1. Our Privacy Principles

Gain Miles Group Limited and its subsidiaries, being either Gain Miles Assurance Consultants Limited or Gain Miles Financial Planning Consultants Limited (collectively, “Company”, “GUM”, “we”, “our” or “us”) respect your legal rights of privacy when collecting, storing, using and transmitting personal data. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region. In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality.

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Pursuant to the Personal Data (Privacy) Ordinance (“Privacy Ordinance”), we write to inform customers and various other individuals (collectively “data subjects”) of the purpose for which data collected or to be collected by us will be used, customers’ rights in relation to their data and the parties to whom we may provide your personal data.  The purpose of this Statement is to establish the policies and practices of the Company’s commitment to protect the privacy of personal data in accordance with the provisions of the Privacy Ordinance. If there is any inconsistency between the English and Chinese version of this PICS, the English version shall prevail

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2. Purposes for which we will use your personal data

• 2.1 From time to time, it may be necessary for data subjects to supply the Company with data in connection with the opening or continuation of accounts, the provision of financial services or compliance with any laws, guidelines or requests issued by regulatory or other authorities.

• 2.2 Failure to supply such data may result in the Company being unable to open or continue the account or establish or continue the financial services.

• 2.3 Data is and will be collected from data subjects in the ordinary course of their relationship with the Company through the following channels:

  • directly from data subjects, for example, opening or continuation of accounts and the provision of financial services;

  • when data subjects call the Company, visit the website of the Company, using the mobile application or service of the Company, viewing the online commercials of the Company (some of the information will be collected through the use of cookies), or contact the Company by other means of communication;

  • consolidating and analyzing all the information obtained by the Company;

  • publicly available information.

• 2.4 The purposes for which data relating to data subjects may be used are as follows :-

  • the daily operation of accounts and other financial services provided to data subjects;

  • regular or special reviews are conducted from time to time;

  • creating and maintaining the Company's data matching, internal business and administrative purposes;

  • designing financial services or related products for data subjects' use;

  • meeting the requirements to make disclosure under the requirements of any law binding on the Company and for the purposes of any guidelines issued by regulatory or other authorities with which the Company is expected to comply;

  • enabling an actual or proposed assignee of the Company, or participant or sub-participant of the Company's rights in respect of data subjects to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;

  • marketing financial services or products of the Company and

  • purposes relating to each of the above

• 2.5 Data held by the Company relating to data subjects will be kept confidential but the Company may, at its sole discretion, provide such information to the following parties for the purposes set out in the above sub-clause:

  • any agent, contractor or third party service provider (whether in Hong Kong or elsewhere) who provides administrative, telecommunications, computer, payment,  securities clearing or other services to the Company in connection with the operation of its business;

  • any of the branches, subsidiaries, holding companies, associated companies controlled by or under common control with the Company, whether in Hong Kong or elsewhere; regulators, lawyers and auditors;

  • any other person under a duty of confidentiality to the Company, including any group company of the Company who has undertaken to keep such information confidential;

  • any financial institution and credit card issuing company with which you have or propose to have dealings;

  • any person to whom the Company is under an obligation to make disclosure under the requirements of any law binding on the Company or any of its branches;

  • any actual or proposed assignee of the Company or participant or sub-participant or transferee of the Company’s rights in respect of a customer; and

  • any person in accordance with any law, rule, regulation, order, ruling, judicial interpretation or directive (whether or not having the force of law) applicable to the Company, its agents and/or affiliates (whether in Hong Kong or elsewhere) from time to time, including without limitation, the requirements, codes, guidelines, policies, customs, practices, recommendations or requests (whether or not mandatory) of any Regulator binding on the Company or any of its branches.

• 3 Use of data in direct marketing

  • 3.1 The Company intends to use a data subject’s data in direct marketing and requires the data subject’s consent for that purpose. In this connection, please note that:

    • the name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of a data subject held by the Company from time to time may be used by the Company in direct marketing;

    • the classes of services, products and subjects may be marketed include financial related services and products;

    • the above services, products and subjects may be provided by the Company and/or:

      • the Company’s group companies; and

      • third party financial institutions, insurers, insurance services companies, securities and investment services providers; and

    • in addition to marketing the above services, products and subjects itself, the Company also intends to provide the data described in paragraph 3.1 (i) above to all or any of the persons described in paragraph 3.1 (iii) above for use by them in marketing those services, products and subjects;

  • 3.2 If a data subject does not wish the Company to use or provide to other persons his data for use in direct marketing as described above, the data subject may exercise his opt-out right by notifying the Company.

• 4  Security of Personal Data

  • It is the policy of the Company to ensure an appropriate level of protection for personal data in order to prevent unauthorized access, processing or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by unauthorized access to that data. It is the practice of the Company to achieve appropriate levels of security protection by restricting physical access to data by providing secure storage facilities, and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data. Data is only transmitted by secure means.

• 5 Accuracy of Personal Data

  • It is the policy of the Company to ensure accuracy of all personal data collected and processed by the Company. Appropriate procedures are implemented to provide for all personal data to be regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. In so far as personal data held by the Company consists of statements of opinion, all reasonably practicable steps are taken to ensure that any facts cited in support of such statements of opinion are correct.

• 6 Collection of Personal Data

  • In the course of collecting personal data, the Company will provide the individuals concerned with a Personal Information Collection Statement informing them of the purpose of collection, classes of persons to whom the data may be transferred, their rights to access and correct the data, and other relevant information.

• 7 Your Right to Access and Correct Personal Data

  • 7.1 It is the policy of the Company to comply with and process all data access and correction requests in accordance with the provisions of the Privacy Ordinance, and for all staff concerned to be familiar with the requirements for assisting individuals to make such requests.

  • 7.2 The Company may, subject to the Privacy Ordinance, impose a moderate fee for complying with a data access request. If a person making a data access request requires an additional copy of the personal data that the Company has previously supplied pursuant to an earlier data access request, the Company may charge a fee to cover the full administrative and other costs incurred in supplying that additional copy.

  • 7.3 Data access and correction requests to the Company may be addressed to the Personal Data Privacy Officer or other person as specifically advised.

• 8 Appointment of Personal Data Privacy Officer

  • 8.1 To co-ordinate and oversee compliance with the Privacy Ordinance and the personal data protection policies of the Company, a Personal Data Privacy Officer has been appointed by the Company.

  • 8.2 The contact details of the Personal Data Privacy Officer are as follows:
    Personal Data Privacy Officer

    Gain Miles Assurance Consultants Limited

    • ​Office A-D, 31/F, Legend Tower, 7 Shing Yip Street, Kwun Tong, Kowloon Tel.: (852) 3469 6928 

• 9 Retention of data

  Personal data provided by you are retained for as long as the purposes for which such data were collected continue. Data are then destroyed unless their retention is required to satisfy legal, regulatory or accounting requirements or to protect the Corporation’s interests.

• 10 This personal information collection statement is subject to change. Any changes will be posted on this page.

Last update: 17 April 2023