processing will be performed.
Cached message content will be processed according to the region where the client is located.
If your app enables Huawei account-based message verification when pushing messages, we will collect the mobile user identifier HMS Core openId in that scenario; HMS Core openId will be irreversibly encrypted and stored only on the device side.
The message content you send will be stored on the end user’s device side.
[NetEase Yunxin SDK]
Purpose: mainly to provide chat functions.
Types of personal information collected: may require access to your personal device information (Mac address/APNS Token/IMEI), phone status, storage permission, network access information, microphone permission, photo album and camera permission.
Collection method: automatically collected after you agree to the Privacy Policy, only during app startup, SDK initialization, and use of chat functions.
Privacy policy: http://yunxin.163.com/clauses?serviceType=3
[Tencent Bugly SDK]
Purpose: used for statistical analysis of program crash information.
Types of personal information collected: log information (including third-party developer custom logs, Logcat logs and app crash stack information), device ID (including androidid and idfv), networking information, system name, system version and country code.
Collection method: automatically collected after you agree to the Privacy Policy, only during app startup, SDK initialization, and app crashes.
Privacy policy: https://bugly.qq.com/v2/contract
[Qiniu Cloud SDK]
Purpose: to provide object storage functions.
We collect your personal information, including registration information, real-name authentication, payment information, and other information (authentication information for specific identities); when using the service, we collect your device information, log information, location information and other information.
Collection method: automatically collected after you agree to the Privacy Policy, only during app startup, SDK initialization, and use of upload functions.
Privacy policy: https://www.qiniu.com/agreements/privacy-right
[NetEase Qiyu SDK]
Purpose: to provide IM message communication functions. We collect and send end users’ voice information, image and video information, end user information (device information, network information, log information), and distance sensor information.
Collection method: automatically collected after you agree to the Privacy Policy, only during app startup, SDK initialization, and use of online customer service functions.
Privacy policy: https://qi.163.com/termsService?catalog=1
[Third-party account login (WeChat Open Platform, QQ Connect, Sina Weibo Open Platform)]
Purpose: to implement third-party login and one-click quick login functions.
Types of personal information collected: after you authorize and consent, WeChat SDK, Sina Weibo login SDK and QQ login SDK may obtain personal device information (device version, system version, generated ID, phone style, phone name, iccid, bssid, MAC address, IMSI, IMEI), read/write external storage, WiFi permission, network status, phone status, and retrieve running apps, to ensure the normal use of corresponding functions.
1.2.3 Operations and security assurance
(1) Operations and security
We are committed to providing you with a safe and trustworthy product and usage environment. Providing high-quality, efficient and reliable services and information is our core goal.
(2) Device information and log information
a. To ensure the security of software services and your account, and the quality and efficiency of service operations, we collect your hardware model, operating system version, device name, device configuration, international mobile equipment identity, unique device identifier, MAC address, IP address, WLAN access point, Bluetooth, base station, software version, network access method, type, status, network quality data, operation, usage and service logs. We may associate your device information or phone number with your Westock Securities account.
b. To prevent malicious programs, ensure service security and improve browsing experience, we collect information about installed apps or running processes, overall app operation, usage and frequency, app crashes, overall installation and usage, performance data, and app sources.
c. To analyze statistical indicators such as app new additions, activations, retention and performance, we may call the clipboard for attribution analysis of relevant statistical information. Please rest assured that we will not collect your private information.
d. We may use your account information, device information, service log information, and information shared by our affiliates and partners with your authorization or in accordance with law to determine account security, app startup activity, conduct identity verification, and detect and prevent security incidents.
e. In silent running state, to accurately push relevant information and analyze app statistical indicators and operation status, we may use your device information, service log information, and information shared by our affiliates and partners (third parties) with your authorization or in accordance with law to determine account security and accuracy, conduct identity verification, and detect and prevent security incidents.
(3) Changes in purposes of collecting and using personal information
Please understand that as our business develops, we may adjust existing functions and services. In principle, when new functions or services are related to our current functions or services, the personal information collected and used will have a direct or reasonable connection with the original processing purpose. In scenarios not directly or reasonably related to the original processing purpose, we will again inform you and obtain your consent in accordance with laws, regulations and national standards through page prompts, interactive processes or agreement confirmation.
