• the daily operation of the services and facilities provided to customers;
• conducting credit checks;
• assisting other institutions to conduct credit checks;
• ensuring customers' ongoing credit worthiness;
• designing financial services or related products for customers' use;
• marketing financial services or related products to customers;
• determining the amount of indebtedness owed to or by customers;
• meeting the requirements to make disclosure under the requirements of any law or regulations; and
• any purposes relating to any of the foregoing.

• any officer, employee, agent, contractor or third party who provides administrative, credit information, debt collection, telecommunications, computer, payment or other services to INNS in connection with the operation of their business;
• any financial institution with which the customer has or proposes to have dealings;
• regulatory authorities and other relevant government bodies;
• any other person under a duty of confidentiality to INNS including a company within INNS which has undertaken to keep such information confidential.
• We share information regarding customers among INNS only in accordance with strict internal security standards and confidentiality policies and with applicable law.
• We hold our employees fully accountable for adhering to those standards, policies and laws.
• We do not share information about our customers with other companies except in order to conduct our business, comply with applicable law, protect against fraud or make available special offers of products and services that we feel may be of interest to our customers. We may also provide information to regulatory authorities and law enforcement officials in accordance with applicable law.
• We have established high standards for protecting information regarding our customers from unauthorized alteration or destruction.

• credit checking;
• data (and other information) verification;
• otherwise producing or verifying Data (and other information) which may be used for the purpose of taking adverse action against the customer or any other person at any time;
• transfer such Data (and other information) to any place outside Hong Kong (whether for the processing, holding or use of such Data (and other information) outside Hong Kong).

• your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by INNS from time to time may be used by INNS in direct marketing;
• the following classes of services and products may be marketed:
  • financial, securities, commodities, leveraged foreign exchange, bullion investment and related services and products and facilities;
  • reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to above; and
  • services and products offered by INNS's co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be) in relation to the class of marketing subjects as referred to above.
• If you do not wish INNS to use or provide to other persons your data for use in direct marketing as described above, you may exercise the opt-out right by notifying INNS in writing to the address provided below in clause 6 of this policy.

• check whether INNS hold Data about the customer and the right of access to such Data;
• require INNS to correct any Data relating to the customer which is inaccurate; and
• ascertain INNS's policies and practices in relation to Data and to be informed of the kind of personal data relating to the customer held by INNS.

1. tag each of the Client’s orders submitted to the China Stock Connect System (“CSC”) with a Broker-to-Client Assigned Number ("BCAN") that is unique to the Client or the BCAN that is assigned to the Client’s joint account with INNS, as appropriate; and
2. provide to the Exchange the Client’s assigned BCAN and such identification information (“Client Identification Data” or “CID”) relating to the Client as the Exchange may request from time to time under the Rules of the Exchange.

Without limitation to any notification INNS has given the Client or consent INNS has obtained from the Client in respect of the processing of the Client’s personal data in connection with the Client’s account and INNS’s services to the Client, the Client acknowledges and agrees that INNS may collect, store, use, disclose and transfer personal data relating to the Client as required as part of INNS’s China Connect securities trading service, including as follows:

