In this Policy when we refer to ARCM or we/us/our we mean Asia Research & Capital Management Limited and also other companies and entities that are associated with us. Our registered office is at 21/F Shanghai Commercial Bank Tower, 12 Queen’s Road Central, Hong Kong.
We may revise this policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
This policy describes:
- The information that we collect
- How we use the information we collect
- How we share information with third parties
- Keeping your information and information security
- Your choices and rights
- How to contact us and other important information
The information that we collect and where we get it from
“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following personal information about you.
Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels such as when you sign up to receive emails from us or updates to the Site or when you contact us with queries or respond to our communications the personal information you provide may include your full name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
Information we otherwise collect about you
How we use the information we collect
We collect your personal information for the following purposes and may do the following with your personal information:
- use it to send you emails for which you have signed up or notice of updates to the Site
- to comply with legal and regulatory obligations that we have to discharge
- use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings
- record and monitor your use of our websites for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business
- use it to look into any complaints or queries you may have, and
- use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Consent – we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
- Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation.
How we share information with third parties
We share personal information with our various companies and entities that make up our international network. As a result, your personal information may be transferred to locations outside Hong Kong and Europe as well as within it for the purposes described above.
We may also share your personal information with third parties. This may include:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
- Third parties relevant to the services that we provide. This may include, but is not limited to, other professional service providers, regulators, authorities, governmental institutions and stock exchanges.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
Where we transfer your personal information outside Hong Kong or Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
- the country to which we send the personal information may be approved by the European Commission
- the recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information, or
- where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.
In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.
You can obtain more details of the protection given to your personal information when it is transferred outside Europe (including a sample copy of the model contractual clauses) by contacting us using the details set out below.
Keeping your information and information security
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
- Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit this information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
- We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
How to contact us and other important information
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at Data Protection Officer, Asia Research & Capital Management Limited 21/F Shanghai Commercial Bank Tower, 12 Queen’s Road Central, Hong Kong.
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What cookies will the site use and for what purposes?
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How long will the cookies remain on my computer?
The cookies will remain in the cookies file of your browser after the closing of the browser, and will become active again when the Site is reopened, until removed. The cookie(s) can be deleted at any time by you. The cookie(s) will not collect any information when you are not accessing the Site.
Third party cookies
The single session and persistent cookies are provided on our behalf by a trusted third party service provider to aid in the reporting of user behaviour on the Site. This behaviour is analysed to provide an improved user experience. The information collected is not linked to personally identifiable information.