This Privacy Policy sets forth the policies and procedures of 18 Salisbury Capital Limited (hereinafter referred to as "18 Salisbury," "we," "us," or "our") pertaining to the collection, use, disclosure, and protection of the personal information of our clients, visitors, and users (hereinafter collectively referred to as "you" or "your") in connection with our services and operations. By utilizing our website or engaging with us, you consent to the practices outlined in this Privacy Policy.
1. Information We Collect
In the course of our business activities, we may collect and process the following categories of personal information:
1.1 Personal Identification Information: This may include your name, contact information (including but not limited to phone number, email address, and physical address), date of birth, nationality, and identification numbers.
1.2 Financial Information: Depending on the services you seek, we may collect personal financial information, including but not limited to banking details, income information, investment profiles, and other data necessary for the purpose of investment management.
1.3 Transactional Data: We may gather data regarding your interactions with us, including records of transactions undertaken, correspondence, and records of communications with our representatives.
1.4 Technical Data: We may collect technical information about your equipment, browsing actions, and usage patterns, which may include your IP address, browser type, operating system, and access times.
1.5 Usage Data: We may collect information regarding how you use our website and services, including details of your visits and the resources that you access.
1.6 Marketing and Communication Data: We may collect your preferences in receiving marketing from us, your communication preferences, and your feedback.
2. Purpose of Data Collection
The personal information collected by 18 Salisbury will be used for various purposes, including but not limited to:
2.1 To Provide Services: We process your personal information to facilitate transactions and provide the financial services requested, including investment management, financial advisory, and related support.
2.2 To Communicate: We may use your personal information to communicate with you, respond to inquiries, and provide you with updates or notifications regarding our services, including any changes to our policies.
2.3 To Improve Our Services: We analyze personal information to understand client preferences and improve our products and services.
2.4 Compliance Obligations: We may process your personal information to ensure compliance with applicable laws, regulations, or industry standards, particularly those relating to anti-money laundering (AML) and know your customer (KYC) requirements.
2.5 Marketing Purposes: With your consent, we may use your personal information to send you promotional materials or newsletters regarding our services, and we may personalize such communications based on your preferences.
2.6 Security and Fraud Prevention: We may collect and process your information as necessary to safeguard our systems, detect fraudulent activity, and prevent security breaches.
3. Legal Basis for Processing Personal Information
We ensure that any processing of your personal information is legally justified, relying on the following bases:
3.1 Consent: By providing us with your personal information, you consent to our processing as described in this Privacy Policy.
3.2 Contractual Necessity: We may process your personal information where it is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into such a contract.
3.3 Legal Obligation: We may process your personal information to comply with our legal obligations, including compliance with applicable laws, regulations, and industry standards.
3.4 Legitimate Interests: We may process your personal information where it is necessary for our legitimate interests or those of a third party, provided that such interests are not overridden by your rights.
4. Disclosure of Your Information
We may share your personal information with:
4.1 Service Providers: We may engage third-party service providers who process your information on our behalf, including payment processors, administrative support, and technology service providers.
4.2 Affiliates: We may share your information within our corporate family for purposes consistent with this Privacy Policy.
4.3 Regulatory Authorities: We may disclose your information to regulatory authorities and law enforcement agencies as required by law or regulation.
4.4 Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our business, your personal information may be transferred as part of that transaction, and we will endeavor to ensure that your personal information remains subject to this Privacy Policy.
5. International Data Transfers
Personal information that we collect from you may be transferred to, and stored at, a destination outside your jurisdiction. By submitting your personal information, you agree to this transfer, storage, and processing. In such instances, we will implement appropriate safeguards, such as standard contractual clauses, to ensure that your personal information is adequately protected in accordance with applicable data protection laws.
6. Data Security
We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing your personal information. We protect your personal information against unauthorized access, unlawful processing, accidental loss, destruction, and damage. However, you should be aware that no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
7. Data Retention
We will retain your personal information only for as long as necessary to fulfill the purpose for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The criteria used to determine our retention periods include:
7.1 Length: The length of time we have an ongoing relationship with you.
7.2 Obligation: Whether there is a legal obligation we are subject to.
7.3 Necessity: The necessity to retain your personal information for any ongoing processes or business operations.
8. Your Rights
Subject to applicable law, you may have the following rights regarding your personal information:
8.1 Access: You have the right to request access to the personal information we hold about you.
8.2 Correction: You have the right to request that we correct any inaccuracies in your personal information.
8.3 Deletion: In circumstances where there is no longer a legitimate basis for processing your personal information, you may request deletion of your personal information.
8.4 Restriction: You have the right to request that we restrict our processing of your personal information under certain circumstances.
8.5 Data Portability: You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.
8.6 Objection: You have the right to object to the processing of your personal information based on legitimate interests or for direct marketing purposes.
To exercise any of these rights, please contact us using the contact details provided below.
9. Cookies and Tracking Technologies
We may use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small text files that are stored on your device when you visit our website. You may choose to accept or decline cookies. Most web browsers automatically accept cookies, but you may modify your browser settings to decline cookies if you prefer. However, please be aware that declining cookies may affect your ability to use certain features on our website.
10. Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those external sites, and we are not responsible for the content or privacy practices of such websites. We recommend that you review the privacy policies of any third-party websites you visit.
11. Changes to This Privacy Policy
We reserve the right to modify, update, or change this Privacy Policy at any time. Any changes will be effective immediately upon being posted on this page with an updated effective date. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of our website after any modifications will constitute your acknowledgments of the modifications and your consent to abide by and be bound by the modified Privacy Policy.
12. Contact Us
If you have any questions or concerns regarding this Privacy Policy or our data practices, please do not hesitate to contact us at stephen.yuen@18salisbury.capital.
By using our website and services, you acknowledge that you have read and understood this Privacy Policy, and you agree to its terms and conditions.
Suite 30, Great Eagle Centre, 23 Harbour Road, Wan Chai, Hong Kong
+852 9326 7678