PRIVACY POLICY

Crane Capital together with its subsidiaries and controlled affiliates (“Crane”, “Company”, “we”, “our” or “us”) are committed to protecting and respecting your privacy. This privacy policy (“Policy”) provides you with information about how we collect, use, disclose or otherwise process your personal data

If you have any questions about this Policy or how we use your personal data, our details are provided in the “Contact Us” section below.

What Personal Data We Collect

Depending on the nature of our relationship with you, we may collect the following types of personal data about you:

  • Identification data and contact details: name, date of birth, age, residential address, office address, telephone number, email address, job title, details of the organisation you work for, and identification information such as passport, national identity card, driver’s license and/or proof of address;

  • Financial data: bank account details, credit or debit card details, invoicing details, and information used to determine creditworthiness such as credit rating, bank statements and tax information;

  • Communication data: any requests, queries or complaints you make and any other data that we may receive if you communicate with us via email, our website (e.g. through the “Contact Us” form), telephone, social media and mail;

  • Device and electronic data: information we collect from your devices when you access our services, such as IP address, cookies, activity logs, online identifiers, device type, operating system, browser, unique device identifiers and geo-location data;

  • Data related to our services: information related to your dealings or engagements with us; and

  • Any other personal data that you disclose in the course of your business relationship with us.

We may collect personal data about you: (i) directly (for example when you use our website, when you communicate with us or otherwise in connection with our services or dealings with you); or (ii) through our trusted partners and associated third parties (including where you are an employee or contractor of such trusted partner/ associated third party).

To the extent that you provide us with the personal data of any other person, you should ensure that you are permitted to do so and that they are aware of the information contained in this Policy (and, where required by applicable data protection laws, obtain their consent before sharing such data with us).

We will indicate whether it is mandatory for you to provide certain types of personal data at the time of collection. If you do not provide us with personal data which is marked as mandatory, we may be unable to administer and manage our relationship with you (including providing you with access to our services) or comply with our legal obligations.

The Purposes For Which We Collect Personal Data

We may process your personal data for the following purposes:

  • To provide you with information about our business;

  • To provide services to you and otherwise manage our business relationship with you (including any contracts that we enter into with you);

  • To communicate with you and to manage and respond to your requests, feedback or queries;

  • For purposes connected with our business operations: this includes managing our internal client and business partner database, developing and improving the quality of our services (including through conducting data analytics), ensuring the integrity and security of our systems and network, fulfilling corporate governance purposes such as those related to management, recordkeeping, training and learning, and facilitating business operations and corporate transactions such as a mergers or acquisitions;

  • To comply with our legal and regulatory obligations, including maintaining required records and responding to regulators’ queries; and

  • Other purposes to which you have consented.

We may also use your personal data to send you marketing information about our services, news, offers, promotions, and events which we think may be of interest to you via email or other electronic means. In each case, where required by applicable laws, we will only do so where we have your consent to receiving such marketing information from us.

Sharing of Personal Data

We may from time to time share your personal data with the following third parties (within or outside of Hong Kong / Singapore):

  • our affiliates and business partners, for example to assist in our dealings with you or facilitate the management of your investment portfolio;

  • third party service providers, including credit reference agencies, those who host, support and/or maintain the IT systems supporting our website, email service providers and telecommunications providers;

  • outside parties involved in an actual or proposed merger, acquisition, reorganisation of part or all of our business;

  • parties involved in a dispute, litigation, investigation, proceedings or enquiry;

  • our professional advisors and any applicable regulators, governmental bodies, tax authorities or other industry recognised bodies we are subject to or whose requests we must comply with; and

  • any other third party you authorise us to disclose your personal data to.

We may also share your personal data with people who are authorised to act on your behalf, and who you consent to us sharing your personal data with.

From time to time your personal data may be transferred overseas for the purposes described in this Policy. Any transfers of personal data overseas are made pursuant to legally acceptable mechanisms that are aimed at ensuring an adequate level of protection as regards your personal data.

Security of Personal Data

We implement reasonable physical, technical, and organizational measures designed to protect your personal data from any unauthorized or accidental access, loss, misuse, alteration, destruction, or damage as well as to keep your personal data confidential. Despite our ongoing efforts, the transmission of information via the internet is not completely secure and we cannot guarantee the security of personal data transmitted to us via the website. Moreover, we are not responsible for the security of information that you transmit to us over networks that we do not control, including internet and wireless networks. Any transmission is therefore at your own risk.

Storage of Personal Data

We will retain your personal data for no longer than is required for the fulfilment of the purposes set out in this Policy, unless otherwise required or permitted by applicable laws.

Use of Cookies and Similar Technologies

We may employ cookies and other technologies from time to time. The information collected by cookies and other technologies includes information of your electronic device, browser details, IP address and your preferences and habits on language, webpage layout and other matters. We collect, analyze, and use the information to enable our website to function and operate, and to enhance website performance and user experience (for example, cookies may be used to help speed up your future interactions with our website and platforms).

We may also share information gathered through cookies with third party research agencies for analysis and research to enable us to perform more focused marketing of our services and products.

If you do not agree to our use of cookies and other technologies as set out in this Policy, you should restrict or disable the cookies associated with our website by changing the settings on your browser accordingly. However, if you do so, you may find that certain features and functions on our website may not work properly. This may impact your user experience while on our website.

Links

Our website may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies and notices. Please check these policies before you submit any personal data to these websites.

Your Rights

You have the following rights in respect of your personal data:

  • to request access to personal data held about you;

  • to ask for the personal data we hold about you to be rectified if it is inaccurate or incomplete;

  • to lodge a complaint with the supervisory authority; and

  • (where applicable) to withdraw your consent at any time to direct marketing communications.

Where permitted to do so under applicable law, we may charge you a reasonable fee to process your request.

Changes to this Policy

We may make changes or updates to this Policy from time to time. Please check back frequently to see any such updates or changes. We may notify you in the event of any material changes and will, where required by applicable laws, obtain your consent to the same.

Contact Us

To obtain further information regarding your rights, to exercise any of your rights, or to ask any questions regarding the processing of your personal data, please contact privacy@cranecapital.com.