Effective Date: from 11 July 2018

Geoswift Limited and its subsidiaries and affiliates (“Geoswift”, “we”, “us”, “our”, and similar terms) respects your privacy and values the confidence of its clients, partners, and employees.

This Privacy Statement applies to Geoswift Websites (the “Services”). By using the Services, you agree to abide by the terms of this Privacy Statement.

This Privacy Statement explains how particular companies in the Geoswift Group collect, process and disclose your personal data, and your rights in relation to the personal data it holds. It also describes your choices regarding use, access, and correction of your personal information.

Geoswift complies with the data protection principles and all relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance and the EU General Data Protection Regulation 2016/679 (the “GDPR”). Geoswift acts both as data controller and data processors under the GDPR.

This Privacy Statement supersedes any previous Privacy Policy or equivalent which you may have been provided with or seen prior to the Effective Date stated above. If any material changes are made on this statement, Geoswift will notify you by means of a notice on the website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Your rights

Upon request, Geoswift will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at DataEnquiry@Geoswift.com. We will respond to your request within a reasonable timeframe.

You also have the following rights:

• To obtain access to, and copies of, the personal data that we hold about you;
• To require that we cease processing your personal data if the processing is causing you damage or distress;
• To require us not to send you marketing communications;
• To require us to erase your personal data;
• To require us to restrict our data processing activities;
• To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
• To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights at https://www.eugdpr.org. and https://www.pcpd.org.hk/

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please fill out the Subject Access Request (“SAR”) form and contact us using the following:

• By post – Attention: Data Protection Officer, Geoswift UK Limited,1925 Portland House, Bressenden Place, London, SW1E 5RS United Kingdom
• By email – DataEnquiry@Geoswift.com

How we collect your data

We collect your personal data in a number of ways, for example:

• From information about you provided to us by your company or an intermediary;
• When you communicate with us through our website (http://www.geoswift.com/), telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
• When you complete the client on-boarding or application or other forms;
• From other companies in the Geoswift Group;
• From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

As is true of most websites, we also gather certain information from you automatically. This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), files viewed on our site (e.g. HTML pages or graphics), operating system, and clickstream data in order to analyze trends in the aggregate and administer the site.

The categories of personal data we collect

We collect the following categories of personal data about you for either operation or lawful obligation purposes:

• Your name and contact information such as your home or business address, email address and telephone number;
• Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality, country of tax residency; and
• Information to assess whether you may represent a politically exposed person or money laundering risk. This might include details on source of wealth.

The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with

(i) Performance of a contract with our clients

We process your personal data because it is necessary for the performance of a contract to which your company is a party or in order to take steps at its request prior to entering into a contract. The use of your personal information is limited to the purpose of providing the service for which your company (our customer) has engaged us.

In this respect, we use your personal data for the following:

• To prepare a proposal regarding the services we offer;
• To provide our clients with the financial services for which we have been engaged;
• To deal with any complaints or feedback you may have;
• For any other purpose as identified in our contract for which you provide us with your personal data.

In this respect, we may share your personal data with or transfer it to the following:

• Other companies in the Geoswift Group;
• Third party service providers who provide services on our behalf and with whom we engage to deliver the services to you, such as our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers. Geoswift has signed Data Protection Agreement with these companies, and the companies are authorised to use your personal information only as necessary to provide these services to us.
• Other third parties such as other financial institutions who we introduce to you. We will wherever possible tell you who they are before we introduce you;
• Our data storage providers.
• In scope of GDPR, the data that we collect from the client, partner or vendors may also involve transfer of those personal data to any country, including countries outside the European Economic Area, but that in those cases, except where the relevant country has been determined to ensure an adequate level of data protection by the European Commission or we need to make the transfer in order to perform a contract concluded in interests of the data suppliers or relevant party, we will ensure that the transferred personal data is protected by a data transfer agreement in the appropriate standard form approved for this purpose by the European Commission or by a binding legal agreement (and that further details of these transfers and copies of these agreements are available from us on request). It may also be processed by our staff operating outside the EEA who work for us. Geoswift will ensure the personal data will be safe and secure during the transfer and processing and ensure the same or equivalent degree of data safety level is met.

 (ii) Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following:

• For marketing to you. In this respect, see the separate section on Marketing below;
• To respond to requests from clients for follow-up services relating to requested transactions;
• Training our staff or monitoring their performance;
• For the administration and management of our business, and archiving or statistical analysis;
• Seeking advice on our rights and obligations, such as where we require our own legal advice.

In this respect, we will share your personal data with the following:

• Our third-party service providers who provide services on our behalf to help with our business activities, such as our advisers or agents where it is necessary for us to obtain their advice or assistance. These service providers are authorized to use your information only as necessary to provide these services to us.;

(iii) Legal obligations

We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:

• To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
• As required by tax authorities or any competent court or legal authority.

In this respect, we will share your personal data with the following:

• With third parties when required by law in order to comply with a subpoena or other legal process;
• With third parties when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety, or the safety of others;
• When disclosure is necessary to investigate fraud or respond to a governmental request;
• With third parties who assist us in conducting background checks; and
• With relevant regulators or law enforcement agencies where we are required to do so.

If Geoswift is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership uses of your personal information, and choices you may have regarding your personal information.

Marketing

We also process your personal data for our marketing purposes.

We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.

We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.

If you object to receiving marketing and would no longer like to receive these communications from us, you can contact us at any time by email DataEnquiry@geoswift.com.

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests.

Cookies and tracking technologies

A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our websites and the internet and helps us provide better services to you and tailor certain content.

Cookies may collect personal information about you. We use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

Cookies help us remember information about your visit to our website, like your country, language and other settings and searches. The Cookies will be used in following aspects:

• Essential cookies. These are cookies that are set throughout our website. They include, for example, cookies that enable you retain information between pages on the website, so you don’t have to re-enter the information.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Targeting/Advertising cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. This information enables us to remember your preference and provide the personalized content.

For more information on how we use cookies please read our Cookie Policy, where you can also find information so you can delete cookies or block certain types of cookie. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Information Security

Geoswift takes all reasonably practicable means to protect the data, both during transmission and once it is received, by restricting the access of data by authorized personnel only and incorporating security measures into equipment in which data is held. Encryption technology is employed for sensitive data transmission.

We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide to us. Security procedures include, restricting the access of data by authorized personnel only and incorporating security measures into equipment in which data is held. Encryption technology is employed for sensitive data transmission.

However, please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information. If you have any questions about the security of your personal information, you can contact us at DataEnqiry@geoswift.com

Minors

We do not knowingly collect, use, or disclose personal information from children under the age of 13. We request that these individuals do not submit such information to us. If you believe that we have inadvertently collected the information of a child, please contact us at DataEnquiry@geoswift.com.

Links to Third Party Sites

The Services may contain links to other websites or online services that may be operated and maintained by Geoswift or third parties and that are not under the control of or maintained by Geoswift. This Privacy Policy does not apply to this third-party content. If you submit personal information to any third-party websites, your information is governed by their privacy policies. We encourage you to review the privacy policies of these third-party websites or services.

Retention of your data

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.  We will only retain your personal data for as long as we have a lawful reason to do so. In particular:

• where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for seven years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
• otherwise, we will in most cases retain your personal data for a period of five years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.

Changes to This Policy

We may update this Privacy Statement to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

You may contact us for any reason by sending correspondence to the address below. You may also contact our Privacy and Data Compliance Officer by email at DataEnquiry@Geoswift.com.

Attention: Data Protection Officer

Geoswift UK Limited,

123 Buckingham Palace Road

Victoria,

London, United Kingdom

SW1W 9SH