1. to disclose and transfer the Client’s BCAN and CID to the Exchange and the relevant SEHK Subsidiaries from time to time, including by indicating the Client’s BCAN when inputting a China Connect Order into the CSC, which will be further routed to the relevant China Connect Market Operator on a real-time basis;
2. to allow each of the Exchange and the relevant SEHK Subsidiaries to:
   1. collect, use and store the Client’s BCAN,CID and any consolidated, validated and mapped BCANs and CID information provided by the relevant China Connect Clearing House (in the case of storage, by any of them or via HKEX) for market surveillance and monitoring purposes and enforcement of the Rules of the Exchange;
   2. transfer such information to the relevant China Connect Market Operator (directly or through the relevant China Connect Clearing House) from time to time for the purposes set out in (c) and (d) below; and
   3. disclose such information to the relevant regulators and law enforcement agencies in Hong Kong so as to facilitate the performance of their statutory functions with respect to the Hong Kong financial markets;
3. to allow the relevant China Connect Clearing House to:
   1. collect, use and store the Client’s BCAN and CID to facilitate the consolidation and validation of BCANs and CID and the mapping of BCANs and CID with its investor identification database, and provide such consolidated, validated and mapped BCANs and CID information to the relevant China Connect Market Operator, the Exchange and the relevant SEHK Subsidiary;
   2. use the Client’s BCAN and CID for the performance of its regulatory functions of securities account management; and
   3. disclose such information to the Mainland regulatory authorities and law enforcement agencies having jurisdiction over it so as to facilitate the performance of their regulatory, surveillance and enforcement functions with respect to the Mainland financial markets; and
4. to allow the relevant China Connect Market Operator to:
   1. collect, use and store the Client’s BCAN and CID to facilitate their surveillance and monitoring of securities trading on the relevant China Connect Market through the use of the China Connect Service and enforcement of the rules of the relevant China Connect Market Operator; and
   2. disclose such information to the Mainland regulatory authorities and law enforcement agencies so as to facilitate the performance of their regulatory, surveillance and enforcement functions with respect to the Mainland financial markets

By instructing INNS in respect of any transaction relating to China Connect Securities, the Client acknowledges and agrees that INNS may use the Client’s personal data for the purposes of complying with the requirements of the Exchange and its rules as in force from time to time in connection with the Stock Connect Northbound trading. The Client also acknowledges that despite any subsequent purported withdrawal of consent by the Client, the Client’s personal data may continue to be stored, used, disclosed, transferred and otherwise processed for the above purposes, whether before or after such purported withdrawal of consent

Consequences of failing to provide Personal Data or Consent
Failure to provide INNS with the Client’s personal data or consent as described above may mean that INNS will not, or no longer be able, as the case may be, to carry out the Client’s trading instructions or provide the Client with INNS’s China Connect securities trading service.

The Client acknowledges and agrees that INNS may collect, store, process, use, disclose and transfer personal data relating to the Client (including the Client’s CID and BCAN(s)) as required for INNS to provide services to the client in relation to securities listed or traded on the Stock Exchange of Hong Kong (SEHK) and for complying with the rules and requirements of SEHK and the Securities and Futures Commission (SFC) in effect from time to time. Without limiting the foregoing, this includes –

1. a) disclosing and transferring the client’s personal data (including CID and BCAN(s)) to SEHK and/or the SFC in accordance with the rules and requirements of SEHK and the SFC in effect from time to time;
2. b) allowing SEHK to: (i) collect, store, process and use the client’s personal data (including CID and BCAN(s)) for market surveillance and monitoring purposes and enforcement of the Rules of the Exchange of SEHK; and (ii) disclose and transfer such information to the relevant regulators and law enforcement agencies in Hong Kong (including, but not limited to, the SFC) so as to facilitate the performance of their statutory functions with respect to the Hong Kong financial markets; and (iii) use such information for conducting analysis for the purposes of market oversight; and
3. c) allowing the SFC to: (i) collect, store, process and use the client’s personal data (including CID and BCAN(s)) for the performance of its statutory functions including monitoring, surveillance and enforcement functions with respect to the Hong Kong financial markets; and (ii) disclose and transfer such information to relevant regulators and law enforcement agencies in Hong Kong in accordance with applicable laws or regulatory requirements.

The client agrees that despite any subsequent purported withdrawal of consent by the client, the client’s personal data may continue to be stored, processed, used, disclosed or transferred for the above purposes after such purported withdrawal of consent.

The client acknowledges that, failure to provide INNS with the client’s personal data or consent as described above may mean that INNS will not, or will no longer be able to, as the case may be, carry out the client’s trading instructions or provide to the client with securities related services (other than to sell, transfer out or withdraw the client’s existing holdings of securities, if any).

Note: The terms “BCAN” and “CID” used in this clause shall bear the meanings as defined in paragraph 5.6 of the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission.