Privacy Policy 

Stellaris Asset Management Limited  (hereinafter referred to as “we,” “our,” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our website (the “Site”) and use our services. By accessing or using our Site and services, you consent to the practices outlined in this policy.

We are bound by the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong and take the protection of your personal data seriously.

1. Collection of Personal Data 

We collect personal data that you voluntarily provide to us when you use our services, interact with our website, or engage with us in any other way. The types of personal data we may collect include, but are not limited to:

  • Identification Information: Name, nationality, gender, date of birth, and identification numbers (e.g., HKID card, passport number).
  • Contact Information: Email address, phone number, residential or business address.
  • Financial Information: Income, assets, liabilities, investment preferences, financial goals, and other related information.
  • Professional Information: Employment details, business affiliations, qualifications, and occupation.
  • Cookies & Usage Data: IP address, browser type, device information, pages visited, and browsing activity on our Site.

2. Use of Personal Data 

We use the personal data collected for the following purposes:

  • Providing Wealth Management Services: To deliver personalized wealth management services, including investment advisory, asset management, and financial planning.
  • Client Communication: To communicate with you regarding our services, updates, account-related matters, or to respond to your inquiries.
  • Regulatory Compliance: To fulfil our regulatory obligations under the Securities and Futures Commission (SFC), Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Tax Compliance (FATCA/CRS) requirements.
  • Marketing and Promotions: To send you newsletters, promotional materials, or updates related to our services that may interest you (only if you have opted in to receive such communications).
  • Improving Services: To enhance the functionality of our Site, improve user experience, and understand how users engage with our content.
  • Legal and Contractual Obligations: To comply with legal obligations, resolve disputes, and enforce our agreements.

3. Disclosure of Personal Data 

We respect your privacy and will not sell, rent, or trade your personal data to third parties. However, we may disclose your personal data to the following parties:

  • Service Providers: Third-party vendors or partners who provide services to us, such as IT support, data storage, legal or financial consultants, or marketing agencies, as necessary to facilitate the provision of our services.
  • Regulatory Authorities: To comply with legal or regulatory obligations, including disclosures required by the Securities and Futures Commission (SFC), Hong Kong Monetary Authority (HKMA), and other relevant authorities.
  • Financial Institutions: Where necessary, we may share information with banks, financial institutions, or custodians to process transactions or manage investments on your behalf.
  • Other Third Parties: If required by law, or to protect our rights, property, or safety, we may disclose personal data to law enforcement or other government entities.

4. Data Security 

We take reasonable and appropriate security measures to protect your personal data from unauthorized access, use, alteration, or disclosure. These measures include:

  • Encryption of sensitive data during transmission.
  • Access Control protocols to restrict data access to authorized personnel only.
  • Regular security audits and updates to ensure data protection.

However, please note that no method of data transmission over the internet or method of electronic storage is 100% secure, and while we strive to protect your personal data, we cannot guarantee its absolute security.

5. Retention of Personal Data 

We will retain your personal data for as long as is necessary to fulfil the purposes outlined in this Privacy Policy, or as required by law. When your personal data is no longer needed, we will ensure it is securely deleted or anonymized.

6. Your Rights 

As a data subject, you have the following rights under the Personal Data (Privacy) Ordinance:

  • Right to Access: You can request access to the personal data we hold about you.
  • Right to Correct: You may request corrections to any inaccurate or incomplete personal data.
  • Right to Withdraw Consent: You may withdraw your consent to our use of your personal data for marketing purposes at any time.
  • Right to Erasure: In certain circumstances, you may request the deletion of your personal data.
  • Right to Object: You may object to the processing of your personal data for certain purposes.

If you wish to exercise any of these rights, please contact us using the details provided in Section 9 below.

7. Cookies and Tracking Technologies 

We use cookies and similar tracking technologies (e.g., web beacons, analytics tools) to enhance your experience on our Site, analyze trends, and monitor traffic patterns. Cookies are small text files stored on your device that help us remember your preferences and improve our website performance.

You can control cookie settings through your browser, including disabling or deleting cookies. Please note that disabling cookies may affect your ability to use certain features of our Site.

For more information on our use of cookies, please refer to our Cookie Policy.

8. Third-Party Links 

Our Site may contain links to third-party websites. These links are provided for your convenience, and we are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

9. Changes to This Privacy Policy 

We reserve the right to amend or update this Privacy Policy from time to time. Any changes will be posted on this page with the updated date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

Acceptance of This Privacy Policy 

By using our Site and services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms and conditions.