Privacy Policy


1. From time to time, it may be necessary for you to supply Innovax Group with data in connection with the opening or continuation of Accounts and the establishment or continuation of credit facilities or provision of the relevant trading, nominee and/or investment advisory services. The data is collected pursuant to applicable laws, regulations, rules, codes or guidelines binding on Innovax Group.

2. Failure to supply such data may result in Innovax Group being unable to open or continue accounts or establish or continue credit facilities or provide securities trading nominee and/or investment advisory services to you.

3. It is also the case that data may be collected from you in the ordinary course of the continuation of the business relationship. This includes information obtained from client reference agencies.

4. The purposes for which the data relating to you may be used are as follows:

4.1 the daily operation of the-related services and credit facilities provided to you;

4.2 conducting credit checks (including without limitation upon an application for consumer credit (including mortgage loans) and upon periodic or special reviews of the credit which normally will take place one or more time each year).

4.3 creating and maintaining Innovax Group’s credit and risk related models;

4.4 assisting other financial institution to conduct credit checks and collect debts;

4.5 ensuring on-going credit worthiness of you;

4.6 designing financial services or related products for your use;

4.7 marketing financial services or relating products for your use;

4.8 determining the amount of indebtedness owed to or by you;

4.9 collection of amounts outstanding from you and amounts as security for your obligations;

4.10 meeting the requirements to make disclosure under the requirements of any law, regulations, rules, codes or guidelines binding on Innovax Group;

4.11 enabling an actual or proposed assignees of Innovax Group or participant or sub-participant of Innovax Group; and

4.12 purposes ancillary or relating to any of the above.

5. Data held by Innovax Group relating to you will be kept confidential but Innovax Group may provide such information to the following parties for the purposes set out in paragraph 4:-

5.1 any member of Innovax Group.

5.2 any agent, contractor or third-party service provider who provides administrative, telecommunications, computer legal, accounting, payment or securities clearing or other services to Innovax Group in connection with the operation of its business;

5.3 any other person under a duty of confidentiality to Innovax Group;

5.4 any financial institution with which you have or propose to have dealings;

5.5 any actual or proposed assignee of Innovax Group or participant or sub-participant or transferee of ISL’s rights in respect of you;

5.6 any person to whom Innovax Group is compelled by law or by relevant regulatory authorities to make disclosure;

5.7 any person with your express or implied consent;

5.8 an person where Innovax Group’s interests require disclosure; and

5.9 any person where the public interest requires disclosure.

6. You acknowledge that Innovax Group is classified as a Participated Foreign Financial Investor within the meaning of FATCA. You hereby authorize Innovax Group to disclose any information concerning you, your securities account and any U.S. securities, monies or other assets held in your securities accounts:

6.1 to any broker, custodian, clearing agent or other person(s) (whether within or outside Hong Kong) appointed by Innovax Group in connection with the services provided pursuant to the provisions in the Client’s Terms and Condition;

6.2 upon request, to any government, legal or regulatory authority or exchange (whether within or outside Hong Kong); or

6.3 to such other persons (whether within or outside Hong Kong) in compliance with the Applicable Laws or FATCA.

7. If a change in circumstances makes any information on any of the self-certificate issued by IRS (e.g. W9 / W8 forms), you have submitted incorrect, you must notify the withholding agent, payer, or FFI with which you hold an account within 30 days of the change in circumstances and you must file a new self-certificate or other appropriate form. An FFI shall rely on a properly completed self-certificate to establish your status to distinguish if you are a U.S. person. The self-certificate should be provided to the FFI when requested, Failure to do so could result in 30 percent withholding on income paid or credited to you as a recalcitrant account holder from sources within the United States.

8. In the course of performing ISL’s and/or any member of ISL’s duties, Innovax Group may as permitted by law, match, compare transfer or Exchange any personal data provided by you with data held, or hereafter obtained, for these or any other purposes by Innovax Group, government bodies, other regulatory authorities, corporations, organizations or individuals in Hong Kong or overseas for the purpose of verifying those data.

9. Under and in accordance with the terms of the PDPO any individual:-

9.1 has the right to check whether Innovax Group holds data about him/her and the right of access to such data;

9.2 has the right to require Innovax Group to correct any data relating to him/her which is inaccurate; and

9.3 has the right to ascertain ISL’s and/or any member of ISL’s policies and practices in relation to data and to be informed of the kind of personal data held by Innovax Group.

10. In accordance with the terms of the PDPO, Innovax Group has the right to charge a reasonable fee for the processing of any data access request.

11. The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:

Compliance Department

Innovax Securities Limited

Unit A-C 20/F Neich Tower, 128 Gloucester Road, Wan Chai, Hong Kong