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Privacy Policy Statement of Asia Frontier Capital Ltd. (AFC)

This is the Privacy Policy Statement of Asia Frontier Capital Ltd., on behalf of itself, its affiliates and subsidiaries (AFC). The purpose of this Privacy Policy Statement is to set out the policies and practices of AFC’s commitment to protecting personal data privacy in accordance with the provisions of the Hong Kong Personal Data (Privacy) Ordinance as well as the European General Data Protection Regulation (GDPR).

For the purposes of the GDPR, we are a data controller in respect of your personal data. AFC is responsible for ensuring that it uses any personal data provided by you in compliance with the GDPR.

This privacy policy applies if you are an existing client or a prospective client. This privacy notice sets out the basis on which any personal data that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us.

We may collect and process the following personal data about you:

  • Information that you provide to us: This includes information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include: Your name, address, email address, telephone number, any financial information and other information provided by you in connection with: (i) any due diligence, (ii) a prospective investment in any funds advised/managed by us, (iii) completing any forms or other documents / communications sent by or on behalf of us to you in relation to any prospective investment or investment made, (iv) any ongoing communications with us regarding any prospective investment or investment made, or (v) any related matters.
  • Information we collect or generate about you. This includes: written documentation AFC has to keep by law or by a regulatory body, information in any client relationship management notes, any telephone conversations (whether recorded or not), meetings, information you provide to us in the completion of any documentation, the use of our website, by email or at any conferences, meetings or other events.
  • Information we obtain from other sources. This includes: information received from any distributor, placement agent, custodian, banks, regulators, financial institution, fund of funds, management company or other company acting on your behalf.


Uses of your personal data

Your personal data may be stored and processed by AFC in the following ways and for the following purposes:

  • Sending you information in relation to the funds we act as investment advisor for, facilitating an assessment of your eligibility to invest, processing any subscription, redemption, withdrawal, exchange or transfer request, communicating with any third parties you may ask us to communicate with.

We are entitled to use your personal data in these ways:

  • In order to perform the obligations set out in any subscription, redemption or withdrawal, exchange or transfer request (a contract between you as the data subject and the fund we act as investment advisor for as data controller);
  • The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as maintenance of client records and communicating with clients in relation to funds we act as investment advisor for that clients or prospective clients have expressed an interest in; and
  • In order for us to comply with our legal and regulatory obligations, or in order to establish, exercise or defend our legal rights or for the purpose of any legal proceedings.

Disclosure of your information to third parties

  • We might have the legal obligation to disclose some or all of your personal data to tax authorities, governments, regulators (FATCA, Automatic Exchange of Financial Account Information (AEOI), Securities and Futures Commission of Hong Kong (SFC) and others) or other enforcement/investigation agencies or government entities.
  • We may disclose your personal data to our affiliates in order for us to discharge our obligations, and/or in order for us to communicate effectively between related parts of our business.

We will take steps to ensure that personal data is accessed only by staff that have a need to do so for the purposes described in this notice.

We may also share your personal data outside of AFC and our affiliates:

  • To third party agents or contractors (for example, the providers of our electronic data storage services, and our fund administrator) for the purpose of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
  • To the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it - we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations - laws or regulation may set a minimum period for which we have to keep your personal data.

Your rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw your consent to our processing of your personal data at any time.
  • However, please note that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. However, please note that there may be circumstances in which you ask us to erase your personal data but we are legally required to retain it;
  • the right to object to, and the right to request that we restrict our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to either continue processing your personal data and / or to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.


Accessing your personal data

You have the right to access and update your information and contact us. If you have any question about our Privacy Policy Statement, please contact us at:

Data Protection Officer 
Asia Frontier Capital Ltd. / Asia Frontier Investments Limited
905 Loon Kee Building

267-275 Des Voeux Road Central

Hong Kong
Fax: 852 3904 1017
This email address is being protected from spambots. You need JavaScript enabled to view it.

May 2018