Privacy Statement


BOCOM Schroder Asset Management (Hong Kong) Company Limited ("we" / "us") recognises the importance of protecting your personal information when you visit this website (the "Website"). The following information is designed to help you understand the personal information collection practices at this Website.

Changes to this PICS

We reserve the right to change, modify, add, or remove portions of this PICS at any time for any reason. We suggest that you review this PICS periodically for changes. The current version of this PICS can be accessed from the link on our homepage, or at the bottom of our Website pages. We will post a message on our Website home page whenever an amendment is made to this PICS so that you will know when to check. You acknowledge that by accessing our Website after we have posted changes to this PICS, you are agreeing to the terms of the PICS as modified.

With respect to any expansion of the purposes of using your personally identifiable information received by us from the purposes as stated in this PICS, prior notice will be given to you and you have the right to decline acceptance of such expansion however in such circumstances our provision of continuing services to you may be limited.

Method of Information Collection and Information Collected

We may receive personally identifiable information you submit to or through our Website or through contact means as provided in the Website (e.g. the ["Contact Us"] page). Failure to provide such personally identifiable information may result in us being unable to provide you with the services or information requested or to answer your queries. The types of personally identifiable information that may be collected at our Website include information you provided to us (e.g. your name and email address).

We use "cookies" to collect and store information about your internet connection when you visit our Website. Cookies or other technology help us to provide customized services and information. "Cookies" are small files placed on your hard drive. Each website that you visit can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Website. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

The "cookies" may track and record information of your activities on our Website (including user's preference and behaviour, navigation on this Website, logged-on identity, etc.). When you are navigating this Website, we record your IP address.

If you would prefer not to accept cookies from us, you may set your browser accordingly. If you choose to disable cookies in your browser, you may not be able to access all pages on our Website.

Use of Personally Identifiable Information

The personally identifiable information you submit to or through our Website (or through contact means as provided in the Website) is used only for responding to your inquiry sent to us, for business administration, business reporting and statistical analysis purposes, and for other directly related purposes and your personally identifiable information may also be used for purposes set out in the paragraphs below headed "Aggregate Information", "Affiliates and Service Providers", "Compliance with Laws", and "Business Transfers" (together, the "Purposes").

We will not use your personally identifiable information for direct marketing purposes without first receiving your separate consent. We will not sell, share, rent or otherwise disclose or transfer your personally identifiable information to others for monetary gains. We will not provide your personally identifiable information to third parties or our affiliates for their marketing purposes without your separate consent. It is only voluntary for you to provide your personally identifiable information for marketing purposes in such circumstances.

With respect to your personal information collected through cookies, we will use such information to assess how and when pages in our Website are visited, what our users' technology preferences are (such as what type of video player they use), whether our Website is functioning properly and for systems, trouble shooting, administrative and reporting purposes. Such statistics are collected for the purpose of managing and improving the design of the website.

Additionally, you may encounter cookies or other similar devices on our Website that are placed by third party website tracking companies. In such circumstances the purpose and means of collection and retention policy of your personal identifiable information is the same as stated in this PICS and such information will not be transferred to any third parties except as provided under this PICS.

Aggregate Information: We generally record certain usage information, such as the number and frequency of visitors to our Website. This information may include the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your IP address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

We may also disclose details about the general use of our Website to third parties e.g. to demonstrate patterns of use to advertisers and other business partners. Information we pass on will not include any personal information by which you may be identified.

Affiliates and Service Providers: We may provide your personally identifiable information to our affiliates and other third party service providers (including information technology service providers) for the Purposes but not for any direct marketing purposes. By disclosing your personally identifiable information to us via this Website, you consent to our disclosing of your personally identifiable information to such parties both in your country of residence and outside your country of residence. These persons may have access to the personally identifiable information you submit through this Website, but only for the purpose of performing their duties specified in this paragraph. These persons may not use your personally identifiable information for any purpose other than those stated above.

Compliance with Laws: Except as otherwise provided in this PICS, we do not automatically collect personally identifiable information from visitors to our Website, except to the extent we are required to do so pursuant to any law or regulation binding on us. We will (and you authorize us to) disclose your personally identifiable information if we are required to make such a disclosure under applicable law or regulation, or where requested to do so by the police or by regulatory bodies, or where we wish to do so in relation to any suspected misuse by you of our Website, or of any of our Website services.

Business Transfers: If the business, stock or assets of us are acquired or merged with another business entity, we will share all or some of your information (including your personally identifiable information) with this other entity to continue to provide services to you. The new entity will inform you of any changes to the practices in this PICS. If the new entity wishes to make additional use of your information, it will inform you beforehand and you may decline such use at that time.

Third Party Websites

We are not responsible for the content or for the privacy policies and customer information practices of third party internet websites hyperlinked from our Website.


We endeavour to prevent unauthorised disclosures of your personally identifiable information by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority.

Retention Period: Your personally identifiable information will be retained by us for a period of 2 years after you last accessed the Website or we have last corresponded with you and your personally identifiable information will be erased after such retention period.

Privacy Preferences: This Website may contain information, including P3P privacy policies ("Privacy Preference Information"), intended to work with your selected privacy preferences. While we have tried to conform such Privacy Preference Information included within this Website to this full-text Privacy Statements, these Privacy Statements is the definitive statement of privacy policies and practices for this Website.

For Hong Kong residents – your rights under PDPO

Under and in accordance with the terms of the Personal Data (Privacy) Ordinance ("PDPO") of Hong Kong and codes and guidelines issued pursuant thereto, any individual:

(i) may check whether we hold personally identifiable information about him/her and may request access to such information;

(ii) may request us to correct any personally identifiable information relating to him/her which is inaccurate;

(iii) may request us to specify its policies and practices in relation to personally identifiable information and to be informed of the kind of personally identifiable information held by us; and

(iv) may object to the use of his/her personally identifiable information for marketing purposes (if applicable); we will not use his/her personally identifiable information for these purposes if he/she communicates his/her objection to us.

In accordance with the terms of PDPO, we have the right to charge a reasonable fee for the processing of any request for access or correction mentioned above.

The person to whom requests for (i) access to or correction of personally identifiable information or (ii) information regarding policies and practices and kinds of information held by us should be sent to our Data Protection Officer. Contact details of this Officer are set out below in the paragraph headed "Contact Us".

Nothing in this PICS shall limit your rights under the PDPO.

Contact Us

For more information on us and our personal information collection practices, please do not hesitate to contact us:

Hong Kong:

Data Protection Officer

BOCOM Schroder Asset Management (Hong Kong) Company Limited

Unit 1911, 19/F, The Center,

99 Queen's Road Central,Hong Kong

Latest updated: 24 July 2017