Data Policy

  • VMS Securities Limited (the “Company”) values the protection of your personal data. All personal data collected by the Company shall be treated in accordance with the Personal Information Collection Statement (“Collection Statement”) set out below and the provisions of the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “Ordinance”).


    1. VMS Securities Limited may collect personal data (as defined in the Ordinance) (which data may relate to yourself or your authorized signatories or other persons) from you, in connection with its dealings with you. You must supply the personal data as required by the Company. If you fail to supply the required personal data, the Company may refuse to open an account for you.

1. Purposes of Collection

The Company may use your personal data (whether provided by you or any other person, and whether provided before or after the date you receive this document) for the following purposes: (a) activities relating to operating your account such as purchasing, investing, advising, exchanging, acquiring, disposing of and generally dealing in and with all kinds of securities and options on your behalf, carrying out transactions at your instructions, ongoing account administration and contacting you; (b) activities relating to the processing of your application to open an account with the Company and maintaining your account, including but not limited to client verification, anti-money laundering and other client due diligence procedures, conducting credit reporting, processing your application for grant of credit or margin facilities or the continuation and review of such credit or margin facilities; (c) maintenance and verification of particulars and data; (d) any other purpose relating to the provision of investment and/or other financial services and facilities by the Company and/or any holding company, subsidiary or affiliate (within or outside Hong Kong)(the “Group”); (e) to provide you with information about your account and account statements; the (f) to conduct research and statistical analysis; and (g) complying with the obligations, requirements or arrangements, whether voluntary or mandatory, for disclosing and using data, including notification requirements that apply to the Company or any member of the Group, according to any law binding or applying to them within or outside Hong Kong or pursuant to any treaty or undertaking between any governmental, regulatory, tax, law enforcement or other authorities within or outside Hong Kong, and in particular the reporting and exchange of information requirements pursuant to the United States Foreign Account Tax Compliance Act (“FATCA”) and the Organisation for Economic Co-operation and Development (“OECD”)’s standard for Automatic Exchange of Financial Account Information (“AEOI”).

2. Classes of Transferees

Personal data held by the Company will be kept confidential but may be transferred to the following persons within or outside Hong Kong solely for the purposes set out at paragraph 1 (excluding direct marketing purposes): (a) other entities within Group (including direct and indirect subsidiaries) providing investment and/or other financial services and/or outsourced activities that facilitate the provision of such services; (b) the Company’s agents, nominees, personal advisers, researchers and other third party service providers that offer services to the Group in connection with the operation of its investment and/or financial services business; (c) credit reporting agencies; (d) financial regulators, government bodies, law enforcement bodies or other regulatory authorities, individuals or corporations who have the right to such data and information as prescribed by law within or outside Hong Kong; (e) the Hong Kong Inland Revenue Department, the United States Inland Revenue Service and any other taxing authority of any jurisdiction to whom the Company or any member of the Group is under an obligation or otherwise required to make disclosures under the requirements of any law or pursuant to any treaty or undertaking between governmental, regulatory, tax or other authorities within or outside Hong Kong (in particular the reporting and exchange of information requirements pursuant to FATCA and the AEOI); (f) where transactions are executed outside Hong Kong, the relevant stock exchange, clearing house or regulatory bodies; and (g) authorized employees of the Company.

3. Transfers of Personal Data Outside Hong Kong

To facilitate the purposes set out in paragraph 1 above, the Company may transfer, disclose, grant access to or share your personal data with the parties set out in paragraph 2. You acknowledge that those parties may be based outside Hong Kong and that your personal data may be transferred to places where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Ordinance.

4. Consequence of failing to provide Personal Information

Unless otherwise specified by us, it is mandatory for you to provide the Personal Information requested by us. In the event that any such Personal Information is not provide, we may be unable to provide you with services or carry out the activities outlined at paragraph 1 above.

5. Access to Personal Data

Under the Ordinance you have the right to enquire whether the Company holds personal data in relation to you, and to request access to and correction of your personal data. You may make such a request to the Privacy Officer – Compliance Department, VMS Securities Limited, 49/F, One Exchange Square, 8 Connaught Place, Central, Hong Kong, Tel: (852) 2996 2100, Fax: (852) 2996 2102. In accordance with the terms of the Ordinance, a reasonable fee may be charged for processing any data access request.

If there is any inconsistency between the English version and the Chinese version, the English version shall prevail.