BOCI-Prudential Trustee Limited (" BOCI-Prudential ") is committed to protecting the integrity of personal data of users collected online. This policy is designed to assist you (the " User ") in understanding why and how BOCI-Prudential collects and uses such data and the safeguards in place to protect such data. This policy should be read in conjunction with the BOCI-Prudential's Terms and Conditions for Internet and Interactive Voice Response System Services and other documents as specified by BOCI-Prudential from time to time.

1. REASONS FOR DATA COLLECTION AND USES

The User may be required to provide data to BOCI-Prudential in order to use certain services available through its website or its telephone services. Failure to supply such data may result in BOCI-Prudential being unable to provide certain services. The User's data is gathered for the following main purposes and uses:

(a) To establish the identity of the User - for these purposes, contact data such as, name, business address and e-mail will be collected from the User.

(b) To enable credit checks - such as analysing, verifying and/or checking the User's credit, payment and/or status in relation to User's ability to use the services.

(c) To provide services and support - the data may comprise both contact data and data related to products and services offered by BOCI-Prudential. The data is also used to provide the User with product and service updates and similar notices in respect of the services provided by BOCI-Prudential.

(d) To tailor the website or telephone services to the User's needs - data on website use or telephone service use may be used to compile aggregate statistics and carry out analysis in order to create website content and navigation that is most relevant and user friendly to the User.

(e) For marketing and promotional purposes, including contacting the User directly to inform them of new services or opportunities.

(f) For ancillary purposes relating to the purposes listed above (including without limitation data matching).

2. DISCLOSURE OF DATA COLLECTED

2.1 The User acknowledges and authorizes that all data supplied by him/her/it will be retained by BOCI-Prudential and stored in one or more of BOCI-Prudential's databases and may be disclosed or transferred to and accessed by:

(a) any persons or bodies corporate within the group of companies of which BOCI-Prudential is a member;

(b) any persons or bodies corporate under a duty of confidentiality to BOCI-Prudential;

(c) any contractors, agents, or other persons engaged by or in relation to any of the purposes listed above or any third party service providers who provide administrative, telecommunications, computer, payment, securities clearing, insurance, professional or other services to BOCI-Prudential;

(d) any banking, financial or other institution with which the User has or proposes to have dealings;

(e) any debt collection or credit reference agency or similar provider of debt collection or credit data services to BOCI-Prudential;

(f) any person or corporation to whom BOCI-Prudential transfers or proposes to transfer its interests and/or obligations in respect of the User or any product or service provided to the User;

(g) any person by whom BOCI-Prudential is required by applicable legal, governmental or regulatory requirements to make disclosure; or

(h) any person reasonably requiring the same in order for BOCI-Prudential to carry out the purposes set out herein.

2.2 The User further acknowledges that third parties to whom data supplied by the User may be transferred in accordance with paragraph 2.1 may be situated outside Hong Kong .

3. USER PREFERENCES / OPT-OUT

If at any point the User does not wish to receive any unsolicited communications from BOCI-Prudential, the User may simply contact BOCI-Prudential by email or in writing and BOCI-Prudential will remove the User from BOCI-Prudential's contact list for the purposes of those communications.

4. COLLECTION OF DATA USING 'COOKIES'

4.1 BOCI-Prudential may use "cookies" to collect data on the usage of the website by the User and to facilitate return visits. A "cookie" is a small piece of data sent by a web server to be stored on a webbrowser so it can later be read back from that browser. The data collected from cookies is currently used to improve the functionality of the website. The data on the website is organized and presented based on the analysis of the aggregate usage of the website.

4.2 The User may disable the cookie feature on their browser without affecting their ability to transact business on the website. Disabling cookies may require more complexity and data entry. The User should also be aware that if they do disable cookies they may not be able to use certain features on the website.

5. SECURITY

BOCI-Prudential is concerned with the security of data collected and has put in place measures to prevent unauthorized access to that data. Notwithstanding the above, BOCI-Prudential shall not in any event be responsible for any breach whatsoever of security or the unauthorised disclosure or use of any such data.

6. UPDATES TO THE PRIVACY POLICY

BOCI-Prudential is sensitive to the privacy issues and recognizes the need to, and may, update this policy as new features and business services are offered by BOCI-Prudential. The User will be deemed to have sufficient notice of any of the changes to this policy 3 days after such changes have been displayed on BOCI-Prudential's website.

7. OTHER RIGHTS

Nothing in this Privacy Policy shall limit the rights of any person under the Personal Data (Privacy) Ordinance of Hong Kong. You are aware of your rights under the Personal Data (Privacy) Ordinance, including the right:

(a) to check whether BOCI-Prudential holds any of your personal data;

(b) to have access to your data held by BOCI-Prudential;

(c) to request correction of your data;

(d) to ascertain BOCI-Prudential's policies and practices (from time to time) in relation to the data and the types of data held by BOCI-Prudential;

(e) to disallow access or use of your data by BOCI-Prudential, and be informed of action taken in response to any such request.

BOCI-Prudential reserves the right to charge a reasonable fee in relation to the time and attendance involved in complying with any request in this regard.

8. CONTACTING BOCI-PRUDENTIAL

Any requests for access to data, correction of data or for data regarding practices and kinds of data held should be addressed in writing to BOCI-Prudential's Data Privacy Officer at email: DataProtection@bocpt.com or at 25/F, Citicorp Centre, 18 Whitfield Road, Causeway Bay, Hong Kong.