SC Lowy is committed to respecting and protecting your privacy. This privacy notice sets out how we look after your personal data when you visit our website at www.sclowy.com, and tells you about your privacy rights and how certain laws may apply to you.

If you have any queries about this notice or how we use your personal data, please contact us at info@sclowy.com.

Your privacy is important to us. To protect your privacy and help you to make informed choices, we provide this notice explaining our information practices, how you can choose how we use your data, and your rights in relation to your personal data.

In brief, we will only use your information:

• to optimise our website performance; or
• where you have consented to us doing so.

This is explained in more detail below.

01 About Us

This website www.sclowy.com (our “site”) is operated by SC Lowy Financial (HK) Limited, a company incorporated in Hong Kong with its principal place of business at 23rd Floor, 26 Des Voeux Road Central, Hong Kong (“SC Lowy”, also referred to in this notice as “we”, “us” and “our”).

SC Lowy is a data user/ controller and is responsible for your personal data collected via this site.

02 This Privacy Notice

This privacy notice describes how we collect and use information collected through your use of this site. You can use most of this site without giving us any personal data.

However, if you wish to take advantage of some of the more personalised services that we make available (such as signing up to receive our updates, or contacting us), you will need to provide certain information.

In certain circumstances (for example, if you become our client), we may provide you with additional privacy notices which are relevant to you.

This site is not intended for children under the age of 18 and we do not intend to collect data of children under the age of 18.

03 What Personal Data Do We Collect Via The Site?

We collect different information depending on how you use the site and how you interact with us. ‘Personal data’ means any data which relates to you as an individual, either directly or indirectly, from which it is practicable for your identity to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.

The personal data we collect via the site may include:

• Identity Information, such as your name, organisation name and position.
• Contact Data, such as your address and email and telephone details.
• Technical Data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the site.
• Usage Data, which includes information about how you use the site, and any communications we may receive from you.
• Marketing and communications data, including your preferences in receiving marketing and other communications from us.

We will identify any personal data which is mandatory when we collect information from you. Failure to provide the requested personal data to us may result in us not being able to provide you with products or services.

We will also collect any personal data that you specifically send to us (for example, if you apply for a position with us and send us your CV).

Our site is not intended for storing or transmitting ‘special categories’ of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or health information. We do not intentionally collect data about actual or alleged criminal offences via our site.

04 How We Collect Personal Data

Different personal data is collected in different ways.

• Personal data you provide to us. When you sign up to receive news updates, you will provide us with your email address or other contact data. You will also provide us with personal data when you contact us via the site (including your name and email address), and if you apply for a position with SC Lowy.
• Personal data we collect automatically. As you use the site, we will collect certain technical data including your browser type and the Internet Protocol (IP) address used to connect your computer to the internet.

05 How And Why We Use Personal Data

We may use your information where:

• You have indicated a desire to purchase our products;
• Any purposes directly related to any of the above purposes.

06 To Whom We Share Personal Data

We may share some of the personal data collected from you with the following parties:

• our affiliated and associated companies and their or our successors and assigns;
• our authorized business partners such as agencies, suppliers, contractors or service providers appointed by us for the aforesaid purposes;
• any person to whom we are under an obligation to make disclosure under any requirements of any law; and
• any person with your express consent.

07 International Transfers

This site is hosted on servers located outside of Hong Kong.

08 Data Security

The safety of your personal data is important to us, and we use various technical and organisational measures to ensure that your data is secure.

SC Lowy employs industry standard technologies to protect and secure all personal data in our possession. However, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorised disclosures of information, we cannot guarantee the security of your data.

09 How Long We Keep Your Personal Data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, the Hong Kong Securities and Futures Commission (SFC) requires us to retain data in certain circumstances for a minimum period of 7 years. To find out more about how long we retain personal data, please contact us at please contact us at info@sclowy.com.

10 Third Party Links

This site may contain links to other sites whose information practices may be different than ours. Please consult all third party sites’ privacy notices as we have no control over information that is submitted to, or collected by, third parties.

11 Your Rights

You have certain rights over your personal data. You may:

• require us to rectify the personal data we hold about you, where that data is incorrect;
• request access to the personal data that we hold about you;
• require that, in certain circumstances, we delete the personal information we hold about you;
• require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format; and/or
• withdraw your consent to our using your data for marketing purposes at any time.

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data for Hong Kong, which is the Hong Kong supervisory authority for data protection issues (www.pcpd.org.hk). We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.

If you wish to exercise any of these rights, please contact at info@sclowy.com or by writing to one of our addresses listed above.

To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

12 Changes To This Notice Or Your Data

We may amend or modify this privacy notice from time to time. We will post any revised notice on this site. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This privacy notice was last updated in May 2024 [].