1.2.4 Providing personalized services and improving service quality
To improve service quality, prevent risks, enhance your service experience, or recommend better or more suitable services to you, we collect your search records when using the Platform, information you provide when contacting our customer service team, questionnaire responses you send to us, service categories and methods you use, and operation information during use. We also collect behavior information and transaction information lawfully retained by our affiliates and partners. We will statistically analyze such information to provide you with more accurate, personalized, smooth and convenient services. To improve processing efficiency, reduce processing costs and improve processing accuracy, we may entrust capable affiliates to provide such services, and we will require such companies to comply with strict confidentiality obligations and prohibit them from using such information for purposes not authorized by you.
1.2.5 Providing service status notifications and inquiry services
Subject to applicable laws, regulations and regulatory provisions, to facilitate your inquiry of transaction status or historical records, we will archive your identity information, transaction information and behavior information when you use the Platform, and properly keep such information in strict accordance with laws and regulations. To let you know the status of using the Platform’s services, we will send service status notifications based on relevant information.
1.2.6 Other circumstances
Within the scope permitted by laws and regulations, we may collect and use your personal information without obtaining your authorization or consent in any of the following circumstances:
(1) directly related to national security or national defense security;
(2) directly related to public security, public health or major public interests;
(3) directly related to criminal investigation, prosecution, trial and judgment execution;
(4) necessary to protect the life, property or other major lawful rights and interests of the personal information subject or other individuals, but it is difficult to obtain the individual’s consent;
(5) the personal information collected is voluntarily made public by the personal information subject;
(6) personal information is collected from legally publicly disclosed information, such as lawful news reports or government information disclosure;
(7) necessary for signing and performing a contract at the request of the personal information subject;
(8) necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;
(9) necessary for a news unit as the personal information controller to carry out lawful news reporting;
(10) necessary for an academic research institution as the personal information controller to carry out statistics or academic research in the public interest, and when providing academic research or descriptive results externally, the personal information contained in the results is de-identified;
(11) other circumstances stipulated by laws and regulations.
2. How we use Cookies and similar technologies
2.1 Cookies and device information identifiers and similar technologies are commonly used on the Internet. To ensure the normal operation of the website, we store small data files called Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With Cookies, websites can store your preferences and other data.
(1) Ensuring safe and efficient operation of products and services
We may set authentication and security Cookies or anonymous identifiers to confirm whether you safely log in to services or encounter theft, fraud or other illegal acts. These technologies also help us improve service efficiency and speed up login and response.
(2) Helping you obtain a more relaxed access experience
Such technologies can help you avoid repeatedly filling in personal information and entering search content.
2.2 Clearing Cookies
We will not use Cookies for any purpose other than those described in this Policy. You may manage or delete Cookies according to your preferences. You can clear all Cookies saved on your computer; most web browsers have functions to block Cookies. However, if you do so, you will need to change user settings each time you visit our website. For details on how to change browser settings, you can search the Internet for operating methods for different browsers.
3. Information storage and information security
3.1 Storage
Personal information we collect and generate within the People’s Republic of China will be stored within the People’s Republic of China. We will store your personal information in accordance with the storage periods stipulated by laws, regulations and regulatory authorities. After you cancel your account, we will stop providing products and services to you and delete or anonymize your personal information at your request, unless otherwise stipulated by laws, regulations or regulatory authorities. If we cease operations, we will immediately stop collecting your personal information, notify you of the cessation by individual delivery, announcement or other means, and delete or anonymize the personal information we hold.
3.2 Information security
(1) To protect your information security, after collecting your information we will take various reasonable and necessary measures to protect it. For example, in technical development environments, we only use de-identified information for statistical analysis; when providing external research reports, we de-identify the information contained in the reports. We store de-identified information separately from information that can be used to restore personal identification, ensuring that individuals are not re-identified in subsequent processing of de-identified information.
(2) To protect your information security, we are committed to using various security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, accessed without authorization, disclosed without authorization or altered. For example, we use Secure Sockets Layer (SSL) software for encrypted transmission, encrypted information storage, and strictly restrict access to data centers. When transmitting and storing sensitive personal information (including personal biometric information), we use encryption, permission control and de-identification measures.
(3) We have designated responsible personnel for personal information protection and conduct personal information security impact assessments for collection, use, sharing and entrusted processing. We also apply the principle of minimum necessary authorization to staff who may access your information; we systematically monitor staff handling your information and continuously train them on relevant laws, regulations, privacy security guidelines and security awareness. In addition, our corresponding network systems have passed national cybersecurity classified protection assessments. We also regularly engage external third parties to evaluate our information security management system.
(4) If a personal information security incident unfortunately occurs, we will promptly inform you in accordance with laws and regulations by email, letter, phone or push notification of the basic situation, scope and impact, measures taken or to be taken, remedial measures, and suggestions for self-prevention and risk reduction. If it is difficult to inform each personal information subject individually due to special circumstances, we will issue an announcement in a reasonable and effective manner. At the same time, we will promptly and proactively report the progress and status of handling the information security incident to higher-level regulators.
(5) Please properly keep your Westock Securities app registered account, Westock Securities trading account and other related identity elements. When you use our services, we will identify you through your Westock Securities app registered account, Westock Securities trading account and other related identity elements. Once you disclose such information, you may suffer losses and adverse legal consequences. If you discover that your login name and/or other identity elements may have been or have been disclosed, please contact us immediately so that we can take appropriate measures to avoid or reduce your losses.
4. How we share, transfer and publicly disclose your personal information
4.1 Sharing
We undertake to keep your information confidential. Except as otherwise provided in this Policy and laws and regulations, we will only share your information with Westock Securities affiliates, our suppliers or partners under any of the following circumstances. Our suppliers include institutions providing technical services, telecommunications services, customer services, risk control services, audit services and legal services. Our partners include financial institutions, e-commerce companies and platforms, offline merchants, etc. (suppliers and partners collectively, “third parties”).
(1) Sharing your information with third parties with your consent.
(2) Sharing your information as necessary to provide services you need or process related transactions.
(3) In sweepstakes, contests or similar promotional activities you participate in, using the information you provide to manage such activities. In such circumstances, if you win, we may publish your phone number or registered name in a desensitized form in the winner list or contest list. If the activity is jointly promoted by us and a third party, we may share with that third party the personal information necessary to complete the activity (number of participants, winner list, winner contact details) so that the third party can promptly deliver prizes or provide services to you.
(4) Reasonable purposes necessary to comply with applicable laws, regulations and regulatory provisions, maintain public interests, and protect the personal and property safety or other lawful rights and interests of our customers.
(5) In accordance with legal provisions and reasonable business practices, when we plan to merge with another company, be acquired by it, or engage in other capital market activities (including but not limited to an IPO) and need to undergo due diligence by other entities, we may provide your information to necessary investigating entities. In such circumstances, we will require such investigating entities to take reasonable confidentiality measures for your personal information by signing confidentiality agreements with them.
(6) Where you authorize a third party to inquire about or collect your information on the Platform from us, we will share your information with the third party within the scope permitted by laws and regulations and authorized by you to the Platform.
4.2 Transfer
We will not transfer or provide your personal information to any company, organization or individual, except in the following circumstances:
(1) the transfer has obtained your explicit consent or authorization in advance;
(2) it is necessary to provide information to relevant departments, institutions or organizations in accordance with applicable laws, regulations, or mandatory administrative or judicial requirements;
(3) transfer due to merger, acquisition or bankruptcy liquidation. In such circumstances, we will require the new company or organization holding your personal information to continue to be bound by this Policy; otherwise we will require such company or organization to seek your authorization or consent again;
(4) transfer of de-identified personal information, ensuring that the data recipient cannot re-identify the personal information subject.
4.3 Public disclosure
Except for desensitized display of winners’ phone numbers, registered names or nicknames when announcing sweepstakes or contest winner lists, in principle we will not publicly disclose your information, unless you separately and explicitly agree.
5. How we protect your personal information
We undertake to bring information security protection to a reasonable level of security. To protect your information security, we are committed to using various security technologies and supporting management systems, such as SSL encrypted transmission, encrypted information storage, strictly restricted data center access, dedicated network channels and network proxies, to prevent your information from being leaked, damaged or lost.
Please understand that due to technical limitations and possible malicious means, in practice our protection of your information may still be uncertain due to factors beyond our control. The Internet is not an absolutely secure environment. Please use complex passwords and trusted network environments to help us protect your personal information.
If we cease operations, we will promptly stop collecting your personal information and delete or anonymize the personal information we hold.
6. Account cancellation by the personal information subject
You may cancel your previously registered trading account (fund account) at any time. After account cancellation, we will stop providing products or services to you and delete your personal information at your request, unless otherwise stipulated by laws, regulations, regulatory provisions or self-regulatory rules. Information you provide or generate during your use of Westock Securities services must still be retained for the period required by regulators, and during such retention period we will cooperate with relevant authorities’ inquiries in accordance with law. You have the right to cancel your account at any time. The specific process shall follow Westock Securities’ cancellation process or consult customer service.
7. Your rights
In accordance with relevant Chinese laws, regulations and standards, as well as common practices in other countries and regions, we protect your right to exercise the following rights over your personal information:
(1) Access your personal information
You have the right to access your personal information, except for exceptions stipulated by laws and regulations. If you wish to exercise your data access right, you may access it yourself in the following ways:
Account information—if you wish to access or edit your account profile and account information, change your password, or add security information, you may perform such operations through “Security Settings”.
Search information—you may access or clear your search history and view related data in the search bar.
(2) Correct your personal information
If you find that the personal information we process about you is incorrect, you have the right to request correction. You may contact our customer service at any time to respond to your request.
(3) Delete your personal information
You may request us to delete personal information in the following circumstances:
(1) if our processing of personal information violates laws and regulations;
(2) if we collect or use your personal information without your consent;
(3) if our processing of personal information violates our agreement with you;
(4) if you no longer use our products or services, or you cancel your account;
(5) if we no longer provide products or services to you.
If we decide to respond to your deletion request, we will also notify entities from which we obtained your personal information and require them to delete it promptly, unless otherwise provided by laws and regulations or such entities have obtained your independent authorization.
After you delete information from our services, we may not immediately delete corresponding information from backup systems, but we will delete such information when backups are updated.
(4) Change the scope of your authorization and consent
Each business function requires some basic personal information to be completed (see “Part 1” of this Policy). For the collection and use of additional personal information, you may give or withdraw your authorization and consent at any time. You may contact our official customer service hotline at any time. After you withdraw consent, we will no longer process the corresponding personal information. However, your withdrawal will not affect personal information processing carried out based on your prior authorization.
(5) Responding to your above requests
To ensure security, you may need to provide a written request or otherwise prove your identity. We may first ask you to verify your identity before processing your request.
For reasonable requests, we generally do not charge fees, but for repeated requests beyond a reasonable limit, we may charge a certain cost as appropriate. We may refuse requests that are unreasonably repetitive, require excessive technical means (for example, developing new systems or fundamentally changing current practices), pose risks to the lawful rights and interests of others, or are otherwise impractical.
In the following circumstances, we will be unable to respond to your request in accordance with laws and regulations:
(1) directly related to national security or national defense security;
(2) directly related to public security, public health or major public interests;
(3) directly related to criminal investigation, prosecution, trial and judgment execution;
(4) sufficient evidence shows that you have subjective malice or abuse rights;
(5) responding to your request would seriously damage the lawful rights and interests of you or other individuals or organizations;
(6) involving trade secrets.
8. How this Policy is updated
Our Privacy Policy may change. Without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. We will publish any changes to this Policy on this page.
For material changes, we will provide more prominent notice (including, for certain services, system announcements explaining the specific changes to the Privacy Policy).
Material changes referred to in this Policy include but are not limited to:
(1) major changes in our service model, such as changes in the purpose of processing personal information, types of personal information processed, and methods of using personal information;
(2) major changes in our ownership structure or organizational structure, such as owner changes caused by business adjustment, bankruptcy or merger;
(3) changes in the main objects of personal information sharing, transfer or public disclosure;
(4) major changes in your rights regarding personal information processing and how they are exercised;
(5) changes in the responsible department, contact methods and complaint channels for personal information security;
(6) when a personal information security impact assessment report indicates high risks.
9. Relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance
9.1 Customers in their individual names must provide personal data (“Data”) to Westock Securities from time to time for the purposes described in the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong). Customer data (and other data) may be used for the following purposes: daily operation of services and facilities provided to customers;
(1) conducting credit checks;
(2) assisting other institutions in conducting credit checks;
(3) ensuring customers maintain good credit;
(4) designing financial services or related products for customers;
(5) promoting financial services and related products to customers (for further details, please refer to Section 9.3 below);
(6) determining the amount of debts owed by or to customers;
(7) meeting disclosure requirements under any law or regulation;
(8) any purpose related to any of the foregoing.
9.2 Customer-related data (and other data) held by Westock Securities will be kept confidential, but Westock Securities may disclose all data (and other data) to the following persons, and customer consent to such disclosure is a condition for Westock Securities to provide services, products and data to customers:
(1) any senior officer, employee, agent, contractor or third party providing administrative, credit data, debt collection, telecommunications, computer, payment or other services relating to the business operations of Westock Securities;
(2) any financial institution with which the customer has or proposes to have transactions;
(3) regulatory or judicial authorities and other relevant government or statutory bodies;
(4) any other person under a duty of confidentiality to Westock Securities, including companies within Westock Securities that undertake to keep such information confidential;
(5) use of customer data among companies within Westock Securities must comply with strict internal security standards, confidentiality policies and applicable laws;
(6) we require employees to fully comply with such standards, policies and laws;
(7) we will not distribute customer-related data to other companies except for conducting business, complying with applicable laws, protecting against fraud, or making product and service offers that we believe may be in customers’ interests. We may also provide information to regulators and law enforcement officials in accordance with applicable laws;
(8) we have established very high standards to protect customer data from unauthorized alteration or destruction.
9.3 We intend to use your personal data for direct marketing, and we must obtain your consent (including an indication of no objection) for this purpose. Part VIA of the Personal Data (Privacy) (Amendment) Ordinance 2012 introduces specific requirements for obtaining your consent (including an indication of no objection). Please note:
(1) your name, contact details, product and service portfolio information, transaction patterns and behavior, financial background and statistical data held by Westock Securities from time to time may be used by Westock Securities for direct marketing;
(2) the following categories of services, products and promotional subjects may be promoted:
1) financial, insurance, securities, commodities, investment and related services and products, and credit;
2) reward, seniority or preferential programs relating to the promotional subjects described in Section 9.3(2)1) above;
3) services and products provided by Westock Securities’ associates relating to the promotional subjects described in Section 9.3(2)1) above (the names of such associates will be provided on the application forms for the relevant services and products, as the case may be);
4) donations and contributions for charitable and/or non-profit purposes;
The above services, products and promotional subjects may be provided by Westock Securities and/or the following persons or, in the case of donations and contributions, solicited by:
1) any member company of Westock Securities;
2) third-party financial institutions, insurers, securities, commodities and investment service providers;
3) third-party reward, seniority, associate or preferential program providers;
4) associates of Westock Securities (the names of such associates will be provided on the application forms for the relevant services and products, as the case may be);
5) charitable or non-profit organizations;
(3) in addition to promoting the above services, products and promotional subjects itself, Westock Securities also intends to provide the data described in Section 9.3(1) above to all or any of the persons described in Section 9.3(3) above for their use in promoting such services, products and promotional subjects (Westock Securities may or may not receive remuneration for this), and Westock Securities must obtain your written consent (including an indication of no objection) for this purpose;
(4) if you do not wish Westock Securities to use or provide your data to other persons for the above direct marketing purposes, you may send a written notice to Westock Securities through online consultation to exercise your right to opt out of direct marketing.
9.4 Westock Securities may conduct the following activities in accordance with the Personal Data (Privacy) Ordinance and other applicable laws:
(1) match, compare or exchange any data provided by or relating to customers with data (or other data) held by Westock Securities or any other person for the following purposes:
1) credit checks;
2) data (or other data) verification;
3) proposing or verifying data (or other data) that may be used to take action adverse to the customer or any other person at any time;
(2) transfer such data (or other data) to any place outside Hong Kong (whether such data is processed, held or used outside Hong Kong).
9.5 Under the terms of the Personal Data (Privacy) Ordinance, every customer has the right to:
(1) check whether Westock Securities holds customer-related data and whether it has the right to use such data;
(2) request Westock Securities to correct any inaccurate customer-related data;
(3) ascertain Westock Securities’ policies and practices regarding data and be informed of the types of personal data held by Westock Securities about customers.
9.6 Requests for access to and/or correction of any data submitted by customers should be sent to:
(1) Customer Service Department, Westock Securities, Room 9-10A, 10/F, Wing Tak Commercial Centre, 177-183 Wing Lok Street, Sheung Wan, Hong Kong;
(2) or call 852 3583 0090.
9.7 Under the terms of the Personal Data (Privacy) Ordinance, Westock Securities has the right to charge a reasonable fee for processing any data access request.
9.8 At Westock Securities, customer-related data will only be used for lawful purposes in conducting its own business and for product design and offers, thereby demonstrating that we understand customers and their needs.
9.9 As we further develop new products and services in the new technology era, we will continue to make every effort to ensure that customer data is used correctly and adequately protected.